As countries have started trading carbon credits under Article 6 of the Paris Agreement, they are required to submit Initial Reports (IRs), documents containing information on their carbon credit trades. Those documents are then subject to a review, which verifies whether the information that countries are reporting is in line with Article 6 reporting requirements.
Our report analyses the reviews that have taken place so far. All reviewed IRs have been found to be inconsistent with current requirements. This is especially worrying considering that the current Article 6 rulebook sets an extremely low bar.
Our analysis finds that the weak transparency rules and the limited mandate of reviewers undermine a review process that is more like a tick the box exercise. The reviewers’ mandate severely limits what they can say, even in the presence of outrageously low quality credits. We provide several case studies that analyse what reviewers say in their comments and what it means. This report gathers and analyses case studies, and finds that the reviewers right now are like a referee without yellow or red cards.
Furthermore, our analysis of the first Article 6.2 review round also shows that rules are too weak to guarantee accountability and the review process is ineffective at addressing any of the problematic elements that clearly emerged so far in Article 6 international trades. We provide recommendations on how the review process should be strengthened in 2028 when all the existing Article 6 rules are open for revision and possible renegotiation.
