The champions of Article 6 carbon markets used the opportunity of the Bonn climate conference to push, ahead of COP31, for a “learning by doing” approach. This happy-go-lucky attitude would spell double trouble for the climate and society.

Although the only carbon market item officially under negotiation in Bonn concerned the funding arrangements for Article 6.2, which allows countries to trade emission reductions and removals, a full Article 6 Day, organised by the UNFCCC,  took place on day one of the conference. 

The event seemed specifically designed to reassure attendees that the shortcomings of carbon credit markets are now largely a thing of the past, and that it is okay to approach engagement under Article 6 with a ‘learning by doing’ process. Notably, according to the UNFCCC Mitigation Division chief James Grabert, the day was not about revisiting design; it was about boosting confidence in the current design. 

But can confidence be built on the current shaky foundations? 

House of credits

Article 6 is plagued by a lack of climate ambition and the absence of robust safeguards, especially in the Article 6.2 rules. This inadequate approach risks real negative consequences for the climate and for indigenous peoples and local communities.

Evidence of these shaky foundations appears in the findings of the UN’s own Article 6 review process. Just before and during the conference, the UNFCCC released the latest batch of reviews covering countries’ carbon credit trading reports under Article 6.2, which exposed the inadequacy of many of these trades and the architecture underpinning them.

Last year’s technical expert reviews covered the reports of Switzerland, Thailand, Vanuatu, Ghana, and Guyana, while the latest batch covers those of the Maldives, Palau, Tunisia, Sri Lanka, Mongolia, Cambodia, Rwanda, and Malawi. The new round of reviews paints a sobering picture of the current state of Article 6.2. UN reviewers found issues related to environmental integrity in every single report they evaluated, which was also the case for batch number one, as our analysis reveals. This means that none of the current deals on the table provides sufficient confidence that they will deliver high-quality carbon credits or benefit the climate, raising concerns among negotiators and observers alike.

At COP29 in Baku, additional, supplementary reporting requirements were agreed upon by countries. Fulfilling these requirements would have countries provide crucial details about their cooperative approaches, such as public participation and scrutiny, as well as environmental integrity. However, not a single country chose to give information on these requirements. This leaves both reviewers and observers in the dark. This is not about finger-pointing at the countries reviewed, but rather about acknowledging far more structural issues stemming from the laissez-faire approach of the current Article 6.2 rules. Some negotiators seem to be realising this and have begun laying the groundwork for 2028, when the Article 6 rulebook will be renegotiated, by offering suggestions for improvements.

No implementation without participation 

In another conference room in Bonn, the Article 6.4 Supervisory Body announced a measly two-week public consultation period for the Sustainable Development (SD) Tool, which is meant to safeguard, among other things, the rights of local communities and indigenous peoples. Many stakeholders had previously voiced their concerns regarding the tool’s current design. This includes a submission by CMW based on a recent analysis conducted in collaboration with the Land Matrix Initiative. 

While the Supervisory Body claims there are already ample opportunities to raise issues, the COP30 Article 6 decision explicitly mandates that a broader spectrum of stakeholders can actually participate in the mechanism. This requires more than just reminders about existing procedures; it requires active efforts from the Supervisory Body to lower the barriers to participation, such as by announcing calls for input in more languages and distributing them through regional networks, as well as ensuring that network-based groups, especially those in the Global South, get enough time to reach out to their constituents to coordinate and submit a response.

Another issue for the Supervisory Body to address is the transition of Clean Development Mechanism projects to the Paris Agreement Crediting Mechanism (PACM) under Article 6.4. With the deadline for host countries to approve such transitions coming up in a matter of days, an analysis by Carbon Market Watch, as well as a report from the Global Forest Coalition, both published during the Bonn intersessional conference, show the serious environmental and human rights shortcomings of the first batches of projects.

Fix Article 6

Immediate course correction is required: while a U-turn would be appropriate for Article 6.2, Article 6.4 also needs some serious steering. Countries must realise that to transition away from flawed legacy systems, we have to do things differently, and do them differently from the outset. 

Fixing the environmental and social flaws of Article 6 cannot be a ‘learning by doing’ process, as this will result in preventable errors that we know will occur after the decades of experience we have acquired with what works and what does not. The UNFCCC and member countries must listen to the science, learn from past mistakes, and aim to get it right, right away. This also means they cannot rush to declare a system riddled with structural flaws and shortcomings “ready for business”. 

There are also faint, but crucial, signs of a shifting tide. In Bonn, those signs included growing concern over the review findings – not only from observers, but also countries – as well as negotiators’ subtle attempts to identify where improvements will be possible during the 2028 review. And in a broader context, actions like Kenya’s refusal to authorise hot air credits because of the impact on its climate goals are similarly telling. They all suggest that the current trajectory may be challenged at COP31 in Turkey, where, hopefully, more countries will dare to face the fact that Article 6 needs some serious fixing