The global uptake of renewable technology is both dramatic and insufficient to achieve a 2-degree world by 2050. Urgently decarbonizing energy use and systems by shifting to renewables relies on intensifying global value chains, beginning with the extraction of minerals and metals primarily from developing countries. Largely devoid of intergovernmental oversight, this paper examines how the global shift to renewable energy is primarily being governed transnationally. We argue that there are ‘governance gaps’ and ‘accountability traps’ in the regulation of renewables. Governance gaps refer to an absence of protective norms in relation to our knowledge of state, industry, and voluntary activity. There are demonstrable gaps upstream and downstream of global value chains for renewable energy, in contrast to a few highly visible energy initiatives where governance is concentrated.

We develop a database of transnational regulations for the extraction of minerals and metals needed for the global value chains of onshore wind, solar PV, and lithium-ion batteries which are driving the renewables uptake. Public, private, and voluntary actors are establishing transnational regulations, which accords with broader trends in global environmental governance. These actors have different normative logics that drive regulatory design and the goals they seek to achieve, including what actors are willing to be held to account for. The transnational regulation database reveals accountability traps: most regulations for minerals for renewables are public, voluntary, market-based, transnational initiatives with little output accountability. This focuses on what can be done at the margins of oversight in the race to secure raw materials, rather than what should be done to mitigate harm from renewable energy. This reveals how governance gaps and accountability traps became taken as given, and how a climate emergency can defer questions of process and justice.