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The document identifies critical transparency gaps in current carbon market infrastructure, specifically within the Clean Development Mechanism, Verra, and Gold Standard registries. It argues that existing systems fail to adequately track credit ownership, verify retirement claims, or distinguish between units contributing to a host country's NDC and those adjusted for international transfer. To remedy this, Carbon Market Watch recommends implementing machine-readable datasets, mandatory non-technical project summaries, detailed financial reporting on revenue distribution, and a transaction log to track legal ownership of credits.

Carbon Market Watch urges the European Commission to adopt the most ambitious options for the EU ETS aviation coverage, specifically advocating for full coverage of emissions and 100% auctioning of allowances from the regulation's adoption. The organization criticizes CORSIA as an ineffective climate strategy and warns that replacing EU ETS coverage with CORSIA would reduce climate ambition and revenue. Additionally, the document calls for the regulation of non-CO2 effects, which are estimated to multiply the global warming impact of aviation CO2 by 2-4 times.

Carbon Market Watch urges the Kenyan government to completely rewrite the climate change amendment bill 2023, citing pervasive ambiguity and vague terminology. The organization argues that the current wording could lead to misinterpretation, potentially harming human rights and the environment. Specific concerns include the lack of clear definitions for actors in the voluntary carbon market, the failure to distinguish between 'aiming' for reductions and actually delivering them, and insufficient requirements for the permanence of carbon removals. The response also highlights a need for greater transparency, specifically calling for the public availability of the Registry and community development agreements.

The report argues that while the EU ETS has halved emissions in key sectors, it remains structurally oversupplied and hampered by free allocation subsidies. It advocates for the total elimination of free allowances, the expansion of the system to cover all international aviation and shipping, and the rejection of carbon offsets and removals. The document emphasizes that the Market Stability Reserve (MSR) must be preserved to maintain a strong carbon price signal and that revenues should be redirected from fossil fuel subsidies toward a 'people first' transition.

Carbon Market Watch advises the CMA against adopting the Supervisory Body's text on removals under the Article 6.4 mechanism without further guidance to ensure environmental integrity. The organization calls for stricter definitions of removal durability, the creation of a science-based risk assessment tool, mandatory post-crediting monitoring, and clear rules on avoidable reversals and buffer pool replenishment. Regarding methodology development, it suggests requiring proponents to prove carbon credit revenues were a significant income source and conducting additionality analyses for different activity types.

Carbon Market Watch and Opportunity Green call on the European Commission to maintain its climate leadership by resisting U.S. pressure to exempt international aviation from the EU ETS. The authors argue that the ICAO's CORSIA scheme is an inferior alternative to the ETS because it lacks an emissions cap and relies on inadequate offsetting. They highlight that in 2023, flights leaving EEA airports emitted 133 MtCO2, with less than half reported under the ETS, and warn that yielding to U.S. threats, such as the EU ETS Prohibition Act, would undermine EU sovereignty and climate goals.

The report by Carbon Market Watch outlines a framework for 'carbon pricing done right,' arguing that such systems must be integrated into broader policy packages and based on strict emission caps to be effective. It emphasizes the 'polluter pays principle,' warning against free allocations and offsets, which it claims can weaken price signals and lead to greenwashing. The document advocates for transparency, the reinvestment of revenues into climate action and vulnerable communities, and a cautious approach to carbon leakage and border adjustment mechanisms to avoid protectionism while ensuring climate justice.

The document asserts that fossil and biological carbon operate on fundamentally different timescales and cycles, making them non-fungible. While fossil carbon is permanent, biological carbon is subject to rapid fluxes and risks of reversibility from fires, pests, or rising temperatures. The author contends that relying on biological offsets to mitigate fossil emissions is scientifically unsound and practically limited by land area and nutrient requirements, concluding that emissions from both sources must be addressed in parallel rather than through offsetting.

Carbon Market Watch argues that the FTC's 'Green Guides' are outdated and fail to align with the Paris Agreement's 1.5C goal. The submission recommends a total ban on claims such as 'carbon neutral' and 'net zero' because they falsely imply that emissions can be 'neutralised' through carbon credits, which the author describes as scientifically unsound. Instead, the document proposes a 'contribution' model where companies fund mitigation projects without claiming to offset their own emissions. It also suggests that the Guides be made enforceable under the FTC Act to provide oversight of the voluntary carbon market and protect consumers from greenwashing.

Carbon Market Watch argues that Gold Standard's proposed methodology for crediting the early retirement of coal plants lacks the necessary rigor to ensure additionality and environmental integrity. The organization expresses skepticism that carbon credit finance is a suitable tool for this purpose given the volatility of energy markets and the difficulty of accurately measuring the future viability of coal plants. Specific concerns include the risk of double claiming, vague definitions of 'baseline plants' that might include economically unviable facilities, and the failure to account for the lifecycle emissions of new renewable energy plants.

Carbon Market Watch criticizes the proposed Green Claims Directive (GCD) for allowing the continued use of carbon neutrality and offsetting claims, which the organization asserts are inherently misleading due to quantification uncertainties, low carbon credit quality, and consumer misunderstanding. The response argues that the GCD's substantiation rules are too weak to prevent greenwashing and that the directive lacks clear definitions for 'significant' environmental impacts and specific requirements for future performance claims.

The document argues that the aviation sector has benefited from excessive exemptions under the EU ETS and that the international CORSIA scheme is an ineffective substitute. It recommends bringing international flights back under the EU ETS, phasing out free allowances to airlines, and addressing non-CO2 climate impacts to align the sector with the Paris Agreement and the polluter pays principle.

The International Coalition for Sustainable Aviation (ICSA) evaluates the 'CORSIA Package,' which includes Standards and Recommended Practices (SARPs) for the global aviation carbon offsetting scheme. While acknowledging the technical soundness of much of the package, ICSA argues that current provisions for reporting transparency, emissions unit eligibility, and sustainable aviation fuel (SAF) sustainability criteria are insufficient. The document recommends that ICAO expand sustainability criteria to include social and economic attributes, improve third-party access to emissions reports, and refine life cycle assessment (LCA) values for waste-based feedstocks to prevent environmental harm and double counting.

Carbon Market Watch has filed a complaint with the ICVCM, asserting that Verra violated the Core Carbon Principles (CCP) Assessment Framework by failing to ensure impartiality during its review of human rights allegations made by Human Rights Watch. The complaint highlights that Verra relied on the project implementer and the same validation/verification bodies that had previously approved the project, creating inherent conflicts of interest. Carbon Market Watch calls on the ICVCM to evaluate the real-world effectiveness of Verra's grievance mechanism and to implement a broader process for assessing program compliance beyond written commitments.

The report by Carbon Market Watch provides a framework for implementing 'right' carbon pricing, arguing that such systems must be integrated into a broader policy mix, feature declining emission caps, and avoid loopholes like free allocations and carbon offsets. It emphasizes the need for transparency, the reinvestment of revenues into climate action and vulnerable communities, and the use of carbon border adjustments to prevent leakage while maintaining equity.

The document critiques agricultural carbon offsets, stating they risk harming farmers' autonomy, fail to provide permanent carbon sequestration, and may actually increase overall emissions. It recommends that governments and international bodies exclude land-based offsets from carbon markets and instead fund agroecological transitions.

A coalition of NGOs expresses concerns regarding the European Commission's Expert Group on Carbon Removal, specifically citing a lack of gender and sectoral balance in meeting agendas, the underrepresentation of scientific and environmental voices in the group's composition, and a lack of transparency in documentation and agenda-setting. The signatories argue that the group must address fundamental policy questions regarding the EU carbon budget and the prevention of offsetting emissions with removals, rather than focusing solely on technical methodologies.

The letter expresses concern that 555 million carbon offset credits were surrendered into the EU ETS between 2008 and 2011, costing an estimated €5.9bn. The signatories argue that these offsets stifle domestic action, support business-as-usual coal and large hydro projects in the CDM, and allow for 'hot-air laundering' through Track 1 Joint Implementation, thereby threatening the environmental integrity of EU climate policies.

The submission argues that environmental attribute certificates, specifically REDD+ carbon credits and energy certificates like RECs and GOs, are unsuitable for corporate decarbonisation targets. It highlights systemic issues in the voluntary carbon market, including over-crediting and flawed methodologies in REDD+ projects, and asserts that energy certificates are financial instruments that do not represent physical electricity delivery. The document advocates for a strict separation of these certificates from gross emission reduction targets, citing the EU Corporate Sustainability Reporting Directive (CSRD) as a regulatory precedent.

The policy brief outlines seven areas where the EU should enhance its climate policies following the Paris agreement. Key recommendations include increasing the 2020 emission reduction target to 30%, revising the 2050 low-carbon roadmap to meet the 1.5°C objective, and adopting 5-year ambition cycles. It also calls for the phase-out of free pollution permits for industry, the inclusion of aviation and maritime sectors in the EU ETS, and the use of the Sustainable Development Mechanism to finance emission reductions in developing countries without relying on offsetting.