This paper considers whether the implementation of mitigation action (MA) policy in developing countries would be subject to similar impediments as other (non-mitigation related) public policy interventions. It focuses on case studies from Brazil, Chile, Colombia and Peru. Variables identified as having the potential to pose risks to the implementation of MAs include finance, technical capacity, vested interests, and social acceptance of the policies. This paper proposes that MAs are more likely to be implemented if the possible impediments or risks to implementation are considered earlier in the planning and selection stages. It concludes that more attempts at implementing MAs need to be made and there need to be more policies with this explicit aim. This working paper forms a basis for further research that considers policy and implementation.