Allocation, provenance, and certificate recognition shape provider-country confidence in the digital sequence information (DSI) Multilateral Mechanism
First published on 09/22/2026, and last updated on 09/23/2026
By June Rubis
Macquarie University Research Fellow, Australia; Co-Founder, Building Initiatives in Indigenous Heritage (BiiH), Sarawak; and Honorary Member, ICCA Consortium
The success of the Multilateral Mechanism for the Fair and Equitable Sharing of Benefits from the Use of Digital Sequence Information on Genetic Resources (the Multilateral Mechanism) under the Convention on Biological Diversity (CBD) depends on confidence across different parts of the system. Potential contributors need clarity that the Mechanism is workable and predictable. Provider countries, in turn, need confidence that multilateral benefit-sharing will continue to reflect their interests as digital sequence information (DSI) circulates and acquires value increasingly far from its biological origins. For Indigenous Peoples and local communities, a further question is whether the benefits and governance arrangements of the Mechanism meaningfully respond to their distinct rights, needs, and relationships with biodiversity.
Confidence across the Mechanism is interdependent but it is not symmetrical. Contributors, provider countries, researchers and database managers, and Indigenous Peoples and local communities occupy different positions within implementation with unequal power, resources, and institutional capacity. Technical choices can reinforce or mitigate these differences, and these categories are not internally uniform.
Why this matters for Indigenous Peoples and local communities
Indigenous Peoples and local communities have an interest in a multilateral mechanism in which the provider side of Access and Benefit-sharing (ABS) remains meaningful. Strong provider-country engagement can help preserve the political space in which biodiversity, provenance and benefit-sharing continue to matter. The commitment to support the self-identified needs of Indigenous Peoples and local communities, however, requires its own assurance: that Indigenous Peoples and local communities can meaningfully identify their needs, access resources and participate in shaping the arrangements through which support reaches them.
In this commentary, provider country is used as political shorthand for countries advancing provider-side interests within the Access and Benefit-sharing (ABS) bargain, rather than as a synonym for developing countries or the global South, or as a claim about where DSI is generated. The CBD’s formal category of a “country providing genetic resources” is not restricted by development status (Convention on Biological Diversity [CBD], 1992). Patterns of DSI provision and use do not map neatly onto North–South lines (Scholz et al., 2021). The discussion focuses particularly on developing-country provider-side concerns because these have been prominent in the DSI negotiations and are especially relevant to the allocation and implementation architecture established under Decision 16/2 (CBD, 2024).
Five principles for sustaining provider-country confidence
- Confidence has to work in both directions
A durable Multilateral Mechanism depends on confidence among contributors that participation is workable, predictable, and worthwhile. It also depends on provider countries having confidence that multilateral benefit-sharing will continue to protect their interests as implementation develops. - Provenance and multilateralism should reinforce rather than displace one another
The difficulty of reconstructing every downstream use is one of the strongest arguments for multilateral benefit-sharing: provider countries should not have to identify and prove every downstream use of their biological information in order to share fairly in benefits. But provenance still matters for attribution, accountability, national ABS systems, and provider or community relationships. Multilateralism is strongest when it uses provenance where it exists and provides a credible benefit-sharing architecture where it cannot carry the full burden. - Allocation and distribution are different parts of fair and equitable benefit-sharing
Allocation determines how pooled benefits are divided and where resources go. Distribution concerns whether intended beneficiaries can access those resources, how priorities are identified, and who has agency over delivery. A credible multilateral bargain therefore requires both a defensible allocation methodology and workable pathways through which benefits can reach those they are intended to support. - Provider-country confidence rests on more than one form of leverage
Provider countries do not encounter the Multilateral Mechanism from the same position. Some have national ABS or DSI systems capable of giving certificates practical effect; others depend more heavily on allocation, access, and wider governance. A durable Mechanism has to sustain confidence across these positions without allowing differences in regulatory capacity to determine whose interests become central in implementation. - Future-proofing must preserve the benefit-sharing bargain over time
Scientific and technological change may alter how DSI is used and turned into value. Future-proofing therefore has to ensure not only that rules remain workable for businesses and researchers, but also that the Multilateral Mechanism can continue generating and sharing benefits as technologies, forms of use, and sources of value change.
The Multilateral Mechanism for the Fair and Equitable Sharing of Benefits from the Use of Digital Sequence Information on Genetic Resources is moving from a political agreement into a more developed phase of implementation. As the first biennium draws to a close, there is an opportunity to look at how the original political bargain is being carried through in the operationalization of the Cali Fund, and more broadly in the way the Mechanism is being developed.
The provider-country frame used here does not assume a simple geography in which the global South supplies DSI and the global North uses it. DSI provision and use do not map neatly onto North–South lines. The concern is with provider-side interests in the multilateral bargain, particularly developing-country concerns that have been prominent in the negotiations and are directly relevant to allocation and implementation under Decision 16/2 (Ramakrishnan, 2026a; Scholz et al., 2021; Third World Network, 2026)
The first phase of implementation has understandably concentrated on operationalizing the Cali Fund. That work now brings wider questions into view: how the Multilateral Mechanism relates to national ABS systems, how provenance is treated, how benefits are allocated and distributed, and what confidence provider countries can place in the bargain over time.
Substantial attention has also gone into understanding what companies need in order to participate: clarity around contribution conditions, recognition, certificates, legal certainty, and a commercially viable business case. This is necessary, but it is only one side of the bargain.
Provider-country confidence was part of the political bargain that established the Multilateral Mechanism, yet less attention has been given to what sustains it through implementation. The seventh meeting of the CBD Subsidiary Body on Implementation (SBI-7) made that gap more visible. A durable capitalization strategy depends not only on a workable route to contribution, but also on whether countries with provider-side interests regard the Mechanism as politically credible and capable of delivering benefit-sharing.
What SBI-7 made visible
Interventions advancing provider-side concerns raised questions about governance and political oversight, national ABS systems, database accountability, provenance and allocation. Third World Network’s reporting records the African Group and other developing-country groupings calling for stronger Party oversight of Cali Fund arrangements and for implementation to remain anchored in Decision 16/2 and provider-country rights (Ramakrishnan, 2026b, 2026c).
These interventions showed that operational questions cannot always be separated neatly from the wider Mechanism. Choices about traceability, attribution, legal certainty, and alignment with national ABS systems can shape its architecture.
Technical choices can therefore carry political consequences (Makowska-Curran, 2026). Provenance is one of the clearest places where this tension appears.
Engaging the provenance question
Provenance supports scientific integrity, transparency, and attribution, and can matter to national ABS systems and to the rights and interests of Indigenous Peoples and local communities. The DSI Scientific Network has recognized roles for geographical-origin information in providing scientific context, supporting transparency and attribution, identifying inequities, and supporting recognition of DSI associated with Indigenous Peoples and local communities (Raposo et al., 2023).
Database practice is also changing. The International Nucleotide Sequence Database Collaboration (INSDC) began introducing mandatory country/location and collection-date metadata for new submissions in 2023 and extended the standard across remaining submission routes by the end of 2024, subject to specified exemptions. A 2026 analysis found geographical collection information for 46% of sequences submitted over the previous five years, compared with about 17% of the full corpus: meaningful improvement alongside a substantial legacy gap (International Nucleotide Sequence Database Collaboration [INSDC], 2023; Raposo et al., 2026).
A geographic field is not, however, complete provenance. INSDC’s /geo_loc_name qualifier records where a sample was isolated or collected (INSDC, 2024). It does not by itself establish the provider country in ABS terms, identify a source collection, Indigenous territory or community relationship, or record the authority and conditions under which material or knowledge was shared. Allocation modeling also shows that using INSDC sequence counts as a proxy for geographic origin can cause the criterion to reflect sequencing and data infrastructure rather than the geographic origin of the underlying biological material (Makowska-Curran, 2026).
Improving provenance need not turn it into a basis for sequence-by-sequence payment. Useful steps include clearer distinctions between collection locality and provider-country relationships; stronger links to source collections, permits, or other records where available; persistent identifiers across infrastructures; and clarity about whether information is unknown, unavailable, or simply not provided. These are also capacity questions (INSDC, 2023, 2024; Ramakrishnan, 2026a; Raposo et al., 2026).
There are real technical difficulties when DSI moves through large datasets, is combined across origins, and undergoes computational transformation (Faggionato et al., 2024). But those difficulties are also shaped by database design, provenance requirements, user accountability and the capacity to maintain those systems (INSDC, 2023, 2024; Ramakrishnan, 2026a; Raposo et al., 2026).
Provider countries are therefore asking what provenance is recorded, whether it remains connected as DSI circulates, how available information will be treated, and how their interests will be protected when provenance becomes mixed, transformed, or incomplete.
Approaching provenance defensively can deepen distrust. If multilateralism is defended mainly because downstream tracing is impracticable, improvements in metadata, persistent identifiers, or database connectivity can strengthen arguments for stronger national approaches. Better provenance and multilateral benefit-sharing need not be opposites. Using provenance where it is available can support attribution, accountability, and provider confidence even where monetary benefit-sharing does not depend on reconstructing every downstream use.
Provider confidence will be strengthened by engaging the provenance question directly and showing how the Multilateral Mechanism protects provider interests where provenance is available and where it becomes increasingly difficult to follow.
Strengthening the provider-country case in implementation
If implementation is assessed mainly through contributor confidence, industry clarity, and commercial participation, the provider side of the political bargain remains underdeveloped. Provider confidence needs to be considered explicitly in how national ABS measures interact with the Mechanism, whether benefits can be realized without disproportionate monitoring burdens, and whether the system remains credible as technologies change. Non-monetary benefits, research relationships, and access to resulting products and services can also form part of the ABS relationship (Ramakrishnan, 2026a).
Certificate recognition offers one practical test. Its value to users will depend in part on whether Parties recognize or otherwise give certificates effect within domestic legal and policy frameworks, making national implementation part of the provider-country confidence question taken up below in relation to allocation (Brazil, 2026; Like-Minded Megadiverse Countries, 2026; South Africa, 2026).
Artificial intelligence (AI), synthetic biology, and other areas of biotechnology are changing how biological information can be analyzed, combined, and used. Future value may lie increasingly in datasets, models, and combinations of information rather than individual sequences. The uncertainty is not which sequences become more valuable, but the changing ways value is being generated from biological information (Faggionato et al., 2024).
The DSI Scientific Network frames part of this challenge as future-proofing: the Mechanism needs to remain workable as AI and other technologies develop, especially where global datasets and computational outputs complicate attribution across legal regimes (Faggionato et al., 2024). Multilateral approaches can also preserve open access and reduce transaction costs without requiring a bilateral permission-and-payment relationship for every sequence and user transaction (Scholz et al., 2022).
Provider countries face the same technological future from another position. They may have little ability to know in advance which biological information will acquire substantial value or to identify every dataset, transformation, company, and jurisdiction through which it later travels.
That is precisely where the positive provider-country case for multilateralism begins.
A country’s ability to share in the benefits of the DSI economy should not depend on its ability to discover and prove every downstream use.
This matters particularly for biodiversity-rich countries with more limited scientific, regulatory, or enforcement capacity. A system requiring providers to find commercial uses, reconstruct data chains, and establish claims across jurisdictions can reproduce inequalities, favoring countries best able to monitor the global DSI economy (Ramakrishnan, 2026a; Third World Network, 2026).
Multilateralism offers another route: benefit-sharing can be organized around the global DSI system without requiring benefits to be attributed sequence by sequence to individual downstream uses (Scholz et al., 2022).
Future-proofing the multilateral bargain
Future-proofing therefore has to work in both directions: businesses need rules that remain workable as innovation develops, while provider countries need confidence that the Mechanism will continue generating and delivering benefits. One place where this two-sided bargain becomes concrete is allocation.
The allocation question: criteria, weighting, provider confidence, and certificate recognition
Allocation is usually approached as a question of how pooled benefits should be distributed. Decision 16/2 identifies an indicative set of criteria: biodiversity richness and other biodiversity-related measures; the geographical origin of the genetic resources from which DSI was derived; and capacity needs for conservation and sustainable use, taking into account the circumstances of developing country Parties, in particular least developed countries and small island developing States, Parties with economies in transition, and Indigenous Peoples and local communities (CBD, 2024).
The 2026 Ad Hoc Technical Expert Group (AHTEG) retained geographic origin but identified a current lack of applicable data for operationalizing the criterion (CBD, 2026). Any future proxy therefore matters: Makowska-Curran’s modeling shows how an apparent “origin” criterion can begin to reflect sequencing and data infrastructure instead (Makowska-Curran, 2026).
The political stakes lie partly in weighting and partly in how biodiversity is measured. Using the Global Environment Facility’s GEF-8 Global Benefits Index for Biodiversity, the AHTEG found that increasing the weight given to biodiversity raised allocations most for large megadiverse countries, which were already receiving the largest allocations in its models (CBD, 2026). This shows that, under the AHTEG methodology, the weight assigned to biodiversity has direct distributive consequences for megadiverse countries.
A separate modeling exercise using the Biodiversity Habitat Index (BHI) illustrates a different point: the distributive effect of a biodiversity criterion also depends on what the indicator measures. BHI reflects projected species persistence under current habitat condition, connectivity, and compositional heterogeneity, rather than functioning as a direct measure of megadiversity. Makowska-Curran found that changing the biodiversity weight had a more limited effect on the overall North–South allocation pattern, while under biodiversity-only weighting African States, Asia-Pacific, and Latin America and the Caribbean were the principal regional beneficiaries (Makowska-Curran, 2026). Her analysis also shows that formula and normalization can materially alter allocation outcomes even where stated weights remain unchanged (Makowska-Curran, 2026).
Taken together, these exercises distinguish two questions: how much weight biodiversity receives, and what the chosen biodiversity indicator actually measures. Both can materially affect who benefits.
Half of the country-allocation pool is first distributed through an equality base, which moderates the largest allocations, while biodiversity is one of several criteria applied to the remaining half. Some megadiverse provider countries may therefore still regard the resulting allocation as not sufficiently reflective of the provider-side contribution represented by their biodiversity. Weighting and measurement therefore do different work: the weight assigned to biodiversity determines its influence on allocation, while the indicator chosen determines which dimensions of biodiversity become consequential within it. The methodology must also accommodate equity, capacity, and wider distributive considerations.
The AHTEG recommended future work towards a biodiversity stewardship index encompassing biodiversity, geographic origin, and traditional knowledge and the contributions of Indigenous Peoples and local communities to biodiversity conservation and sustainable use (CBD, 2026). This raises a further design question: how should those distinct contributions be brought together without obscuring what each is intended to recognize? In particular, how should an integrated stewardship index retain meaningful recognition of biodiversity richness while also recognizing Indigenous Peoples’ and local communities’ knowledge, governance, and contributions to biodiversity conservation and sustainable use?
Biodiversity weighting is not a single distributive choice. Its effect depends both on how much weight biodiversity receives and on what the chosen indicator measures. These choices can favor different countries and embody different judgments about how provider-side biodiversity interests, equity, and capacity should be balanced.
Decision 16/2 also gives allocation wider distributive purposes. It directs funding towards the objectives of the Convention in developing country Parties, especially least developed countries and small island developing States, and provides that, where appropriate and subject to national circumstances and legislation, at least half of funding should support the self-identified needs of Indigenous Peoples and local communities (CBD, 2024). Biodiversity richness and other biodiversity-related measures therefore sit alongside capacity, equity, and other distributive considerations.
Certificate recognition adds another dimension. At SBI-7, South Africa, on behalf of the Like-Minded Megadiverse Countries, called for certificates to be verifiable, meaningful, and recognized by national ABS authorities (Like-Minded Megadiverse Countries, 2026). In its national statement, South Africa further warned that without clear verification and recognition procedures, certificates may not be usable by national ABS authorities in provider countries (South Africa, 2026). Brazil described certificates as important to avoiding overlapping commitments and making the Fund attractive to private-sector participation, and argued that allocation methodology should give due weight to countries’ biodiversity and the global environmental benefits it provides (Brazil, 2026).
These interventions do not establish a direct causal relationship between allocation preferences and domestic certificate recognition. They do show why allocation, certificate design, and national implementation cannot be treated as entirely separate political questions. Where national ABS or DSI systems may give certificates practical value, countries may judge allocation alongside what they are being asked to provide through national implementation. If the provider side is seen as weakly reflected, confidence in the wider Mechanism may suffer; narrower domestic recognition could in turn weaken both the legal certainty sought by users and the incentives for contributions.
Implementation creates a different risk of narrowing. Beginning with countries able to give certificates immediate practical effect may be useful, but it can privilege countries with stronger national DSI or ABS measures. Other provider countries may have less regulatory leverage even where their stake in the bargain is substantial and may depend more heavily on allocation, distribution, and wider governance.
The challenge is therefore to avoid two forms of narrowing: an allocation methodology in which the biodiversity and provider-side relationship at the heart of ABS becomes too weak to sustain confidence among some provider countries, and an implementation pathway in which differences in regulatory capacity disproportionately shape which provider countries become most politically consequential. These concerns point in different directions, but belong to the same multilateral problem.
Working initially with willing countries may still help demonstrate how certificate recognition works (European Commission et al., 2026). But those relationships should not define the wider bargain. Multilateral implementation has to sustain confidence both where certificates have immediate legal value and where the principal stake lies in how benefits are allocated, accessed, and governed.
Allocation is therefore part of what holds the bargain together: it affects how Parties understand the value and reciprocity of benefit-sharing, while national recognition affects the practical value of certificates to users. Provider and contributor confidence are interdependent.
Allocation and access are needed to complete the multilateral bargain. Country shares alone are not enough; provider countries also need benefits to be accessible in a timely, workable, and sufficiently direct manner.
Decision 16/2’s provision that, where appropriate and subject to national circumstances and legislation, at least half of Cali Fund resources should support the self-identified needs of Indigenous Peoples and local communities, makes this distinction concrete (CBD, 2024). Allocation determines where resources go, but not who shapes priorities or how delivery is designed. Those are distribution and governance questions, and arrangements for Indigenous Peoples and local communities need to preserve meaningful agency over priority-setting, access, and delivery.
Contributors should not have to trace every sequence in order to contribute. Provider countries should not have to identify and prove every downstream use in order to benefit.
A multilateral system asks countries to rely partly on collective benefit-sharing rather than pursue every downstream use. That bargain is credible only if pooled benefits are fairly allocated and practically accessible, with meaningful agency in priority-setting and the governance of delivery.
The enabling conditions and review of effectiveness therefore need to keep political ownership, national implementation, and provider-country confidence visible alongside contributor concerns.
A further question for future-proofing
A final future-proofing question concerns the living biological base from which future DSI will emerge. Existing DSI records information already generated and sampled; living biodiversity continues to evolve and contains biological variation not yet sampled or represented in any database. Maintaining biodiversity therefore matters not only to conservation, but also to the future scientific and commercial value on which the DSI economy may draw.
The Multilateral Mechanism will be strongest when it preserves a meaningful provider-side connection in allocation without allowing differences in regulatory capacity to disproportionately shape whose interests become central in implementation.
Sustaining confidence through implementation
The Multilateral Mechanism for the Fair and Equitable Sharing of Benefits from the Use of Digital Sequence Information on Genetic Resources has to carry a political bargain across countries differently positioned in relation to DSI. Certain provider countries have national ABS or DSI systems able to give certificates practical effect; others rely more heavily on allocation, access, and wider governance. Implementation has to sustain both.
The two forms of narrowing identified above therefore matter to the durability of the Mechanism. Provider-country confidence cannot be inferred from contributor participation or secured through allocation alone. The country-allocation methodology determines country shares, but not the wider arrangements through which benefits are accessed, prioritized, and delivered (Makowska-Curran, 2026). The provision for Indigenous Peoples and local communities also raises distinct questions of allocation, access, and governance (CBD, 2024).
Provider and contributor confidence are interdependent without being identical. Work on capitalization, certificates, and legal certainty will be more durable when provider countries can see what multilateralism protects for them through national recognition, meaningful allocation, practical access to benefits and wider governance.
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DOI: https://doi.org/10.70841/CM7U68. © 2026 The Author. Published by the ICCA Consortium.
Published under the terms of the Creative Commons Attribution-NonCommercial 4.0 International license.
Reviewed by: Jasmine Kindness and other reviewers who wished to remain anonymous
Copyediting: Jessica Merriman
Editorial Lead: Mohammad Arju
The author is deeply grateful to the peer reviewers whose thoughtful comments, challenges, and suggestions greatly strengthened this paper.
Correspondence concerning this article should be addressed to June Rubis at jrubis@gmail.com
The views expressed in this commentary are those of the author and do not necessarily reflect the views or policy positions of the ICCA Consortium.
Recommended citation: Rubis, J. (2026). Sustaining Provider-Country Confidence in the Multilateral Mechanism for Digital Sequence Information on Genetic Resources (On Governance). ICCA Consortium. https://doi.org/10.70841/CM7U68
