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IETA has submitted input to the United Nations Framework Convention on Climate Change (UNFCCC) Secretariat on the draft standard addressing reversals and non-permanence. It said that the current requirements risk excluding land-based removals from the mechanism.
In an exclusive interview with Fastmarkets on Wednesday August 6, IETA’s international policy director, Andrea Bonzanni, said that Option A in the draft standard would be unworkable for nature-based projects. The option would require projects to continue post-crediting monitoring indefinitely, unless they were to cancel all issued credits or demonstrate negligible reversal risk.
“The most problematic measure is the obligation to monitor indefinitely until the risk of a reversal is negligible,” Bonzanni told Fastmarkets. “For land-based activities, the probability of a reversal never becomes negligible. Any obligations that extend beyond the lifespan of a project are always problematic, let alone if they have no end date. An alternative mechanism must be found to ensure that reversals are addressed.”
The draft standard, titled “Draft standard: Addressing non-permanence and reversals,” was released by the Supervisory Body’s Methodological Expert Panel (MEP) in July 2025. A call for input on the draft document was issued, with any input received to be considered by the MEP at its next meeting in September.
It outlines permanence and liability requirements for eligible removals under the Article 6.4 mechanism, including two options for post-crediting monitoring. Option A requires indefinite obligations unless strict conditions are met, while Option B proposes a fixed minimum period of 45 years.
Bonzanni said that the current binary framing of permanence was not aligned with atmospheric science and may disadvantage nature-based solutions.
“We believe that liabilities for project proponents should be better grounded in a scientific understanding of the atmospheric effect of carbon dioxide [CO2] and its decay curve,” he said. “We know that 40% of a CO2 pulse is removed from the atmosphere within 20 years, and 60% within 100 years, while only about 25% persists beyond 1,000 years. The current binary approach suggested by the MEP is prohibitive for nature-based solutions, without even reflecting the best available science.”
IETA’s submission also pointed out that the Intergovernmental Panel on Climate Change (IPCC) does not define a fixed permanence threshold, instead describing CO2 atmospheric removal as a multi-timescale process.
IETA noted that the draft does not address the role of host countries, despite a prior mandate from the Supervisory Body to develop recommendations on this issue.
“We highlighted that the MEP was given a mandate to work on the role and responsibilities of host parties, but this mandate was not fulfilled,” Bonzanni said. “We believe that host countries could play a facilitative role by taking over some responsibilities that are too onerous for project proponents, especially over very long time horizons. We understand that some host country governments have sensitivities and reservations, but this should not be a reason to avoid the discussion.”
According to previous mandates in the Supervisory Body’s work program, the Methodological Expert Panel was tasked with developing recommendations on how host parties should participate in long-term oversight and accounting for removal activities. This was not included in the current draft.
Bonzanni noted that the consultation process was limited, and that stakeholders were given no visibility into related technical tools such as risk ratings, buffer pool design and liability provisions.
“These decisions are too important and too complex for the very short and technical consultation process the MEP is used to running,” Bonzanni said. “We propose that the UNFCCC Secretariat and the Supervisory Body run a more structured stakeholder engagement process with virtual and in-person workshops, where draft standards and decisions can be properly explained and the effect on stakeholders [can be] fully understood.
“And very importantly,” he added, “stakeholders should be given the opportunity to provide input on the full package of standards and tools. Instead, we have been asked to comment on a standard without any visibility on key elements such as risk ratings, buffer pool design and the role of host countries.”
Asked whether IETA would support differentiated permanence requirements based on project type or scale, Bonzanni said that some flexibility may be helpful, especially for vulnerable countries.
“Adopting the same approach to all types of activities is a cleaner solution, and we still believe that it is possible to implement requirements that are robust without excluding entire activity types. A more flexible approach for smaller projects, or projects in vulnerable countries, would be welcome. For instance, the Supervisory Body already implemented a fee waiver for PACM [Paris Agreement Crediting Mechanism] projects in the least developed countries.”
The PACM refers to the Article 6.4 mechanism established under the Paris Agreement to issue tradable emission reduction or removal credits.
On the overall framing of the draft options, Bonzanni added: “Option B is slightly better than Option A, but still problematic. In our view, the best course of action is to have an overall rethink of the approach taken by the MEP so far.”
The Article 6.4 Supervisory Body has previously approved registration and issuance fee exemptions for project activities in least developed countries and small island developing states under the Paris Agreement Crediting Mechanism.
Bonzanni declined to comment on whether IETA would support a formal mechanism under Article 6.4 to allow transfer of long-term liabilities in the event of land ownership changes or insolvency.
When asked about potential crediting and pricing effects from the current proposals, he said that “the inability to comply with perpetual monitoring obligations would result in a de facto ban on nature-based projects under Article 6.4.”
The Supervisory Body is continuing its consultation process on the permanence standard and other implementation tools for Article 6.4.
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