A tick the box exercise?

The report analyzes the first round of Article 6.2 reviews, finding that every reviewed Initial Report contained inconsistencies with reporting requirements. It argues that the Technical Expert Review Team (TERT) lacks the mandate to judge credit quality or enforce compliance, rendering the process a 'box-ticking exercise'. Case studies on Switzerland, Ghana, Guyana, and Vanuatu illustrate how high-risk or non-compliant credits can be traded despite transparency gaps. The author recommends extending the TERT mandate to include quality assessments and prohibiting the trade of credits until reviews are finalized.

• The first round of Article 6.2 reviews revealed that every single Initial Report reviewed so far has failed to meet at least some reporting requirements, indicating widespread non-compliance with existing transparency rules.
• The Technical Expert Review Team (TERT) is restricted to checking if information is consistent with guidance and is explicitly prohibited from assessing the actual quality of carbon credits, the credibility of reported information, or the rigour of human rights safeguards.
• Current reporting rules allow countries to delay the publication of information about carbon credit trades until the next biennial transparency report, potentially creating a gap of up to two years between the authorization of Internationally Transferred Mitigation Outcomes (ITMOs) and public disclosure on the Centralised Accounting and Reporting Platform (CARP).
• In the case of Guyana, the review process identified that the High Forest, Low Deforestation (HFLD) approach under the TREES standard allows for baseline increases, which contradicts the Article 6 requirement that baselines be set below 'business as usual' projections.
• Vanuatu openly disclosed the use of a Clean Development Mechanism methodology that does not require baselines to be set below business-as-usual projections, yet the review process lacked the authority to enforce a resolution beyond recommending a shift to suitable baselines.
• Independent risk assessments by BeZero Carbon for Swiss projects in Ghana (climate smart agriculture) and Thailand (electric buses) identified 'very high carbon accounting risk' and 'moderately high risk to the additionality', respectively, while the official Article 6.2 review only flagged that the reporting was not 'sufficiently transparent or complete'.
• The review process is undermined by a lack of enforcement, as there is no obligation to prohibit the use of ITMOs even after inconsistencies have been identified.

APA

Dossi, F., & Crook, J. (2026). A tick the box exercise? Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2026/04/What-the-first-Article-6.2-review-tells-us-about-transparency-and-accountability-3-combined-FINAL-27.04.pdf

Chicago

Dossi, Federica, and Jonathan Crook. A tick the box exercise? Carbon Market Watch, 2026. https://carbonmarketwatch.org/wp-content/uploads/2026/04/What-the-first-Article-6.2-review-tells-us-about-transparency-and-accountability-3-combined-FINAL-27.04.pdf.

Wikipedia

{{cite report |last1=Dossi |first1=Federica |last2=Crook |first2=Jonathan |title=A tick the box exercise? |publisher=Carbon Market Watch |date=April 2026 |url=https://carbonmarketwatch.org/wp-content/uploads/2026/04/What-the-first-Article-6.2-review-tells-us-about-transparency-and-accountability-3-combined-FINAL-27.04.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{dossi2026tick, author = {Dossi, Federica and Crook, Jonathan}, title = {{A tick the box exercise?}}, institution = {Carbon Market Watch}, year = {2026}, month = apr, url = {https://carbonmarketwatch.org/wp-content/uploads/2026/04/What-the-first-Article-6.2-review-tells-us-about-transparency-and-accountability-3-combined-FINAL-27.04.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }