Morningside Campus Status Updates

Current Access Level “I” – ID Only: CUID holders, alumni, and approved guests only

  • Campus open to active affiliate Columbia University ID (CUID) holders and approved guests only.
  • Columbia students, faculty, and staff can use the guest registration portal to register up to two same-day guests. Alumni can use the portal to register for campus same-day access as well. Learn more below.

News

Explore our expert insights and analysis in leading energy and climate news stories.

Energy Explained

Get the latest as our experts share their insights on global energy policy.

Podcasts

Hear in-depth conversations with the world’s top energy and climate leaders from government, business, academia, and civil society.

Events

Find out more about our upcoming and past events.

Finance & Economics

How to Fully Operationalize Article 6 of the Paris Agreement

Commentary by Gautam Jain & Shubham Deshmukh • September 11, 2025

This commentary represents the research and views of the author. It does not necessarily represent the views of the Center on Global Energy Policy. The piece may be subject to further revision. Contributions to SIPA for the benefit of CGEP are general use gifts, which gives the Center discretion in how it allocates these funds. More information is available at Our Partners. Rare cases of sponsored projects are clearly indicated.

Acknowledgments: The authors are grateful to Josh Zoffer, Ned Shell, and the anonymous reviewers for their valuable comments on an earlier draft, as well as to the Center on Global Energy Policy publications team for their thoughtful and detailed editorial work.


  • Article 6 of the Paris Agreement introduced a framework for voluntary cooperation between countries to reduce emissions, primarily using carbon markets, but putting it into practice has been difficult.
  • While one transfer of carbon credits between two countries has occurred and there is broad agreement on key methodologies, such as for what constitutes additionality, further action is needed to close operational, governance, and capacity gaps.
  • For a carbon credit market to become viable and scale up, high environmental integrity and investor protection is required, which necessitates establishing enforcement authority as well as capacity building for emerging economies’ participation, among other steps.

A key component of the Paris Agreement[i] is Article 6, which introduces a framework to facilitate voluntary cooperation between―primarily using carbon credit trading―to help achieve their nationally determined contributions (NDCs) more cost-effectively.[ii] Within Article 6, sections 6.2 and 6.4 are the most pertinent to achieve this objective. Article 6.2 establishes a decentralized framework for bilateral trading of carbon units―called Internationally Transferred Mitigation Outcomes (ITMOs)―between countries.[iii] Article 6.4, meanwhile, is attempting to create a centralized, United Nations-supervised global carbon market.[iv] While the 1997 Kyoto Protocol established a similar centralized mechanism via the Clean Development Mechanism (CDM), it faced a host of criticisms for its subjective methodologies,[v] which Article 6.4 aims to address with stricter standards.

Although the Article 6 framework was established at the United Nations climate change conference in 2015 (COP21), it lacked specifics, making implementation a challenge. It was not until COP26 in 2021 that the Article 6 rulebook was adopted.[vi] Among the key outcomes achieved were: an agreement on the eligibility and approval processes for projects and activities under Article 6.4; requirements to avoid double counting of emission reductions when credits are transferred between countries;[vii] rules for transitioning eligible CDM credits into the new Article 6.4 mechanism;[viii] and enhanced transparency, reporting, and review processes to track the implementation of Article 6 activities.[ix]

While the rulebook’s adoption marked the completion of the Paris Agreement’s implementation framework,[x] operationalizing these mechanisms has remained elusive because of persistent disagreements over methodological standards and governance issues. This commentary discusses the broader objective of Article 6 before delving into challenges associated with it, and concludes with possible actions to prioritize for negotiation, including at this year’s COP30, to help close operational gaps. To fully unlock Article 6’s potential, negotiations could include: enforcing robust methodological tests for additionality and baseline-setting, mandating buffer pools and insurance mechanisms for carbon removal activities, ensuring transitioned CDM credits meet strengthened quality criteria, improving transparency through stricter reporting and accountability requirements, authorizing oversight bodies to impose penalties for non-compliance, and providing technical support to facilitate the implementation process in low-income nations.

The Objective of Article 6

Article 6 aims to facilitate the use of carbon markets, which allow countries and private entities to trade credits for the reduction or removal of carbon dioxide or other greenhouse gas emissions. While governments act as buyers and sellers, authorized project developers can supply the credits for sale by the host country, and similarly, a private company in the acquiring country can use the credits toward offsetting its emissions.[xi] These markets can support sustainable development while ensuring environmental integrity[xii] via robust accounting.[xiii]

International cooperation is pivotal for a functioning carbon market by making it more efficient to decarbonize, as it allows countries to buy credits from those with lower marginal abatement costs.[xiv] Accordingly, the value of cooperative approaches is emphasized in Article 6.2, and a globally accepted centralized crediting mechanism is pivotal in Article 6.4.[xv]

Article 6.2: Corresponding Adjustments Are Key

Making a “corresponding adjustment” to emissions inventories of the seller and buyer when an ITMO is transferred is the cornerstone of Article 6.2’s environmental integrity provisions, preventing double counting. For example, if one country generates a carbon removal credit and sells it to another country, one ton of carbon is added back to the seller country’s emissions count and one ton is subtracted from the buyer country’s balance.[xvi]

Corresponding adjustments incentivize host countries to keep low-cost mitigation for themselves and offer higher-cost mitigation to buyers. Zambia, for example, aims to only sell credits from expensive mitigation activities such as industrial energy-efficiency retrofits (e.g., replacement of distribution transformers), enabling the country to meet its NDC at a lower cost.[xvii]

Article 6.4: Successor to CDM

Article 6.4 is overseen by a Supervisory Body (SBM) comprising 12 members, selected from the Parties to the Paris Agreement.[xviii] This mechanism, also known as the Paris Agreement Crediting Mechanism, was designed to verify and regulate carbon credits and facilitate their trading under stricter environmental integrity standards than its predecessor, the Kyoto Protocol’s CDM. It covers activities to support:[xix]

  • Mitigation: Article 6.4 is described as a mechanism that contributes to the reduction or removal of greenhouse gas emissions.[xx]
  • Adaptation: A share of proceeds (SOP) from Article 6.4 transactions is directed to an adaptation fund to support developing countries’ efforts to build resiliency to climate change.[xxi]
  • Sustainable development: The SBM outlines social and environmental safeguards and requires impact reports.[xxii]

Issuance of credits under Article 6.4 can only occur after submission of detailed documentation by project developers that is accredited by third-party verifiers. Projects must receive host country approval and meet the methodological requirements established by the SBM to ensure that the emission reductions are real, measurable, long-term, and greater than business-as-usual scenarios.

Article 6.4 provides for a broad range of project types, including:

  • Nature-based solutions, which include afforestation, reforestation, wetland restoration, and soil carbon enhancement projects. Reduced Emissions from Deforestation and forest Degradation (REDD+) activities―such as preventing the conversion of forest land to other uses, protecting existing forest areas and their stored carbon, initiating community-based conservation efforts, or practicing sustainable forest management[xxiii]―may also become eligible if relevant methodologies are adopted, but these are still under discussion.[xxiv]
  • Renewable energy projects, which dominate the current pipeline of Article 6.4 credits, led by solar, wind, energy efficiency, electric transportation, and waste management.[xxv]
  • Regenerative agriculture practices, such as soil organic carbon enhancement and sustainable agricultural land management, which are recognized as eligible activities but must await methodology approval by the SBM.

Challenges in Operationalizing Article 6 Mechanisms

High-quality carbon credits are created from projects that generate real, additional, quantifiable, verifiable, unique, and permanent reductions in greenhouse gas (GHG) emissions. Ensuring additionality and permanence while preventing double counting is thus essential for the environmental integrity of a carbon credit.

GHG reductions are considered additional if they would not have occurred in the absence of a market for carbon credits.[xxvi] A project’s carbon reduction is determined to be “additional” if it is greater than a baseline level, which is assumed based on a business-as-usual scenario. While the concept of additionality seems simple enough, properly defining and determining additionality can be a complex endeavor because proving additionality means constructing a credible counter-factual baseline predicting what would have happened in the absence of the carbon-credit revenue, while factoring in shifting laws, market trends, and technology costs. This data-intensive judgment is inherently uncertain and susceptible to information asymmetry and baseline manipulation.[xxvii]

The permanence of a carbon offset project ensures that the carbon sequestered will have a long-lasting impact on reducing GHG emissions to compensate for the fact that the effects of carbon dioxide emissions are very long-lived. Ensuring the permanence of carbon reduction or removal is inherently complicated due to the unpredictability of outcomes and risks of reversal―i.e., the carbon that has been sequestered gets released back into the atmosphere either from natural causes or human activities―over a long timeframe.

Not surprisingly, therefore, implementing and operationalizing Articles 6.2 and 6.4 face significant technical and political hurdles. Despite the framework for Article 6.2 being in place since 2021, real-world implementation has lagged significantly. As of April 2025, over 90 Article 6.2 bilateral agreements have been signed, but only one ITMO transfer has been fully completed, between Switzerland and Thailand in January 2024.[xxviii] Similarly, the first issuance of an Article 6.4 credit was expected by mid-2025,[xxix] but the timeline has now been pushed to early 2026.[xxx]

Delays are due to complexities around the following:

Additionality, Baseline-Setting, and Permanence

At COP29 last year, negotiators made modest progress on methodological standards, with investment analysis formally adopted as the primary tool for assessing additionality under Article 6.4. To support its implementation, the SBM has developed different types of investment analyses and approaches to conducting them.[xxxi] The type chosen would need to be suitable for the context of the Article 6.4 activity, whose additionality is being assessed. However, agreeing on baseline methodologies has been problematic.[xxxii] While some standards have been adopted by the SBM in preparation for the next COP, including a minimum downward adjustment to the baseline such that it remains below conservative business-as-usual scenarios, they still need to be tested in practice.[xxxiii]

For carbon removal activities, COP29 finalized standards requiring remediation of reversals that are avoidable (i.e., those within the control of the project developer, such as deforestation or poor forest management) and unavoidable (i.e., those outside the control of the project developer, such as wildfires, insect infestation, floods, etc.). The standards require establishing a buffer pool for the latter and mandating insurance coverage for the former, which provides either financial indemnification or replacement credits to mitigate against the risk of a project under-delivering credits.[xxxiv] Despite these advances, concerns remain that these standards may still be insufficient to guarantee environmental integrity due to the lack of repercussions and the same standards not being applied to CDMs.[xxxv]

Environmental Integrity and Double Counting

The COP29 agreement on Article 6.2 included a provision requesting parties not to use ITMOs (carbon units that can be transferred to other countries) that are determined—either by an automated consistency check conducted by the United Nations Framework Convention on Climate Change (UNFCCC) secretariat or by the technical expert review team for Article 6.2—to be “inconsistent” with achieving NDCs.[xxxvi] Notably, though, this is a request rather than a requirement. 

COP29 also clarified that to be eligible under Article 6, REDD+ projects need to be aligned with national strategies[xxxvii] to ensure environmental integrity by preventing leakage[xxxviii] (reducing emissions in one area only to increase them elsewhere) and applying a standardized baseline at a higher sectoral or national level of aggregation.[xxxix] However, an extension allowing CDM projects to transition to Article 6.4 credits raises concerns about the market getting flooded with low-quality credits[xl] that predominantly stem from avoidance activities (such as improved cookstoves) that have a high risk of non-additionality and for which there has been systematic over-crediting.[xli]

Whether credits from voluntary carbon markets (VCMs) should be accepted under Article 6 remains another divisive issue, with some stakeholders seeking flexibility to encourage private sector participation, while others are pushing back because of doubts regarding the quality and environmental integrity of existing VCM credits.[xlii] VCMs are decentralized platforms in which private companies, organizations, and individuals buy and sell carbon credits to offset emissions beyond regulatory requirements. Such credits lack regulatory oversight, such as the standards mandated by Article 6, but typically follow voluntary standards produced by independent bodies. Private sector participants drive demand by purchasing these credits voluntarily to meet corporate net-zero commitments and finance mitigation projects.

Another important development at COP 29 was the approval of a dual-layer registry system, which consists of interconnected national registries maintained by each participating country and a centralized international registry operated by the UNFCCC secretariat.[xliii] It aims to enhance transparency through automated consistency checks of ITMOs to prevent double counting. However, critics note that the system cannot verify the environmental integrity of the underlying projects. Also, such an interoperable framework is still under development and not in operation yet.

Removals versus Avoidance Credits

The distinction between carbon removal and carbon avoidance credits has emerged as a critical issue. Avoidance projects are those that avoid future emissions, such as renewable energy, forest conservation and avoided deforestation (REDD+), changes to the diets of dairy cows, cookstoves, fuel efficiency, and energy-efficient buildings, among others.[xliv] Removal projects, meanwhile, remove GHG emissions from the atmosphere and sequester them, such as through reforestation, afforestation, and technology-based direct air capture (DAC) or carbon capture, utilization, and storage (CCUS). Since greater investments are typically needed for removal projects and they are likely to be more impactful in reducing atmospheric carbon than avoidance projects, the credits generated by them usually trade at a premium to avoidance credits.[xlv] However, no clear or universal definition of these types of credits has been formally accepted, leading to some ambiguity―for example, it is unclear how carbon removal at the source should be classified.  

Some progress was made at COP29 in this area, as new methodologies for removals were approved, but disagreements persist about their relative value and fungibility vis-à-vis avoidance credits. A key unresolved question is whether carbon markets should differentiate pricing between these credit types, reflecting their different risk profiles and permanence characteristics. For now, the issue of including avoidance credits under Article 6 has been pushed out to 2028.[xlvi]

There is also growing debate on the role of technology-based carbon removal versus nature-based solutions. Negotiating parties at COP29 recognized both approaches for generating credits, but left unresolved questions about their relative permanence, risk profiles, and pricing.[xlvii] As engineered solutions such as DAC become more prominent, comparing their durability with nature-based approaches is gaining importance.[xlviii] Forest conservation projects are particularly contested, with new methodologies for REDD+ regarding baseline setting, leakage, and permanence receiving continued scrutiny.[xlix] To address these concerns, the SBM now mandates that REDD+ activities submit documentation proving inclusion in the host country’s national REDD+ strategy, forest monitoring system, and forest reference emission level.[l] The SBM is also considering jurisdictional approaches to REDD+ activities, not just project-based methodologies, which, as mentioned earlier, would mean baseline aggregation at a national or regional level and lower risk of leakage.[li]

Accountability, Transparency, and Governance Gaps

The technical expert review team for Article 6.2 has a limited mandate, primarily checking whether countries have provided required information, rather than assessing the quality of the credit to ensure it meets the standards. The penalties for inconsistencies in reporting are weak,[lii] with little ability to enforce compliance. 

The recently launched Centralized Accounting and Reporting Platform (CARP),[liii] along with the release of procedures for direct communication between the SBM and relevant stakeholders,[liv] represents progress but leaves open questions about public access to transaction details. The standardized Agreement Electronic Format (AEF), which is a component of CARP, was established for registry reporting, including authorization of credits, transfers, and cancellations.[lv] Despite the progress made, parties still lack standardized monitoring, reporting, and verification (MRV) guidelines or the ability to integrate ITMO data with national registries and GHG inventories. Few officials have been trained to run the AEF workflow or troubleshoot automated consistency checks in CARP.

Besides these issues, there are governance gaps that are essential to close for Article 6.2 and 6.4 mechanisms to become operational.[lvi] For Article 6.4, the SBM is due to provide its first annual report to the Conference of the Parties[lvii] at COP30,[lviii] but its enforcement authority remains limited and would need to be strengthened to create market confidence. Meanwhile, Article 6.2’s flexibility creates potential integrity risks, in contrast with Article 6.4, whose centralized structure offers stronger oversight.

Adaptation Funding and Technical Support

A persistent question exists regarding financing sources for the adaptation fund, which is meant to provide support to climate adaptation projects―such as drought-resistant agriculture, coastal protection, resilient water infrastructure, and early warning systems―in the most vulnerable developing countries.[lix] While Article 6.4 includes mandatory “in-kind” and monetary levies for the adaptation fund, Article 6.2 implementation still relies on voluntary share of proceeds (SOP) contributions, which is a contentious issue, as climate-vulnerable nations continue to push for mandatory contributions.[lx] Moreover, at COP29, exemptions were granted to Least Developed Countries (LDCs) and Small Island Developing States (SIDS) from SOP payments to encourage market participation,[lxi] as these countries face far greater challenges than other nations in implementing Article 6 due to their limited fiscal and technical capacities.

The UNFCCC has delivered many capacity-building workshops and events for LDCs and SIDS,[lxii] with the support of its implementation partners and six Regional Collaboration Centres (RCCs).[lxiii] However, practical hands-on training modules remain insufficient.[lxiv] As an example, the dual-layer registry system was created as a compromise to serve both as a repository of information for tracking credits and as a national registry―to facilitate issuing and trading of credits―for countries that lack resources to develop their own.[lxv] However, to operationalize this registry, training and ongoing support need to be provided to administrators for registry interoperability, including implementing standards and procedures to ensure data consistency in the transfer and reconciliation of credits between registries.[lxvi] There is also a need for in-depth training on operating the AEF and CARP systems; applying investment-analysis additionality tests; and creating MRV templates that incorporate co-benefits of projects, such as biodiversity, community impact frameworks, and indigenous rights.

Discussion Points for Addressing Article 6 Challenges

Given the implementation gaps in Article 6 mechanisms identified in this commentary, a few critical enhancements can be considered to improve environmental integrity, transparency, and governance to create an international carbon market that is effective because it instills confidence in its participants. The following subsections list specific actions to address core issues around Article 6 that could be ripe for discussion and decision-making at COP30.

Environmental Integrity and Additionality

  • Independent verification: The SBM could mandate third-party, UN-accredited verification of environmental integrity for all Article 6.4 credits before issuance.
  • Enforcement and monitoring of baseline adjustment: The SBM could establish a transparent monitoring system to ensure that all Article 6.4 projects implement baseline adjustments (incorporating the business-as-usual level) to establish when a project provides “additional” GHG emissions reductions.[lxvii] Independent, third-party audits could be conducted to verify compliance, and corrective action taken as necessary. Similar baseline adjustments could apply to ITMOs under Article 6.2.
  • Dynamic additionality tests: Investment analysis to determine additionality could be supplemented with sectoral or jurisdictional benchmarks that are updated frequently to reflect technological advancements to make the test more robust and lower the risk of leakage.
  • Buffer pools and insurance products for removals: All removal credits could be required to contribute to a buffer pool and carry insurance against reversals, with the ratios of buffer pool contributions to total credits reviewed and adjusted annually to account for the evolving reversal risk profile to ensure the pool remains adequately capitalized to cover the potential losses in any given year.[lxviii]
  • Credible CDM transition: The body overseeing implementation of the Paris Agreement, known as the CMA, could direct the SBM to require that all CDM projects undergo new baseline and additionality assessments before transitioning to Article 6.4 credits.

Transparency and Registry

  • Real-time public disclosure: All ITMO and Article 6.4 credit transactions, authorizations, transfers, and status updates (e.g., revocations) could be published in real time on CARP. This could include an audit trail with all necessary information for each unit from issuance to retirement.
  • Registry interoperability: The SBM could conduct annual interoperability checks for Article 6.4 transactions (i.e., that national registries maintain data synchronization and transaction capabilities with the UN registry) to ensure data integrity, and publish the results to help accelerate the creation of a harmonized, interoperable framework. For Article 6.2 ITMO transfers, the UNFCCC secretariat could develop comprehensive interoperability standards, with annual compliance testing and public reporting of registry connectivity performance metrics such as transaction success rates, cross-registry data consistency scores, and data transmission response times.[lxix]

Governance and Accountability

  • Penalties for non-compliance: The CMA could provide explicit enforcement authority to the Article 6.2 technical expert review team and Article 6.4 SBM to reject low-quality credits, address non-compliance, recommend corrective actions, impose penalties, and elevate extreme cases to the Paris Agreement Implementation and Compliance Committee (PAICC). PAICC could also be empowered to suspend countries or projects from Article 6 participation for repeated or egregious violations.
  • Public reporting: The CMA could require the SBM and PAICC to publish annual reports detailing enforcement actions, registry anomalies, unresolved disputes, and recommendations for corrective action.
  • Dispute resolution mechanism: The CMA could create an independent dispute resolution panel with authority to resolve registry, authorization, and credit quality disputes, with enforceable outcomes and defined timelines.

Capacity Building and Technical Support

  • Funding for capacity building: The CMA could mandate a fixed portion of the SOP for technical, legal, and financial support to LDCs and SIDS. The funds could be used to expand training workshops and provide hands-on support for dual-layer registry operations, AEF and CARP workflows, investment-analysis additionality procedures, and comprehensive MRV template development incorporating biodiversity and indigenous rights safeguards.
  • Expand the mandate of regional hubs: With a focus on under-represented regions, the CMA could expand the mandate and funding of existing RCCs to serve as peer-to-peer South-South knowledge exchange centers and as technical support hubs providing hands-on training on Article 6 procedures, readiness assessments, and institutional framework development. RCCs could also promote the development and deployment of regional MRV toolkits and provide ongoing support in local languages, funded through a combination of SOP revenues and donor contributions.

Following the progress made at COP29, COP30 presents an opportunity to close the remaining gaps and fully operationalize Article 6. As the host, Brazil has an unprecedented platform to use its experience with reducing Amazon deforestation and building indigenous partnerships to shape the outcome.[lxx]

About the Authors

Dr. Gautam Jain is a Senior Research Scholar at the Center on Global Energy Policy (CGEP) of Columbia University’s School of International and Public Affairs (SIPA). He focuses on the role of financial markets and instruments—including thematic bonds, blended finance structures, and carbon markets—in the energy transition, with an emphasis on emerging economies.

Dr. Jain has an extensive background in the financial industry where he covered emerging markets as a portfolio manager and strategist. He has worked at asset management firms and an investment bank, including The Rohatyn Group, Barclays Capital, and Millennium Partners. He has helped manage emerging market local debt and hard-currency bond portfolios, encompassing currencies, interest rate instruments, and sovereign credits. He specialized in portfolio construction and asset allocation incorporating macroeconomic, policy, and political developments in emerging markets.

He holds a Ph.D. in Operations Research from Columbia University. He also has an M.S. in Industrial Engineering from Iowa State University and a B.Tech. in Mechanical Engineering from the Indian Institute of Technology, Bombay. He is a CFA charter holder, a Cornell EMI Fellow, an Adjunct Professor at Columbia University’s School of International and Public Affairs, and a consultant for the United Nations to support the workstream of the Global Investors for Sustainable Development (GISD) Alliance on “Tackling Local Currency Risk”.

He has co-authored publications in the Journal of Derivatives, the Journal of Banking and Finance, the Journal of Applied Probability, Probability in Engineering and Informational Science, and the International Journal of Production Economics. He has also contributed chapters for the 2020 and 2021 Cornell EMI Annual Reports.

Shubham Deshmukh is a Master’s candidate in Sustainability Management at Columbia University and is researching carbon-market regulatory architecture at the Center on Global Energy Policy at Columbia University SIPA. He is compiling a comparative stock-take across global jurisdictions of project-based carbon-credit regulations and analyzing Article 6 rule-making from COP 21–29 to evaluate registry interoperability, corresponding adjustments, and share-of-proceeds design.

Prior to joining Columbia University, Shubham worked with Indian start-ups, where he helped in structuring high-integrity nature-based carbon projects, guided smallholder farmers in adopting regenerative agriculture, and supported the deployment of IoT-enabled precision agriculture systems that raised horticulture yields and resource efficiency.

He holds degrees in Rural Management and Electrical Engineering.


Notes

[i] United Nations Framework Convention on Climate Change, “The Paris Agreement,” https://unfccc.int/process-and-meetings/the-paris-agreement.

[ii] Initiative for Climate Action Transparency (ICAT), “A Guide to Cooperative Approaches under Article 6 of the Paris Agreement,” June 2023, https://climateactiontransparency.org/wp-content/uploads/2023/06/ICAT-Guide-Article-6_D4-2.pdf.

[iii] Kathy Fallon and Zoe Jee, “Article 6 Can Make or Break Carbon Markets at COP29: Here’s All You Need to Know,” Clean Air Task Force, October 2024, https://www.catf.us/2024/10/article-6-make-break-carbon-markets-cop29-heres-all-you-need-know/.

[iv] UNFCCC, “Article 6.4 Supervisory Body,” accessed April 26, 2025, https://unfccc.int/process-and-meetings/bodies/constituted-bodies/article-64-supervisory-body.

[v] Danny Cullenward, “Why Did the Clean Development Mechanism Produce Low-Quality Carbon Offsets?” Kleinman Center for Energy Policy, September 11, 2024, https://kleinmanenergy.upenn.edu/commentary/blog/why-did-the-clean-development-mechanism-produce-low-quality-carbon-offsets/.

[vi] UNFCCC, “COP26 Outcomes: Market Mechanisms and Non-Market Approaches (Article 6),” https://unfccc.int/process-and-meetings/the-paris-agreement/the-glasgow-climate-pact/cop26-outcomes-market-mechanisms-and-non-market-approaches-article-6.

[vii] Charlotte Streck et al., “Double Claiming and Corresponding Adjustments: A Deep Dive into the Double Counting of Emission Reductions, Corresponding Adjustments, and their Implications for the Voluntary Carbon Market,” Climate Focus, November 30, 2023, https://climatefocus.com/wp-content/uploads/2023/11/Double-Claiming-and-Corresponding-Adjustments.pdf.

[viii] UNFCCC, “Outcome of COP 26 (Glasgow) on CDM – DNA Forum Meeting, Virtual,” December 16, 2021, https://cdm.unfccc.int/sunsetcms/storage/contents/stored-file-20211220155101899/CDM_Global%20DNA%20Forum_virtual_v2.pdf.

[ix] UNFCCC, “COP26 Outcomes: Market Mechanisms and Non-Market Approaches (Article 6),” https://unfccc.int/process-and-meetings/the-paris-agreement/the-glasgow-climate-pact/cop26-outcomes-market-mechanisms-and-non-market-approaches-article-6.

[x] Andrei Marcu, “Article 6 Rule Book: A Post COP26 Assessment,” European Roundtable on Climate Change and Sustainable Transition (ERCST), November 22, 2021, https://ercst.org/wp-content/uploads/2021/11/20211122-COP26-Art6-final.pdf.

[xi] Clyde & Co, “Article 6 Developments at COP29 and Their Implications for Carbon Markets,” December 19, 2024, https://www.clydeco.com/en/insights/2024/12/carbon-trading-and-article-6-at-cop29.

[xii] Environmental Defense Fund, “Article 6 of the Paris Agreement: Fact Sheet,” November 2023, https://www.edf.org/sites/default/files/2023-11/EDF%20Article%206%20fact%20sheet_0.pdf

[xiii] Lambert Schneider et al., “Robust Accounting of International Transfers under Article 6 of the Paris Agreement – Preliminary Findings: Discussion Paper,” German Emissions Trading Authority (DEHSt), October 2016, https://www.dehst.de/SharedDocs/downloads/EN/project-mechanisms/discussion-papers/Robust_accounting_2016.pdf?__blob=publicationFile&v=1.

[xiv] Gautam Jain, Kaushik Deb, and Ryan Levitt, “Lessons for Structuring India’s Carbon Market to Support a Cost-Efficient Energy Transition,” Center on Global Energy Policy, Columbia University, May 13, 2024, https://www.energypolicy.columbia.edu/publications/lessons-for-structuring-indias-carbon-market-to-support-a-cost-efficient-energy-transition/.

[xv] Andrei Marcu, “Carbon Market Provisions in the Paris Agreement (Article 6),” Centre for European Policy Studies (CEPS), January 26, 2016, https://www.ceps.eu/ceps-publications/carbon-market-provisions-paris-agreement-article-6/.

[xvi] Instead of using the ITMO toward the achievement of the acquiring country’s NDC, it could be used toward other international mitigation purposes, such as the Carbon Offsetting and Reduction Scheme for International Aviation, or  by private actors in voluntary carbon markets; see Clyde & Co, “Article 6 Developments at COP29 and Their Implications for Carbon Markets,” December 19, 2024, https://www.clydeco.com/en/insights/2024/12/carbon-trading-and-article-6-at-cop29.

[xvii] Beatriz Granziera, Kelley Hamrick, and John Verdieck, “Article 6 Explainer,” The Nature Conservancy, February 19, 2024, https://www.nature.org/content/dam/tnc/nature/en/documents/TNC_Article_6_Explainer.pdf; Kelley Hamrick Malvar, Kim Myers, and Beatriz Granziera, “Article 6 Implementation: Case Studies and Host-Country Strategies,” The Nature Conservancy, November 7, 2024, https://www.nature.org/content/dam/tnc/nature/en/documents/Article-6-Implementation.pdf.

[xviii] UNFCC, “Article 6.4 Supervisory Body,” https://unfccc.int/process-and-meetings/bodies/constituted-bodies/article-64-supervisory-body.

[xix] UNDO Carbon, “Opportunities from COP29’s Article 6 Agreement: A Step Forward for Carbon Market Standards,” April 2025, https://un-do.com/resources/blog/opportunities-from-cop29s-article-6-agreement-a-step-forward-for-carbon-market-standards/.

[xx] UNFCCC, “2023 Webinar Series: Overview of Article 6.4.: The Mechanism,” August 24, 2023, https://unfccc.int/sites/default/files/resource/Webinar%20II_2023-08-23_Overview%20of%20Article%206.4.pdf; UNFCCC, “Article 6.4 Mechanism Two-Year Business and Resource Allocation Plan 2024–2025,” September 14, 2023, https://unfccc.int/sites/default/files/resource/a64-sb007_a01.pdf.

[xxi] Adaptation Fund, “Arrangements for the Transition of the Adaptation Fund to the Paris Agreement,” March 2025, https://www.adaptation-fund.org/wp-content/uploads/2025/03/AFB.B.44.5-Arrangments-for-the-Adaptation-Fund-Transition-to-Paris-Agreement-2.pdf

[xxii] UNFCCC, “Tool: Article 6.4 Sustainable Development Tool,” Version 01.0, October 9, 2024, https://unfccc.int/sites/default/files/resource/A6.4-SBM014-A04.pdf.

[xxiii] Green Climate Fund, “REDD+”, https://www.greenclimate.fund/redd.

[xxiv] UNFCCC, “Information Note: Removal Activities Under the Article 6.4 Mechanism,” Version 04.0, May 17, 2023, https://unfccc.int/sites/default/files/resource/a64-sb005-aa-a09.pdf

[xxv] Charles Di Leva and Scott Vaughan, “Paris Article 6 and Converging Carbon and Nature Markets,” IISD/SDG Knowledge Hub, March 12, 2025, https://sdg.iisd.org/commentary/guest-articles/paris-article-6-and-converging-carbon-and-nature-markets/.

[xxvi] Pedro Martins Barata, “Carbon Credits and Additionality: Past, Present, and Future,” World Bank, May 2016, https://openknowledge.worldbank.org/server/api/core/bitstreams/d0ad30e4-af71-5bf0-ab79-d4eafc0629df/content.

[xxvii] Gold Standard, “Requirements for Additionality Demonstration,” Version 1.0, April 24, 2025, https://globalgoals.goldstandard.org/standards/447_V1.0_Requirements-for-additionality-demonstration.pdf.

[xxviii] Sylvera, “Article 6 of the Paris Agreement: What You Need to Know Heading into 2025,” December 23, 2024, https://7608351.fs1.hubspotusercontent-na1.net/hubfs/7608351/%5BSylvera%5D%20Article%206%20Ebook%202024%20-%20Updated%2023.12.pdf.

[xxix] UNFCCC, “Procedure: Article 6.4 Activity Cycle Procedure for Projects,” Version 02.0, February 14, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM015-A09.pdf.

[xxx] UNFCCC, “Meeting Report: Sixteenth Meeting of the Article 6.4 Mechanism Supervisory Body,” May 16, 2025,  https://unfccc.int/sites/default/files/resource/A6.4-SBM016.pdf.

[xxxi] UNFCCC, “Draft Standard Demonstration of Additionality in Mechanism Methodologies,” February 3, 2025, https://unfccc.int/sites/default/files/resource/A6.4-MEP004-A02_0.pdf.

[xxxii] Catalina Cecchi Hucke, “Why the COP29 Article 6 Decision Strengthens High-Integrity Carbon Markets,” C2ES, February 6, 2025, https://www.c2es.org/2025/02/why-the-cop29-article-6-decision-strengthens-high-integrity-carbon-markets/.

[xxxiii] UNFCCC, “Setting the Baseline in Mechanism Methodologies,” Version 01.0, May 16, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016-A12.pdf.

[xxxiv] Injy Johnstone, “Article 6 in Focus: Outcomes from COP29,” Smith School of Enterprise and the Environment, University of Oxford, December 19, 2024, https://www.smithschool.ox.ac.uk/news/article-6-focus-outcomes-cop29; Daniel Bannister, Oliver Colman, and Gabrielle Osborne, “The Role of Insurance in Protecting Carbon Markets from Wildfire Risks,” WTW, March 4, 2025,  https://www.wtwco.com/en-sg/insights/2025/03/the-role-of-insurance-in-protecting-carbon-markets-from-wildfire-risks.

[xxxv] Khaled Diab, “COP29: Complex Article 6 Rules Pave Way to Unruly Carbon Markets,” Carbon Market Watch, November 23, 2024, https://carbonmarketwatch.org/2024/11/23/cop29-complex-article-6-rules-pave-way-to-unruly-carbon-markets/.

[xxxvi] The Nature Conservancy, “Key Takeaways on Article 6 at COP29,” May 2025, https://www.nature.org/content/dam/tnc/nature/en/documents/COP29-Article-6-Key-Outcomes.pdf.

[xxxvii] UNFCCC, “Standard: Addressing Leakage in Mechanism Methodologies,” Version 01.0, May 16, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016-A13.pdf.

[xxxviii] UNFCCC, “Addressing Leakage in Mechanism Methodologies,” Version 01.0, February 3, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016-A13.pdf.

[xxxix] UNFCCC, “Application of the Requirements of Chapter V.B (Methodologies) for the Development and Assessment of Article 6.4 Mechanism Methodologies,” Version 01.1, February 26, 2025, https://unfccc.int/sites/default/files/resource/A6.4-STAN-METH-001.pdf.

[xl] The Supervisory Body has made attempts to reduce the risk of low-quality credits, including imposing strict transition requirements for CDM cookstove programs of activities, requiring re-evaluation of the fraction of non-renewable biomass (fNRB) using 2025 data (e.g., Ghana’s CDM Program 10430 must update fNRB from 0.9884, and Bangladesh’s CDM Program 10431 must update fNRB from 0.843), and calling for a reassessment of leakage discount factors (0.95) based on current conditions under Article 6.4 standards. Transition approvals are conditional on applying updated parameters at the time of issuance requests. See UNFCCC, “Meeting Report: Sixteenth Meeting of the Article 6.4 Mechanism Supervisory Body,” Version 01.1, May 16, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016.pdf.

[xli] Isa Mulder, “First Wave of Article 6 Carbon Credits Misfire Spectacularly,” Carbon Market Watch, April 10, 2025, https://carbonmarketwatch.org/2025/04/10/first-wave-of-article-6-carbon-credits-misfire-spectacularly/.

[xlii] World Bank, “State and Trends of Carbon Pricing 2023,” May 2023, https://ppp.worldbank.org/public-private-partnership/sites/default/files/2023-10/State%20and%20Trends%20of%20Carbon%20Pricing%202023.pdf; Clyde & Co, “Article 6 Developments at COP29 and Their Implications for Carbon Markets,” December 19, 2024, https://www.clydeco.com/en/insights/2024/12/carbon-trading-and-article-6-at-cop29; Integrity Council for the Voluntary Carbon Market (ICVCM), “How Article 6 of the Paris Agreement and the Core Carbon Principles Work Together,” November 7, 2024, https://icvcm.org/article-6-of-the-paris-agreement-and-the-integrity-councils-work/; Guy Turner, Tristan Loffler, and Maudie Cooper, “State of Integrity in the Global Carbon-Credit Market,” MSCI Carbon Markets, September 2024, https://www.msci.com/documents/10199/0c700856-3190-44c5-e77e-8fa5f16881bd.

[xliii] The Nature Conservancy, “Key Takeaways on Article 6 at COP29,” May 2025, https://www.nature.org/content/dam/tnc/nature/en/documents/COP29-Article-6-Key-Outcomes.pdf.

[xliv] Silvia Favasuli and Vandana Sebastian, “Voluntary Carbon markets: How They Work, How They’re Priced and Who’s Involved,” S&P Global, June 10, 2021, https://www.spglobal.com/commodity-insights/en/news-research/blog/energy-transition/061021-voluntary-carbon-markets-pricing-participants-trading-corsia-credits.

[xlv] Silvia Favasuli and Vandana Sebastian, “Voluntary Carbon Markets: How They Work, How They’re Priced and Who’s Involved,” S&P Global, June 10, 2021, https://www.spglobal.com/commodity-insights/en/news-research/blog/energy-transition/061021-voluntary-carbon-markets-pricing-participants-trading-corsia-credits; World Bank, “State and Trends of Carbon Pricing 2023,” May 2023, https://ppp.worldbank.org/public-private-partnership/sites/default/files/2023-10/State%20and%20Trends%20of%20Carbon%20Pricing%202023.pdf.

[xlvi] Abby Fennelly and Rose Hansen, “Article 6.4 & Natural Climate Solutions,” Woodwell Climate Research Center, November 15, 2024, https://www.woodwellclimate.org/article-6-4-natural-climate-solutions/.

[xlvii] Patricia da Matta, “COP29 Week 1 Wrap-Up: Nature Remains on the Bench,” Nature4Climate, May 2025, https://nature4climate.org/cop29-week-1-wrap-up/.

[xlviii] Josh Burke and Felix Schenuit, “Permanence of Carbon Dioxide Removal: A Review of the Evidence and Implications for Policy,” CO2RE, November 2023, https://co2re.org/wp-content/uploads/2023/11/CO2RE_Report_CDR_Permanence-FINAL-v7.pdf.

[xlix] Barbara K. Haya et al., “Quality Assessment of Verra’s Updated REDD+ Methodology (VM0048),” Berkeley Carbon Trading Project, July 2024, https://gspp.berkeley.edu/assets/uploads/page/Quality-Assessment-of-VM0048–July-2024–BCTP-Policy-Brief.pdf.

[l] UNFCCC, “Standard: Addressing Leakage in Mechanism Methodologies,” Version 01.0, May 16, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016-A13.pdf.

[li] Abby Fennelly and Rose Hansen, “Article 6.4 & Natural Climate Solutions,” Woodwell Climate Research Center, November 15, 2024, https://www.woodwellclimate.org/article-6-4-natural-climate-solutions/.

[lii] Joel Gould, Lily Ginsberg-Keig, and Isobel Sizer, “COP29: Catalysing Global Carbon Markets,” BeZero Carbon, November 26, 2024, https://bezerocarbon.com/insights/cop29-catalysing-global-carbon-markets.

[liii] UNFCCC, “Article 6.2 Reference Manual for the Accounting, Reporting and Review of Cooperative Approaches,” April 2025, https://unfccc.int/sites/default/files/resource/Article_6.2_Reference_Manual.pdf.

[liv] UNFCCC, “Procedure: Direct Communication with Stakeholders,” Version 02.0, May 16, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016-A02.pdf.

[lv] UNFCCC, “Article 6.2 of the Paris Agreement Agreed Electronic Format,” May 2022, https://unfccc.int/sites/default/files/resource/WorkshopArticle6_AEF_0.pdf.

[lvi] Alexandra Soezer and Daniel Tutu Benefoh, “Article 6 of the Paris Agreement: White Paper,” Gulf Organisation for Research & Development (GORD), August 2024, https://cace.gord.qa/wp-content/uploads/2024/08/CACE-White-Paper-A6.pdf.

[lvii] The Conference of the Parties, serving as the meeting of the Parties to the Paris Agreement (CMA), is the supreme decision-making body responsible for overseeing and promoting the effective implementation of the Paris Agreement. All Parties to the Paris Agreement participate in the CMA, which meets annually to review progress and adopt decisions necessary for the Agreement’s implementation. See UNFCCC, “Conference of the Parties Serving as the Meeting of the Parties to the Paris Agreement (CMA),” https://unfccc.int/process/bodies/supreme-bodies/conference-of-the-parties-serving-as-the-meeting-of-the-parties-to-the-paris-agreement-cma.

[lviii] Ministry of Foreign Affairs of Japan, “Process Under UNFCCC (COP, CMP, CMA, SB),” January 10, 2025, https://www.mofa.go.jp/ic/ch/page22e_000921.html.

[lix] Adaptation Fund, “Arrangements for the Transition of the Adaptation Fund to the Paris Agreement,” March 2025, https://www.adaptation-fund.org/wp-content/uploads/2025/03/AFB.B.44.5-Arrangments-for-the-Adaptation-Fund-Transition-to-Paris-Agreement-2.pdf.

[lx] Jonathan Crook, “FAQ: Fixing Article 6 carbon markets at COP29,” Carbon Market Watch, November 6, 2024, https://carbonmarketwatch.org/2024/11/06/faq-fixing-article-6-carbon-markets-at-cop29/.

[lxi] The Nature Conservancy, “Key Takeaways on Article 6 at COP29,” May 2025, https://www.nature.org/content/dam/tnc/nature/en/documents/COP29-Article-6-Key-Outcomes.pdf.

[lxii] Subsidiary Body for Implementation, “Capacity-building Work of Bodies Established under the Convention and Its Kyoto Protocol and Undertaken by Bodies Serving the Paris Agreement: Compilation and Synthesis Report by the Secretariat – Addendum (FCCC/SBI/2025/1/Add.1),” April 9, 2025, https://unfccc.int/sites/default/files/resource/sbi2025_01a01.pdf.

[lxiii] UNFCCC, “Regional Collaboration Centres,” https://unfccc.int/RCCs.

[lxiv] UNFCCC, “Article 6.2 Reporting, Review and Infrastructure,” June Climate Meetings (SB 62): Art. 6.2 Information Session, June 18, 2025, https://unfccc.int/sites/default/files/resource/SB62_Article6.2_InfoSession_TER.pdf.

[lxv] The Nature Conservancy, “Key Takeaways on Article 6 at COP29,” May 2025, https://www.nature.org/content/dam/tnc/nature/en/documents/COP29-Article-6-Key-Outcomes.pdf.

[lxvi] Axel Michaelowa, Hanna-Mari Ahonen, Juliana Keßler, and Aayushi Singh, “Interlinkages of Registries and Implications for Functions and Structures in the Context of Article 6,” German Federal Ministry for Economic Affairs and Climate Action, Perspectives Climate Research gGmbH, August 2023, https://perspectives.cc/wp-content/uploads/2024/01/Interlinkages-of-registries-and-implications-for-functions-and-structures-in-the-context-of-Article-6.pdf.

[lxvii] UNFCCC, “Setting the Baseline in Mechanism Methodologies,” Version 01.0, May 16, 2025, https://unfccc.int/sites/default/files/resource/A6.4-SBM016-A12.pdf.

[lxviii] UNFCCC, “Recommendation: Activities Involving Removals Under the Article 6.4 Mechanism,” November 17, 2023, https://unfccc.int/sites/default/files/resource/a64-sb009-a02.pdf.

[lxix] UNFCCC, “Standards and Recommended Practices: Interim Progress Report,” Forum of Article 6 Registry Administrators, 2024, https://unfccc.int/sites/default/files/resource/RSAForumInterimProgressReport.pdf.

[lxx] Brazilian Government, “COP30: Brazil works to consolidate diplomatic leadership in climate agenda,” December 16, 2024, https://www.gov.br/secom/en/latest-news/2024/12/cop30-brazil-works-to-consolidate-diplomatic-leadership-in-climate-agenda.

Our Work

Relevant
Publications

A Roadmap to Catalyze Methane Abatement in the Oil and Gas Sector Using Debt Financing

Human-caused methane emissions have contributed to at least one quarter of global warming since the preindustrial era. Since methane is 80 times more potent than carbon dioxide (CO2) in trapping heat over the first two decades after its release, abating methane is considered a critical near-term strategy for reducing emissions.[

Reports by Luisa Palacios, Gautam Jain & Preetha Jenarthan • June 30, 2025
A Roadmap to Catalyze Methane Abatement in the Oil and Gas Sector Using Debt Financing
See All Work
Finance & Economics

How to Fully Operationalize Article 6 of the Paris Agreement

Commentary by Gautam Jain & Shubham Deshmukh • September 11, 2025