§1.1 — Ex-post delivery
The underlying activity must have already taken place, and its results, expressed in metric tonnes of CO₂e, must have been verified using observed monitoring data. No forward-issued or projected credits.
Aligns with: ICVCM CCP 7 · ISO 14068-1 §11.2 (ex-post rule) · CORSIA Criterion 3 · DEFRA Timing
§1.2 — Robust quantification
Mitigation outcomes must be quantified in tCO₂e using transparent, scientifically rigorous methods. Quantification must be conservative in its assumptions, complete in its coverage of all relevant gases, pools, and sources, and consistent with recognised standards. Baselines must be aligned with Paris Agreement principles and established transparently and conservatively using credible, verifiable evidence. Speculative counterfactual baselines — such as avoided emissions based on unobservable changes in customer behaviour — are explicitly excluded. Reported results must document data sources, methods, and assumptions, include an uncertainty assessment, and be reproducible by independent third parties.
Aligns with: ICVCM CCP 7 · ISO 14068-1 §11.2(c) · CORSIA Criterion 2 & 3
§1.3 — Additionality
The outcome would not have occurred without the intervention. Activities must not be financially viable, legally mandated, or fully financed under existing policies. To avoid creating barriers to investment in lower-income countries, activities can be aligned with, or contribute toward, a host country’s NDC — provided there is credible evidence that company support enables mitigation beyond what is already funded or committed under existing policies and measures. The draft explicitly states that corresponding adjustments under Paris Agreement Article 6 would not apply, since mitigation outcomes are framed as MIC claims rather than international transfers.
Aligns with: ICVCM CCP 5 · ISO 14068-1 §11.2(b) · CORSIA Criterion 1 · DEFRA Additionality
Note: CAs explicitly excluded under MIC framing — contrast with CORSIA Phase 1 requirement
§1.4 — Transparency and disclosure
Disclosure of the underlying activity type, methodology, key assumptions, uncertainty ranges, monitoring period, and the specific mitigation outcome delivered (emission reductions, carbon removals, or sink protection/enhancement, or a mix). This is the disclosure requirement that connects most directly to the ISO 14068-1 §11.4 documented information requirements.
Aligns with: ISO 14068-1 §11.4 · ICVCM CCP 3 · DEFRA Transparency
§1.5 — Vintage
Mitigation outcomes must be generated in respect of, or represent, mitigation from 2021 onward. This ensures that recognised outcomes reflect recent and relevant climate action, aligned with the timeframe of 1.5°C-consistent pathways and current standards of integrity.
Aligns with: ISO 14068-1 §11.2 (5-year rolling limit, different threshold) · CORSIA (Phase 1 vintage parameters)
Note: SBTi sets a fixed 2021 floor; ISO uses a rolling 5-year limit. For reporting year 2025, ISO permits vintage back to 2020; SBTi v2.0 requires 2021 onward. The SBTi floor is the binding constraint.
§1.6 — Avoidance of leakage
The substantiation mechanism must demonstrate how leakage has been assessed, quantified, and addressed. Mitigation outcomes must be designed and implemented to avoid or minimise leakage in accordance with recognised standards and good practice.
Aligns with: ICVCM CCP 5 (leakage component) · CORSIA Criterion 6 · DEFRA Avoiding leakage
§1.7 — Risk of reversal safeguards
Measures must be in place to manage the risk of reversal. This includes ongoing monitoring, transparent reporting on permanence and reversal events, and compensation mechanisms such as buffer pools, contractual make-good obligations, or insurance solutions. In land-based contexts, safeguards must be designed and implemented in line with social and environmental safeguards and the principles of Free, Prior and Informed Consent, to ensure they do not result in adverse impacts on rights or livelihoods.
Aligns with: ICVCM CCP 6 · ISO 14068-1 §11.2(d) · CORSIA Criterion 5 · DEFRA Permanence
§1.8 — Social and environmental safeguards
Underlying mitigation activities must be designed and implemented in accordance with internationally recognised safeguards embedded in the design and verification of the mechanism. This includes: respect for Free, Prior and Informed Consent of affected communities and landholders; protection of human rights, biodiversity, and environmental integrity; and fair and transparent benefit-sharing or compensation where applicable.
Aligns with: ICVCM CCP 9 · ISO 14068-1 §11.3(b) · CORSIA Criterion 8 (Do no net harm)
§1.9 — Independent verification
Claimed mitigation outcomes must be subject to credible, high-quality, independent assurance. Verification must be performed either by an accredited third party or through a substantiation mechanism that provides sufficient, transparent information for independent verification to be carried out. All verification opinions must be public to enable external scrutiny and challenge. For carbon credits specifically, this means validation and verification in line with recognised standards; neutral allocation of verification bodies to reduce conflicts of interest; and oversight mechanisms including meta-audits and sanctions for underperformance.
Aligns with: ICVCM CCP 4 · ISO 14068-1 §11.3(f) · CORSIA Criterion 3 · DEFRA Validation and verification