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The climate agenda includes a movement to build and implement commitments, policies and actions at the national and sub-national levels. From this, the complex aspects of climate change are perceived and emphasized with the intergovernmental nature of the system of political-territorial organization of countries. The concept of complex intergovernmental problem (CIP) was introduced in 2020 by Paquet and Scherzer to address the COVID-19 pandemic, and this article seeks to transpose the approach to climate change Based on a case study, the article reflects on climate change as a CIP and analyzes the proposition of the Climate Action Plan of the Municipality of São Paulo – Planclima in the face of the Brazilian federative pact. For the theoretical discussion, the concepts of federalism, climate governance, complex problem and CIP are addressed. Through document analysis, a summary table of climate change as a CIP was obtained.
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