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The Lack of Control of Legal Deforestation in MATOPIBA: Regulation and Governance of Authorizations for the Suppression of Vegetation
The report identifies critical gaps in the governance of legal deforestation in the MATOPIBA region (Maranhão, Tocantins, Piauí, and Bahia), where agricultural expansion for soy and corn drives significant vegetation loss. It highlights a lack of clarity in legal competence between state and municipal authorities for issuing Authorizations for the Suppression of Vegetation (ASV) and the failure of the national SINAFLOR system to serve as an effective management tool. Key issues include underreporting of ASVs, a lack of public transparency regarding georeferenced data, and technical incompatibilities between state and federal systems. The authors recommend that the federal government clarify issuing competencies, improve SINAFLOR's functionality, and ensure open access to complete ASV data to support the goal of zero deforestation by 2030.
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Document type: Report
LOST IN DOCUMENTATION
The report evaluates transparency in the voluntary carbon market (VCM) by analyzing a sample of 140 projects across the Verified Carbon Standard (VCS), Gold Standard (GS), American Carbon Registry (ACR), and Climate Action Reserve (CAR). It finds that no single standard provides full disclosure, with significant gaps caused by both inadequate rule-setting and insufficient enforcement. Specifically, CAR and ACR have structural limitations regarding the public disclosure of monitoring reports. The study also identifies widespread issues with mislabelled, duplicated, or missing documents, which rating agencies confirm hinder the independent assessment of carbon credit quality. The report recommends implementing stronger quality assurance/quality control (QA/QC) processes, standardized naming conventions, and regular audits to align with Integrity Council for Voluntary Carbon Markets (ICVCM) requirements.
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Document type: Report
SB60 | BONN CLIMATE CHANGE CONFERENCE 2024
The document details the role of Action for Climate Empowerment (ACE) at the SB60 conference in Bonn, highlighting an expert dialogue on children and climate change, the identification of implementation challenges, and the goal of scaling up the involvement of civil society and marginalised groups to inform the annual summary report for COP29.
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Document type: Policy brief
Towards A Global AI Auditing Framework: Assessment and Recommendations
The report analyzes the current AI audit ecosystem, identifying critical gaps in auditor independence, data access, and the failure to account for global sociotechnical impacts. It uses New York City's Local Law 144 as a case study to illustrate how regulatory-driven audits often prioritize transparency over actual harm mitigation. To address these issues, the authors propose a comprehensive Global AI Auditing Framework that emphasizes multidisciplinary teams, participatory stakeholder engagement, and the inclusion of labor and environmental criteria to ensure accountability across the AI supply chain.
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Document type: Research paper
توصيات بشأن الإطار العالمي لعمليات التدقيق في الذكاء الاصطناعي
The International Panel on the Information Environment (IPIE) presents a global framework for AI auditing designed to mitigate systemic harms, including bias, inequality, and environmental damage. The framework outlines seven key features: audit scope, the auditor's role, stakeholder engagement, context-specific criteria, evidence requirements, auditing methodologies, and post-audit activities. It emphasizes the need for auditor independence, public transparency of results, and the inclusion of marginalized communities, particularly in the Global South, to address disproportionate impacts of AI technologies.
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Document type: Executive summary
Statement on the Public Procurement Bill 2023
The Procurement Reform Working Group (PRWG) criticizes the Public Procurement Bill 2023, asserting that it was rushed through Parliament with inadequate consultation and contains flaws that could amplify corruption and economic instability in South Africa. The group highlights the erosion of integrity provisions, the failure to implement Zondo Commission recommendations, and the introduction of a vague preferential procurement chapter that may lead to operational chaos and litigation.
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Document type: Statement
Assessing the transparency and integrity of benefit sharing arrangements related to voluntary carbon market projects
The report finds that comprehensive requirements for benefit sharing arrangements are not common practice across major carbon crediting programmes. While some projects, particularly those under Plan Vivo, demonstrate best practices by providing detailed monitoring reports on monetary and non-monetary benefits, many others provide only procedural information or limited evidence of actual implementation. Major carbon crediting programmes like Verra (VCS), CAR, and ACR have largely resisted mandatory disclosure of benefit sharing terms, citing commercial confidentiality and a lack of institutional expertise to monitor downstream financial flows.
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Document type: Report
Uma proporção justa do mercado voluntário de carbono? Como a ausência de regras padronizadas sobre os acordos de partilha de benefícios prejudica as comunidades locais e os povos indígenas
The document reports on a study by the Öko-Institut commissioned by Carbon Market Watch, which found that benefit-sharing arrangements (BSAs) in the voluntary carbon market are largely insufficient and lack transparency. Analysis of five carbon standards and 47 projects revealed that most standards do not require BSAs, and very few projects provide evidence of distributing benefits beyond simple performance-based payments. The brief argues that performance payments (like salaries) should not be conflated with benefit-sharing and calls for the Integrity Council for Voluntary Carbon Markets (ICVCM) to mandate standardized, transparent BSA rules.
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Document type: Policy brief
MANUAL IN TERMS OF SECTION 51 OF THE PROMOTION OF ACCESS TO INFORMATION ACT, 2000 (AS AMENDED)
This document is a PAIA Manual published in October 2023 by the Centre for Environmental Rights (CER), a non-profit law clinic based in Cape Town. The manual outlines the procedures and categories of information available to the public in accordance with the Promotion of Access to Information Act, 2000 (PAIA) and the Protection of Personal Information Act 4 of 2013 (POPIA), ensuring transparency and the exercise of environmental rights.
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Document type: Guide
Public Procurement Bill 2023 Submission of Public Comment
PARI argues that the Public Procurement Bill 2023 misinterprets Section 217 of the Constitution, particularly regarding preferential procurement, and risks legal instability by deferring too much substance to unpublished subordinate instruments. The submission proposes specific rewrites to Section 17 to ensure a mandatory national legislative framework for economic development and local content. It further recommends strengthening whistleblower protections, expanding automatic exclusions for political office-bearers, and clarifying access and disclosure clauses to prevent the Bill from becoming a 'secrecy clause'.
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Document type: Statement
Statement on the Public Procurement Bill 2023
The Procurement Reform Working Group (PRWG) supports the introduction of the Public Procurement Bill 2023 as a means to simplify South Africa's fragmented procurement legal framework, which currently consists of over 100 pieces of legislation. However, the PRWG argues that the Bill fails to provide clear definitions for 'preferential procurement' and 'public procurement' and grants excessive law-making power to the National Treasury and the Public Procurement Office. The group advocates for the Bill to contain concrete core rules and principles—including open contracting and proactive transparency—rather than relying on subordinate legislation, to ensure the system is fair, equitable, transparent, competitive, and cost-effective.
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Document type: Statement
Report on the activities of the Information Appeals Panel
The Information Appeals Panel (IAP) processed one appeal between February and May 2023 concerning a delayed response to an information request. The IAP determined that while the GCF Secretariat eventually provided the requested information, there was a significant delay in responding to a specific clarification request. The IAP concluded there were no grounds for further disclosure but shared recommendations with the Ethics and Audit Committee regarding the response timeline.
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Document type: Report
Access to justice in State aid matters in EU Member States
The study finds that in eight of the nine researched EU Member States, there are no instances of NGOs bringing actions against State aid measures. It highlights a systemic lack of standing for non-competitors, limited transparency regarding aid schemes, and inconsistent public consultation practices, which collectively hinder the enforcement of EU environmental law in State aid matters.
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Document type: Report
Realización de un análisis de situación orientado a la corrupción para el trabajo de conservación: La experiencia como guía
The document outlines the benefits, scoping, and implementation of corruption-oriented situation analyses within conservation projects. It emphasizes the importance of understanding local power dynamics, social norms, and legal vulnerabilities to design effective interventions. The guide provides a framework for stakeholder identification, data collection, and the formulation of recommendations, while highlighting critical considerations such as security, confidentiality, and gender perspectives. Three case studies from Latin America, Asia, and Europe illustrate the application of these analyses in fisheries, community forestry, and land-use planning, demonstrating how such studies can shift organizational mindsets toward a more systematic approach to anti-corruption work.
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Document type: Guide
Réalisation d’une analyse de situation axée sur la corruption pour le travail de conservation: conseils tirés de l’expérience
The document outlines a methodology for conservation practitioners to analyze how corruption impacts natural resource management. It details the benefits of such analyses—including improved understanding of power dynamics and local perceptions of corruption—and provides a step-by-step approach to defining scope, identifying stakeholders, and collecting sensitive data. The guide emphasizes a non-conflictual approach with governments and the importance of security and confidentiality. It includes three case studies: one in Latin America focusing on fishing permits, one in Asia on community forestry governance, and one in Europe on land-use planning, demonstrating how these analyses lead to systematic anti-corruption integration in conservation programming.
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Document type: Guide
Groups react with dismay to FMO's position statement on financial intermediaries pointing to outstanding human rights and climate concerns
A coalition of civil society groups, including Oxfam Novib, Both ENDS, SOMO, and Recourse, criticizes FMO's October 2022 Position Statement on Impact and ESG for Financial Intermediaries. The groups argue that FMO's indirect investment model—which constitutes approximately 40% of its total portfolio—carries higher risks than direct lending but lacks sufficient safeguards against human rights abuses and environmental harm. Specifically, they highlight a gap in FMO's fossil fuel phase-out commitments, which apply to direct investments but not to those made via financial intermediaries, such as the Africa Finance Corporation. The statement also notes that a lack of transparency prevents impacted communities from accessing remedies for adverse project impacts.
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Document type: Statement
LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT
The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted comments on the Draft 8th National Greenhouse Gas Inventory Report (NGHGIR) on 31 August 2022. The submission argues that the draft significantly undercounts methane emissions due to the omission of fugitive emissions from the oil and gas industry, pipeline transport, and abandoned mines, and criticizes the use of outdated global warming potential (GWP) metrics and low emission factors for coal mining.
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Document type: Statement
Carbon Market Watch note on selected Article 6.2 elements following SBSTA 56 call for submissions
Carbon Market Watch argues that 'averaging accounting' for single-year NDCs creates a risk of double counting that should be addressed through the ex-post cancellation of Internationally Transferred Mitigation Outcomes (ITMOs). The organization advocates for a 'public' default status for all Article 6 information and a transparent, machine-readable infrastructure for the Centralised Accounting and Reporting Platform (CARP). Additionally, it strongly opposes allowing 'emission avoidance' to qualify for ITMOs, citing poor definitions and the risk of crediting fossil fuel infrastructure.
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Document type: Statement
20 Years of the Environmental Integrity Group in Global Climate Governance
The report details the evolution of the Environmental Integrity Group (EIG) from its founding in 2000 to its role in the Paris Agreement. It highlights how the EIG's unique composition—including both developed and developing nations—enables it to facilitate compromises on technical and political issues such as climate finance, transparency, and carbon markets. The document also examines the individual contributions of member states like the Republic of Korea, Mexico, Monaco, Switzerland, Liechtenstein, and Georgia to global climate science and policy.
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Document type: Report
Conference on the Future of Europe
ClientEarth argues that the EU suffers from a persisting democratic deficit that hinders the implementation of the European Green Deal. The organization recommends four primary reforms: increasing transparency in decision-making (particularly in comitology and the EIB), granting the public direct access to the Court of Justice of the EU, ensuring EU accession to the European Convention on Human Rights (ECHR) to close human rights gaps in climate and environmental governance, and expanding the ordinary legislative procedure to all environmental matters to remove Member State vetoes on critical issues like fuel taxation.
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Document type: Statement