Assessing the robustness of Carbon Market Grievance Mechanisms and recommendations for the establishment of an Article 6.4 Grievance Mechanism

The report evaluates grievance mechanisms across various carbon market standards and funds, using UN Guiding Principles on Business and Human Rights as a benchmark. It finds that most voluntary carbon market (VCM) standards have opaque or insufficient mechanisms, while the Green Climate Fund (GCF) and Gold Standard provide more robust models. The authors recommend that the Article 6.4 mechanism prioritize accessibility, transparency through public repositories, independence, and the ability to provide binding remedies, including the power to overturn Supervisory Body decisions.

• The UN Guiding Principles on Business and Human Rights establish seven universal criteria for effective grievance mechanisms: legitimacy, accessibility, predictability, equitability, transparency, rights compatibility, and being a source of continuous learning.
• The Clean Development Mechanism (CDM) lacked a grievance mechanism for over 15 years, which the report suggests may have contributed to human rights abuses in projects such as the Barro Blanco dam in Panama and the Bujagali hydropower plant in Uganda.
• Most voluntary carbon market (VCM) standards, including Verra, American Carbon Registry (ACR), and Climate Action Reserve (CAR), have grievance mechanisms that are opaque, lack detailed procedural descriptions, and do not provide public repositories of grievances.
• Verra employs a deterrent practice by charging complainants procedural costs, which are only refunded if the complaint is decided in the complainant's favor.
• Gold Standard is the only assessed VCM standard with a public grievance repository and detailed operational guidance, though it is still less comprehensive than the Green Climate Fund's mechanism.
• The Green Climate Fund's Independent Redress Mechanism (IRM) is identified as the best-performing model due to its proactive awareness campaigns, multi-language support, and detailed case register.
• The Dedicated Grant Mechanism for Indigenous Peoples and Local Communities (DGM) demonstrates the importance of culturally appropriate practices, such as using local languages and integrating customary decision-making processes in countries like Burkina Faso, DRC, and Peru.
• Recommendations for the Article 6.4 grievance mechanism include the creation of a public repository, the acceptance of diverse evidence (e.g., photographs, media reports), and the removal of all procedural costs for complainants.
• The Article 6.4 mechanism should have the authority to provide binding remedies, specifically the ability to overturn prior decisions of the Article 6.4 Supervisory Body or deregister activities.

APA

Dalfiume, S., & Michaelowa, A. (2023). Assessing the robustness of Carbon Market Grievance Mechanisms and recommendations for the establishment of an Article 6.4 Grievance Mechanism. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2023/03/Grievance-mechanism-report.pdf

Chicago

Dalfiume, Sandra, and Axel Michaelowa. Assessing the robustness of Carbon Market Grievance Mechanisms and recommendations for the establishment of an Article 6.4 Grievance Mechanism. Carbon Market Watch, 2023. https://carbonmarketwatch.org/wp-content/uploads/2023/03/Grievance-mechanism-report.pdf.

Wikipedia

{{cite report |last1=Dalfiume |first1=Sandra |last2=Michaelowa |first2=Axel |title=Assessing the robustness of Carbon Market Grievance Mechanisms and recommendations for the establishment of an Article 6.4 Grievance Mechanism |publisher=Carbon Market Watch |date=14 March 2023 |url=https://carbonmarketwatch.org/wp-content/uploads/2023/03/Grievance-mechanism-report.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{dalfiume2023assessing, author = {Dalfiume, Sandra and Michaelowa, Axel}, title = {{Assessing the robustness of Carbon Market Grievance Mechanisms and recommendations for the establishment of an Article 6.4 Grievance Mechanism}}, institution = {Carbon Market Watch}, year = {2023}, month = mar, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/03/Grievance-mechanism-report.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }