Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 11th meeting: appeal and grievance processes

Carbon Market Watch argues that the draft appeal and grievance processes for the Article 6.4 mechanism are insufficient and not ready for adoption. The organization recommends a structured consultation period of at least one month and suggests using the Green Climate Fund's Independent Redress Mechanism as a model for accessibility, legitimacy, and rights compatibility. Key criticisms include the imposition of appeal and grievance fees, restrictive eligibility criteria for appellants and grievants, limited language options (English only), and a lack of retaliation safeguards.

• The draft procedure for appeal and grievance processes is not ready for adoption at the 11th meeting of the Supervisory Body. Carbon Market Watch recommends a structured consultation of at least one month, specifically seeking input from Indigenous Peoples, local communities, and other rights-holders.
• The proposed appeal fees (standard fee of USD 2,500 to 5,000 and reduced fee of USD 2,500) and the requirement for a bond deposit create financial barriers that limit accessibility and equitability for stakeholders without sufficient means.
• The grievance process is overly restrictive because it requires grievants to meet all eligibility requirements and limits grievances to direct adverse effects occurring within the activity cycle, ignoring indirect or potential harms and long-term environmental impacts.
• The draft mechanism lacks sufficient accessibility and safety measures, specifically regarding the requirement to use an English-language online form, the lack of comprehensive confidentiality for all appeal information, and the absence of retaliation safeguards.
• The Supervisory Body's ability to disregard recommendations from the grievance panel undermines the legitimacy of the process; the body should instead be required to provide public justifications for its decisions.
• A comparison with the Green Climate Fund's Independent Redress Mechanism (IRM) shows that the Article 6.4 process performs significantly worse across seven effectiveness criteria: legitimacy, accessibility, predictability, equitability, transparency, rights compatibility, and being a source of continuous learning.

APA

Carbon Market Watch (2024). Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 11th meeting: appeal and grievance processes. https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-procedure.pdf

Chicago

Carbon Market Watch. Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 11th meeting: appeal and grievance processes. 2024. https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-procedure.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 11th meeting: appeal and grievance processes |date=22 April 2024 |url=https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-procedure.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2024carbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 11th meeting: appeal and grievance processes}}, publisher = {Carbon Market Watch}, year = {2024}, month = apr, url = {https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-procedure.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }