MCC-400 — VVB Standard

Document control

Field	Value
Document code	MCC-400
Title	VVB Standard (Validation and Verification Body Recognition and Performance)
Version	2.0-draft
Status	DRAFT — FOR CONSULTATION
Date of this draft	3 September 2026
Tier	Tier 3 (Document Hierarchy & Precedence Register, per FD-2026-09-03 item D5)
Effective date	None. This document is not in force. It takes effect only on approval under clause 22.1.
Document owner	Programme Administrator (transitional, until a Secretariat is staffed — FD-2026-10-01 Schedule 1, C3)
Approved by	Not approved. Prepared for public consultation.
Decision basis	Founder Decisions FD-2026-09-03, items D1–D8 (adopted 3 September 2026 in the programme working channel; to be tabled for ratification by the Governing Board), including item D8 (stay of entry into force of MCC-400 Addendum 1 v1.0). FD-2026-09-03 is recorded in the decision register as attested by the founder on 7 September 2026; no executed copy has been filed (the register at /governance/decisions shows its status).
Supersedes	The circulated consolidated text "MCC-400 VVB Accreditation and Performance Standard v1.1 — APPROVED" and, on entry into force of this version, the stayed MCC-400 Addendum 1 v1.0, the predecessor reclassified by FD-2026-09-03 item D5 and the Addendum stayed under item D8; the document register records v1.1 as in force, and the Addendum as stayed, until this version is adopted, when the withdrawal of v1.1 as a controlled copy is executed (FD-2026-09-07 item A8: scheduled, not executed). See the baseline declaration below.
Language convention	British English; RFC-style normative verbs (SHALL/MUST = mandatory; SHOULD = recommended, deviation to be documented; MAY = optional). Platform enumeration values are quoted verbatim and retain their spelling (for example "FULLY_ACCREDITED").
Classification	Public — consultation draft
Consultation period	30 days (FD-2026-10-01 Schedule 1, C4), from the opening recorded on the consultation register (FD-2026-09-04 item 2; FD-2026-10-01 item 5)

Baseline declaration and version-identity resolution

The controlled identity of the predecessor text is defective and is resolved here, honestly, by declaring a new baseline:

1. Two approval bodies in one control table. The circulated MCC-400 v1.1 control table states "Approved by: MCC Governance Board" and, in the same table, "Adopting decision: D-2026-08-11, Governing Board"; its body text alternates between the two names (Phase 0 source inventory §4; audit SYS-03). No signed record of decision D-2026-08-11 or of record MCC-BDR-2026-002 is in the programme record. MCC-BDR-2026-002 exists only as an unsigned draft with blank attendance, apologies, chair, quorum count and voting tallies; it records a Governing Board meeting of 17 August 2026 — nine days before the Board was constituted on 26 August 2026 — and states of itself that it is drafted from the resolutions as reported, so the adoption it is cited for is unevidenced (Evidence Register ER-2026-001 §B1).
2. Phantom cross-versions. MCC-400 v1.1 Appendix A.5 directs that Section 18 be read with "MCC-850 … v1.1", while the circulated MCC-850 cover reads v1.2; MCC-850 Appendix B.4 in turn cites a "MCC-400 v1.2" that has never existed. The two consolidations cite versions of each other that do not exist (Phase 0; audit 850-01).
3. APPROVED status over a not-in-force Section. The v1.1 cover states APPROVED while Section 18 (Articles 93–121) was expressly not in force until 17 September 2026 — a future-effective block inside an approved consolidated text (audit 400-09).
4. Stay of Addendum 1. By FD-2026-09-03 item D8, the entry into force of MCC-400 Addendum 1 v1.0 (Section 18, Articles 93–121, scheduled for 17 September 2026) is stayed; it has not entered into force and does not enter into force. This rewrite supersedes the stayed instrument by consolidating what survives of it (chiefly its integrity guardrails — see the change history) into a redesigned regime; nothing in this document revives the stayed text.
5. Truncation finding corrected. The audit (SYS-10/400-01) reported MCC-400 v1.1 as physically truncated (ending mid-Article 102, Articles 103–121 absent). Phase 0 verification against the corpus PDF (built 31 August 2026) found the file complete — Articles 1–121, Schedule 1 and Appendix A are all present. Finding 400-01 is overtaken; the audit evidently examined an earlier defective build. SHA-256 hashes for the served corpus are recorded in the platform document manifest and were verified byte-for-byte against the Drive corpus on 31 August 2026; no publication log predating that verification exists, so whether a truncated build was ever served cannot be established from the record (Evidence Register ER-2026-001 §B5). All substantive audit findings against MCC-400 (400-02 to 400-09) stand and are remediated in this version.

Resolution. This version 2.0-draft is declared the new baseline of MCC-400. It consolidates, where retained, the substance of MCC-400 v1.0 (Sections 1–17, printed effective 1 April 2026) and the surviving integrity guardrails of the stayed Addendum 1, as conformed to Founder Decisions FD-2026-09-03 D1–D8 and the other rewrites in this suite (MCC-001 v3.0-draft, MCC-100 v3.0-draft, MCC-200 v3.0-draft, MCC-700 v4.0-draft, and the drafts of MCC-600, MCC-ESS, MCC-CADCP, MCC-BPM and MCC-HCA). The version number 2.0 is used so that no reader can mistake this text for the disputed v1.1 consolidation or for the phantom "v1.2" cited by MCC-850. The predecessor is reclassified by FD-2026-09-03 item D5 and the Addendum is stayed under item D8; the document register records the predecessor as in force, and the Addendum as stayed, until this version is adopted, when the predecessor's withdrawal as a controlled copy, and its archiving as a superseded record with its printed identities noted, are executed (FD-2026-09-07 item A8: scheduled, not executed).

Change history

Version	Date	Change	Instrument
1.0	March 2026 (printed)	Base text, Sections 1–17, Articles 1–92; printed as in force since 1 April 2026	No such instrument is in the programme record; the programme's document corpus was searched on 3 September 2026 (Evidence Register ER-2026-001 §B3).
1.1	17 August 2026 (printed)	Consolidation adding Section 18 (Articles 93–121, AI-Augmented Validation and Verification) via Addendum 1 v1.0, printed as adopted as amended with five Board modifications recorded in its Appendix A.2; Section 18 printed as entering into force 17 September 2026	Printed as decision D-2026-08-11, Governing Board (record MCC-BDR-2026-002). MCC-BDR-2026-002 exists only as an unsigned draft with blank attendance, apologies, chair, quorum count and voting tallies; it records a Governing Board meeting of 17 August 2026 — nine days before the Board was constituted on 26 August 2026 — and states of itself that it is drafted from the resolutions as reported, so the adoption it is cited for is unevidenced (Evidence Register ER-2026-001 §B1).
—	3 September 2026	Entry into force of Addendum 1 v1.0 (Section 18) stayed; Section 18 never entered into force	FD-2026-09-03 item D8
2.0-draft	3 September 2026	Full rewrite against the independent audit of 3 September 2026 (findings 400-01 to 400-09, with 400-01 overtaken by Phase 0; SYS-02, SYS-03, SYS-11) and FD-2026-09-03 items D1–D8: recognition decisions moved from the Programme Administrator to the VVB Oversight Committee under MCC-700 Annex A; eligibility re-based on accreditation to ISO 14065:2020 with ISO/IEC 17029, with ISO 14066:2023 as the competence design reference, replacing the ICROA/ICVCM equivalence route; recognition pipeline aligned to the platform's vvb_accreditation_status model; the AI-anchored workflow of the stayed Section 18 replaced by a mandatory blind first pass with post-lock AI discrepancy review; confidence-band sampling (10/30/100%) abolished in favour of VVB-set risk/materiality sampling that no AI output may reduce; separate GHG and marine-outcome assurance objectives added; scope families generated from the canonical family matrix; suspended-VVB default completion of engagements replaced by case-by-case containment; local retention periods replaced by the canonical Record Retention Schedule; AI-premised fee-reduction economics removed; honest first-recognition transitional path added (no VVB is accredited)	FD-2026-09-03 items D1–D8

NOTE (non-normative). This document is issued for public consultation. Nothing in it asserts that any approval, accreditation, recognition, engagement, eligibility or operational history exists unless a linked record is identified in the MCC Evidence Register. Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions below and marked in the text.

Consultation questions

Each point below is open for comment. A proposal is the administration's proposal, put to consultation under founder direction FD-2026-10-01; it is not a rule in force. The suite is to be adopted as one instrument once its longest consultation period has closed (FD-2026-10-01 Schedule 1, C4). Because it includes the Constitution, whose amendment is within the competence of the constituted Governing Board (FD-2026-08-24 item D11, recorded in the decision register as attested by the founder, with no executed copy filed), each point below is decided by the Governing Board on adoption of the suite; a clause of this text that provides another route for adopting it alone is itself open to comment.

1. Clause 4.6 — VVB professional indemnity. Proposed: USD 2 million per occurrence and USD 5 million in aggregate. Basis: FD-2026-08-24 item D7; FD-2026-10-01 Schedule 1 (C6). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether these minimums are proportionate, and on whether the first limit should apply per occurrence, as proposed, or per claim, as FD-2026-08-24 item D7 prints it.

2. Clause 5.6 — Lead Auditor examination threshold. Proposed: at least 70% on the technical examination, with a satisfactory case-study performance, and a retake after ninety days. Basis: carried from MCC-400 v1.0 Article 24 as an open decision for consultation (FDP-2026-001 Part 3); no validation evidence for the threshold exists. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether 70% is the right threshold and on the evidence that should support it.

3. Clause 5.9 — Mandatory provisional stage. Proposed: every recognition passes through PROVISIONAL before FULLY_ACCREDITED, with no bypass. Basis: an open decision carried in the draft (FDP-2026-001 Part 3). It departs from MCC-400 v1.0 Article 29, which permitted full accreditation directly; the platform's recognition pipeline places PROVISIONAL before FULLY_ACCREDITED, and no VVB is recognised and no engagement has been performed under the Programme (ER-2026-001 §B5). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether a bypass of PROVISIONAL should be available, and on what evidence.

4. Clause 18.1 — VVB recognition fees. Proposed: EUR 2,500 on application, EUR 1,500 a year and EUR 500 per engagement, set in the MCC Fee Schedule. Basis: FD-2026-10-01 Schedule 1 (C6). Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-400 v1.1 art. 84; FD-2026-09-04 item 6). The per-engagement fee is not one of the fee heads clause 18.1 lists, nor one of the five heads of MCC-400 v1.1 art. 84 (MCC Fee Schedule draft, line V6). Comments are invited on the amounts, on whether they are proportionate, and on whether a per-engagement fee should be a fee head at all.

5. Annex A, A-2 — Denial and reapplication. Proposed: DENIED may be entered from any pipeline stage and from RENEWAL_IN_PROGRESS, as the Annex A table provides; a LAPSED or WITHDRAWN VVB reapplies as a new applicant. Basis: an open decision carried in the draft (FDP-2026-001 Part 3); the table is to be confirmed against the transitions configured in the platform's workflow transition guard (ER-2026-001 §A3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether denial should be available only after a completed assessment.

6. Annex B — Specialist competence required by family. Proposed: the specialist competence stated for each family in the last column of the Annex B table, as drafted, populating the "VVB scope" column that the canonical Family–Methodology–Instrument Matrix leaves open. Basis: the drafting of this Standard (Annex B, GENERATED CONTENT note); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on the competence required for each family.

Table of contents

1. Purpose, scope and application
2. Normative references, definitions and interpretation
3. Governance interface and decision rights
4. Eligibility for recognition
5. Recognition process and status model
6. Scope of recognition
7. Competence
8. Impartiality and conflicts of interest
9. Engagement conduct
10. Evidence, sampling and assurance
11. Blind first pass and AI discrepancy review
12. Validation and verification reports
13. Performance monitoring and annual review
14. Witness audits and spot checks
15. Suspension, denial, lapse and withdrawal
16. Renewal
17. Assignment and rotation
18. Fees
19. Records and transparency
20. Use of AI systems by VVBs
21. Transitional provisions — the first-recognition path
22. Entry into force

Annex A — Recognition status model (normative) Annex B — Scope-of-recognition families (normative) Annex C — Two-stage engagement workflow (informative)

---

1. Purpose, scope and application

1.1 This Standard (MCC-400) SHALL establish the requirements for the recognition, competence, impartiality, engagement conduct, oversight, performance management and sanctioning of Validation and Verification Bodies (VVBs) under the Marine Conservation Credits (MCC) Programme.

1.2 This Standard SHALL apply to: (a) applicants for VVB recognition; (b) recognised VVBs; (c) the individual auditors, technical experts and peer reviewers they deploy; (d) MCC-appointed accreditation assessors and witness-audit assessors; and (e) every Programme body and function exercising a power under this Standard.

1.3 No validation or verification report SHALL be accepted by the Programme unless issued by a VVB recognised under this Standard for the applicable scope at the time of the engagement (MCC-001 clause 5.3; MCC-100 clause 18.1).

1.4 VVB competence, impartiality, insurance, sampling independence, rotation, cooling-off and oversight requirements are stated exclusively in this Standard; no methodology, procedure or other MCC instrument SHALL vary them (MCC-100 clause 18.1; MCC-200 clause 7.9; MCC-700 clause 15.3).

1.5 This Standard is a Tier 3 instrument under the Document Hierarchy & Precedence Register; precedence is governed by MCC-001 Section 2, and a requirement of this Standard that depends on a referenced instrument is ineffective until MCC-001 clause 2.5 is satisfied for that instrument.

NOTE. The following instruments referenced in this Standard are not in force: the Record Retention Schedule (MCC-810) and the rewritten MCC-850 (v2.0-draft), each put to consultation with this suite; the Fee Schedule (MCC-FEES, 1.0-draft), put to consultation with this suite, which asks the Governing Board whether any fee amount has already been set (clause 18.1; MCC-FEES 1.0-draft cll. 2.1 and 3.3); the VVB application and COI-declaration templates; and the report templates, of which the Validation Report Template, the Verification Report Template and the VVB Accreditation Assessment Report Templates closed their consultations on 8 and 9 September 2026 with closing protocols of 24 September 2026 recommending adoption, and none of them is entered in the document register as adopted. The Definitions Register is in force (clause 2.5). Each dependent requirement is deferred under clause 1.5, never silently effective.

2. Normative references, definitions and interpretation

2.1 The following Programme documents are normatively referenced: MCC-001 Constitution; MCC-100 Programme Standard (Sections 18, 19, 22 and 23 in particular); MCC-200 Methodology Framework (clause 7.9 and Annex B in particular); MCC-700 Governance and Appeals (Sections 5, 10–12, 15 and 20, Annex A and Annex B in particular); MCC-850 AI Governance; MCC-800 Registry Operations; the Environmental & Social Safeguards Policy (MCC-ESS); and the MCC Record Retention Schedule.

2.2 The following International Standards are referenced as design references: ISO/IEC 17029:2019 (Conformity assessment — General principles and requirements for validation and verification bodies); ISO 14065:2020 (General principles and requirements for bodies validating and verifying environmental information); ISO 14064-3:2019 (Greenhouse gases — Specification with guidance for the verification and validation of greenhouse gas statements); and ISO 14066:2023 (Environmental information — Competence requirements for teams validating and verifying environmental information). A design reference informs the design of this Standard's requirements; it is not a claim that MCC, the Programme, this Standard or any MCC unit is accredited to, certified against, approved under, or endorsed by any of these standards or their issuing bodies.

2.3 In this Standard: Recognition means the Programme's decision, under Section 5, to accept a VVB for a defined scope; it is recorded in the registry platform's vvb_accreditation_status field, and the words "accreditation" and "accredited", where used in this Standard without qualification, refer to MCC recognition. ISO accreditation means accreditation of a body by an accreditation body operating under ISO/IEC 17011. MCC recognition is not ISO accreditation, and a recognised VVB SHALL NOT represent MCC recognition as an ISO or governmental accreditation.

2.4 In this Standard: Validation means the ex-ante, systematic, independent and documented evaluation of a project design against the applicable methodology and Programme requirements; Verification means the ex-post, systematic, independent and documented evaluation of an environmental information statement (a GHG statement or a marine-outcome statement) for a defined period and assurance level; Engagement means one validation or one verification of one project; First-Pass Record means the locked record defined in clause 11.4; AI Discrepancy Review means the Stage 2 review defined in clauses 11.6 to 11.9; Witness Audit means observation of a VVB engagement (live or simulated) by an MCC-appointed assessor; Spot Check means an unannounced oversight examination under clause 14.5; Recognition Cycle means the five-year validity period of clause 5.12.

2.5 Terms used with initial capitals and not defined in clause 2.3 or 2.4 SHALL have the meanings assigned in the MCC Definitions Register, which is in force (v1.0; FD-2026-08-24 item D12, recorded in the decision register as attested by the founder, with no executed copy filed); where that Register does not define a term, the canonical meanings adopted through FD-2026-09-03 apply as interim definitions.

2.6 The normative verb conventions of MCC-001 clause 3.1 SHALL apply throughout this Standard; each numbered clause states one testable requirement, and text introduced by "NOTE" or "GUIDANCE" is non-normative.

3. Governance interface and decision rights

3.1 Every recognition, scope, monitoring-outcome, sanction, suspension, withdrawal and renewal decision under this Standard SHALL be taken by the VVB Oversight Committee under MCC-700 Annex A row 6; no such decision SHALL be taken by the Programme Secretariat or any administrator function (MCC-001 clause 9.4.1; MCC-700 clause 15.2).

NOTE. This supersedes the accreditation power that MCC-400 v1.1 Article 17 and Articles 29, 38, 72–75 and 79 vested in the "Programme Administrator" (audit 400-03). The Programme Secretariat performs the administrative functions this Standard assigns to it, within its delegated authority, and holds no approval power over VVB recognition (MCC-001 clause 9.7.2).

3.2 The Programme Secretariat SHALL administer the recognition process — receiving applications, managing assessor logistics, maintaining the public VVB register, operating the registry platform workflows and preparing decision papers — and SHALL NOT approve, refuse, suspend or sanction any VVB.

3.3 Accreditation assessors and witness-audit assessors SHALL be appointed by the VVB Oversight Committee, SHALL be free of conflicting interests in respect of the assessed VVB under Section 8 principles, and SHALL NOT hold any commercial role in the Programme.

3.4 Every decision under this Standard SHALL be issued in writing with reasons per MCC-700 clause 10.4, and SHALL carry the independent review and appeal rights of MCC-700 Sections 11 and 12; appeals against refusals of recognition and against suspensions and revocations are heard de novo by the Independent Appeals Panel (MCC-700 clause 12.5 and Annex A row 6).

3.5 During the transitional period of MCC-700 Section 23, the functions of the VVB Oversight Committee under this Standard are exercised by the founder, logged as Founder Decisions and tabled for ratification; nothing in this Standard asserts that the Committee is currently constituted.

4. Eligibility for recognition

4.1 An applicant for VVB recognition SHALL be a legal entity in good standing in its jurisdiction of incorporation, evidenced by current registration documents.

4.2 An applicant SHALL hold current ISO accreditation to ISO 14065:2020 (with ISO/IEC 17029:2019) for validation and/or verification of greenhouse gas statements or environmental information, issued by an accreditation body that is a signatory to the International Accreditation Forum multilateral recognition arrangement for the relevant scope, and SHALL maintain that ISO accreditation throughout any MCC recognition.

NOTE. This replaces MCC-400 v1.1 Article 14, under which accreditation "under another ICROA-endorsed or ICVCM-approved crediting programme" could substitute for ISO accreditation. ICVCM assesses crediting programmes and categories, and ICROA endorsement concerns programmes — neither is an accreditation of individual VVBs, and neither is a competence basis for one (audit 400-02). Approval under another crediting programme MAY be submitted as supporting evidence of experience under clause 4.4; it SHALL NOT substitute for the clause 4.2 requirement.

4.3 An applicant SHALL demonstrate relevant experience in marine, coastal or blue-carbon assessment, or a documented plan to obtain the family-specific specialist competence of Annex B before deploying any engagement team.

4.4 An applicant MAY submit evidence of approval, accreditation or performance under other crediting programmes as supporting evidence of experience; such evidence SHALL be weighed by the assessor and SHALL NOT reduce any requirement of this Standard.

4.5 An applicant SHALL demonstrate financial and organisational independence from project developers, credit buyers, intermediaries and MCC's own commercial functions; no entity with a financial interest in the outcome of any MCC engagement is eligible.

4.6 An applicant SHALL maintain professional indemnity insurance of at least USD 2 million per occurrence and USD 5 million in aggregate, or equivalent coverage accepted by the VVB Oversight Committee. (Consultation question 1.) These are the amounts FD-2026-08-24 item D7 fixed ("forsikringskrav til VVB-er: USD 2 000 000 per krav / USD 5 000 000 aggregert"), the alignment MCC-700 v3.1 clause 5.2 cited; "per krav" is per claim, while the VVB Terms v1.1 article 11.1 state the first limit per occurrence. FD-2026-08-24 is served in the public document manifest and is recorded in the decision register as attested by the founder, with no executed copy filed; GB-2026-001 item 2, which the decision register also records as attested by the founder, with no executed copy filed, records its ratification as to substance (Evidence Register ER-2026-001 §B2; the register at /governance/decisions).

4.7 An applicant SHALL operate a documented quality management system and a documented conflict-of-interest policy meeting at least the requirements of Section 8.

4.8 An applicant SHALL NOT be, and SHALL NOT be under common beneficial ownership or control with, any entity excluded from the Programme under MCC-100 Section 23.

5. Recognition process and status model

5.1 The recognition process SHALL proceed through the following stages, recorded in the registry platform's vvb_accreditation_status field: APPLICATION_SUBMITTED → ASSESSOR_ASSIGNED → DESK_REVIEW → COMPETENCE_ASSESSMENT → WITNESS_AUDIT → PROVISIONAL → FULLY_ACCREDITED, with the non-pipeline statuses SUSPENDED, RENEWAL_IN_PROGRESS, DENIED, LAPSED and WITHDRAWN applied as provided in Annex A; no other status value SHALL be used.

GENERATED CONTENT. The status values and their pipeline order are quoted verbatim from the registry platform's vvb_accreditation_status enumeration; Annex A states the semantics this Standard attaches to each value. The implemented enumerations and transitions are those in the platform schema and the workflow transition guard; the schema drift audit reports zero column drift and zero enum drift as at 3 September 2026 (Evidence Register ER-2026-001 §A3).

5.2 Application (APPLICATION_SUBMITTED). Applications SHALL be submitted through the registry platform using the prescribed application form and SHALL include: legal entity documentation; evidence of the clause 4.2 ISO accreditation; CVs of proposed Lead Auditors and Technical Experts; quality management system documentation; the engagement history of the preceding five years; evidence of insurance; the COI policy; and references from at least two crediting programme operators or equivalent assurance clients.

5.3 Assessor assignment (ASSESSOR_ASSIGNED). The Programme Secretariat SHALL acknowledge a complete application within five business days, and the VVB Oversight Committee SHALL assign an accreditation assessor within ten business days of acknowledgement.

5.4 Desk review (DESK_REVIEW). The assessor SHALL complete a desk review of the application within thirty business days of assignment, verifying completeness and eligibility under Section 4, and SHALL issue a Desk Review Report identifying any non-conformities and recommending whether to proceed; each request for additional information SHALL allow the applicant fifteen business days to respond.

5.5 Competence assessment (COMPETENCE_ASSESSMENT). Each proposed Lead Auditor SHALL pass a competence assessment comprising: (a) a technical examination covering MCC-001, MCC-100, MCC-200, the relevant methodologies, MCC-850 and this Standard; (b) a case-study assessment demonstrating identification of non-conformities and quantification errors in simulated MCC project documentation, including at least one simulated blind first pass under Section 11; and (c) an interview with the assessor.

5.6 A Lead Auditor SHALL achieve at least 70% on the technical examination and a satisfactory case-study performance to be approved; an unsuccessful candidate MAY retake the assessment after ninety days. (Consultation question 2.)

5.7 Witness audit stage (WITNESS_AUDIT). Before any recognition is granted, the applicant SHALL complete at least one witnessed engagement — an actual MCC engagement where one is available, and otherwise a simulated engagement on Programme-provided case materials — observed and reported on by an MCC-appointed witness-audit assessor against the criteria of clause 14.2.

5.8 Provisional recognition (PROVISIONAL). On the basis of the Desk Review Report, the competence assessment results and the Witness Audit Report, the VVB Oversight Committee SHALL decide provisional recognition, with conditions, or denial with reasons; the decision SHALL be communicated within ten business days of completion of all assessment stages.

5.9 Every recognition SHALL pass through PROVISIONAL before FULLY_ACCREDITED. (Consultation question 3.)

5.10 A provisionally recognised VVB SHALL be subject to enhanced oversight: (a) every validation and verification report reviewed by an MCC-appointed independent peer reviewer before acceptance; (b) no more than three engagements per year; and (c) at least one witnessed live MCC engagement before full recognition.

5.11 Full recognition (FULLY_ACCREDITED). The VVB Oversight Committee SHALL grant full recognition where the provisional conditions are discharged, the clause 5.10(c) witnessed live engagement is satisfactorily reported, and no unresolved non-conformity remains; provisional recognition SHALL otherwise lapse eighteen months after grant (status LAPSED), after which the applicant must reapply.

5.12 Full recognition SHALL be valid for five years from the recognition decision, subject to ongoing compliance with this Standard, annual performance review under Section 13 and continued ISO accreditation under clause 4.2.

5.13 A denial (DENIED) SHALL state each ground separately (MCC-700 clause 10.5) and is appealable de novo under clause 3.4.

6. Scope of recognition

6.1 Every recognition SHALL specify a scope defined by: (a) service type — validation, verification, or both; (b) methodology family — one or more of F01 to F05 per Annex B; and (c) statement type — GHG statements (MCC-CC), marine-outcome statements (MCC-MOU), or both.

NOTE. Statement-type scope implements the split assurance model of FD-2026-09-03 item D1 and MCC-100 clause 18.5, replacing the carbon-only assurance framing of the predecessor (audit 400-07): a VVB competent for GHG quantification is not thereby competent for marine-outcome metrics, and conversely.

6.2 The methodology-family scope values SHALL be exclusively the canonical families of the Family–Methodology–Instrument Matrix adopted under FD-2026-09-03 item D2, as reproduced in Annex B; the family taxonomy printed in MCC-400 v1.1 Article 32 (F01 mangrove … F05 kelp) is superseded and SHALL NOT be used (audit SYS-02).

6.3 A VVB SHALL NOT accept, and the platform SHALL NOT assign, an engagement outside the VVB's recognised scope.

6.4 A recognised VVB MAY apply to extend its scope to additional families or statement types by demonstrating the required specialist competence; scope extensions SHALL be decided by the VVB Oversight Committee and MAY require a further witness audit.

6.5 The Programme Secretariat SHALL maintain, on the public register, the current recognition status, scope and expiry date of every VVB, generated from the registry record.

7. Competence

7.1 Each VVB SHALL establish, document and maintain team competence in accordance with the principles of ISO 14066:2023 as a design reference: for every engagement, the VVB SHALL determine the competences the engagement requires, map them to the team deployed, and record the mapping in the engagement plan.

7.2 Each Lead Auditor SHALL hold, at minimum: (a) a degree in environmental science, marine science, ecology, engineering or a related discipline; (b) lead-auditor certification for ISO 14064-3-based validation/verification or equivalent; (c) at least three years of validation/verification experience; and (d) approval under clause 5.5 for each methodology family in which they lead.

7.3 Each engagement team SHALL include at least one Technical Expert with specialist knowledge relevant to the project's family per Annex B; Technical Experts need not hold auditor qualifications but SHALL evidence at least five years of relevant professional experience.

7.4 For engagements on Category A (high-risk) projects under the Environmental & Social Safeguards Policy, the team SHALL include a safeguards specialist with environmental and social impact assessment experience (see MCC-ESS clauses 3.3 and 7.1 for the assessment duties the specialist discharges).

7.5 For any engagement covering a GHG statement quantified by life-cycle assessment (family F03 CC-leg engagements in particular), the team SHALL include demonstrated LCA competence.

7.6 Each Lead Auditor SHALL complete at least twenty hours per year of continuing professional development relevant to their MCC scope, recorded by the VVB and reviewable under Section 13.

7.7 The VVB SHALL maintain an internal peer-review capability: every report SHALL be internally peer-reviewed under clause 9.9 by a qualified reviewer who was not a member of the engagement team.

8. Impartiality and conflicts of interest

8.1 Each VVB SHALL maintain and implement a documented impartiality and conflict-of-interest (COI) policy at least as stringent as this Section, informed by the impartiality principles of ISO/IEC 17029 and ISO 14065:2020 as design references, including identification, analysis, treatment and monitoring of threats to impartiality (self-interest, self-review, familiarity, intimidation and advocacy threats).

8.2 A VVB SHALL NOT accept an engagement where: (a) the VVB or any team member has a financial interest in the project, the project developer or the credited units; (b) the VVB has provided consultancy services to the project developer within the preceding three years; (c) any team member has a personal or family relationship with key personnel of the developer; or (d) the engagement would breach the rotation or same-project separation rules of Section 17.

8.3 A VVB's fees for an engagement SHALL NOT be contingent on the engagement's conclusion, on the volume of units issued, or on any commercial outcome for the developer or any buyer.

8.4 Before accepting each engagement, the VVB SHALL conduct a documented COI screening covering every team member and the VVB itself, and SHALL submit a signed COI declaration through the registry platform; the engagement SHALL NOT commence until the declaration is recorded as accepted in the platform.

8.5 The Programme Secretariat SHALL review each COI declaration administratively within five business days and SHALL refer any identified or suspected conflict to the VVB Oversight Committee.

8.6 The VVB Oversight Committee MAY direct a VVB to decline or terminate an engagement where it identifies a conflict of interest, whether or not the VVB's own screening flagged it; such a direction is appealable under clause 3.4.

8.7 A programme override of a COI screening SHALL operate in one direction only: a direction or platform control MAY block or terminate an engagement on conflict grounds, but no programme body, official or platform action SHALL clear, waive or override a conflict identified by the VVB's own screening or by the platform's screening rules.

8.8 A conflict arising after commencement SHALL be declared by the VVB through the platform within five business days of the VVB becoming aware of it, with the engagement paused pending the clause 8.6 determination.

8.9 An undeclared material conflict discovered at any time is grounds for suspension under Section 15 and for re-examination of every engagement the conflict touched.

9. Engagement conduct

9.1 Engagements SHALL be initiated, coordinated and documented exclusively through the registry platform's VV coordination workflow, which records assignment, progress, document exchange, findings and reports.

9.2 Within ten business days of assignment, the VVB SHALL submit an engagement plan stating: the scope and statement types; the team composition with the clause 7.1 competence mapping; the timeline; the site-visit position under clause 9.5; and a confirmation that the sampling plan will be established under Section 10 within the blind first pass.

9.3 The VVB SHALL review all project documentation relevant to the engagement, including the project design document or monitoring report, supporting data, safeguards assessment and ESMP where applicable, stakeholder consultation records, grievance register, and previous validation and verification reports.

9.4 Validation SHALL cover at minimum the matters of MCC-100 clause 18.3, and verification the matters of MCC-100 clause 18.4, in each case extended by the methodology's MOD-06/MOD-07 requirements (MCC-200 clause 7.9).

9.5 A physical site visit SHALL be conducted for: (a) every initial validation; (b) the first verification of each crediting period; and (c) any engagement where the VVB's risk assessment or the methodology requires it (MCC-100 clause 18.9).

9.6 A remote assessment (satellite imagery, drone survey, video inspection) MAY substitute for a mandatory site visit only where site access is demonstrably impractical or unsafe, with the justification documented in the engagement plan and no objection recorded by the VVB Oversight Committee within ten business days of the plan's submission.

9.7 During a site visit the VVB SHALL: verify the physical existence and condition of the project; confirm monitoring data by independent measurement or observation; interview project staff and local stakeholders, including affected community members selected by the VVB; and assess safeguards implementation and the grievance register.

9.8 The VVB SHALL classify findings as: Major non-conformity (a material failure that could affect the integrity of units or labels — must be resolved before any positive conclusion); Minor non-conformity (a non-material failure — must be resolved before the next engagement); Observation; or Forward action; findings SHALL be communicated to the developer through the platform, with thirty days for the developer's evidence of corrective action.

9.9 Every report SHALL undergo internal peer review by a qualified reviewer who was not on the engagement team, covering completeness, adequacy of evidence, correctness of quantification and conformity with this Standard; the peer reviewer SHALL have access to the First-Pass Record and the discrepancy dispositions of Section 11.

9.10 For verification, the VVB SHALL independently recompute the quantification (baseline, monitoring data application, methodology calculations, uncertainty and conservativeness treatment, leakage and any permanence-related deductions) and SHALL state a final verified quantity, rounded down at the methodology's unit precision, as the sole basis for any issuance recommendation.

9.11 The VVB SHALL verify the durability-class assignment and buffer-contribution calculation where the Buffer Pool Management Policy requires it (MCC-BPM clauses 5.2 and 9.5), and SHALL assess continued domestic-legality validity per MCC-HCA clause 4.11.

9.12 Obstruction of the VVB's access to documentation, data, systems, sites or persons is a material breach by the developer under MCC-100 clause 18.10; the VVB SHALL report any obstruction through the platform within five business days.

10. Evidence, sampling and assurance

10.1 The VVB SHALL determine its own evidence-gathering plan and sampling for every engagement on risk and materiality grounds — the assessed risks of material misstatement and non-conformity, and the materiality thresholds of MCC-200 Annex B — using its professional judgement (MCC-100 clause 18.6).

10.2 The sampling plan SHALL be established and recorded in the First-Pass Record before the VVB receives any AI output for the engagement (clause 11.4).

10.3 No AI output — no confidence value, score, tier, flag, completeness assessment or sampling suggestion — SHALL reduce the VVB's evidence, sampling, scrutiny or procedures below what the VVB's own risk and materiality assessment requires, and no confidence value SHALL map to any sampling quantum.

NOTE. This abolishes the confidence-band sampling architecture of the stayed Section 18 (Articles 99–102 and Schedule 1: 10%/30%/100% sampling keyed to HIGH/MEDIUM/LOW AI confidence), which the audit found statistically indefensible (400-05) and which the Addendum as printed itself part-suspended (Article 99.1's 30% floor pending calibration evidence). Under this Standard the question those provisions answered no longer arises: AI confidence has no sampling consequence in any direction except under clause 10.6.

10.4 Verification supporting any issuance SHALL be performed to a reasonable level of assurance, and validation to the level of assurance the methodology's MOD-06 specifies, in each case informed by ISO 14064-3:2019 as a design reference; the assurance level SHALL be stated in the report.

10.5 Where an engagement covers both a GHG statement and one or more marine-outcome statements, the VVB SHALL apply separate assurance objectives, separate materiality and separate sampling to each statement, and SHALL reach separately identifiable conclusions (MCC-100 clause 18.5).

10.6 An AI output examined in Stage 2 MAY cause the VVB to add procedures, evidence or sampling; it SHALL NOT cause the VVB to remove or reduce any.

10.7 The aggregate of uncorrected misstatements SHALL be below the applicable MCC-200 Annex B materiality threshold before the VVB issues any positive verification conclusion (MCC-100 clause 9.6).

10.8 The sampling plan, its risk assessment basis, and every subsequent addition to it SHALL be documented in the working papers and summarised in the report.

11. Blind first pass and AI discrepancy review

11.1 Every engagement SHALL be conducted in two stages: Stage 1, an independent first pass performed and concluded blind to all AI outputs; and Stage 2, an AI discrepancy review conducted only after the First-Pass Record is locked.

11.2 During Stage 1, no AI output concerning the project or the engagement — no score, flag, finding, completeness assessment, risk indication, anomaly detection, sampling suggestion, confidence value, tier or recommendation generated by any Programme AI system — SHALL be made accessible to the VVB or any member of the engagement team, and the VVB SHALL NOT seek, receive or use any such output from any source.

11.3 The registry platform SHALL withhold every AI output for the engagement from every VVB user until the First-Pass Record is locked; the platform SHALL log every AI-output access with user, time and engagement.

11.4 Before receiving any AI output, the VVB SHALL complete and lock the First-Pass Record, containing: (a) the sampling plan and its risk and materiality basis (Section 10); (b) the findings per assessment area; (c) the draft validation or verification conclusions, including the draft verified quantity for a verification; and (d) the evidence relied on; once locked, the First-Pass Record SHALL be immutable, time-stamped and retained with the working papers.

11.5 The engagement SHALL NOT proceed to Stage 2, and no AI output SHALL be released to the VVB, until the platform records the First-Pass Record as locked.

11.6 In Stage 2, the VVB SHALL obtain and review the AI findings for the engagement; only findings, flags and categorical outputs SHALL be disclosed to the VVB — the platform SHALL NOT disclose any AI approval/rejection recommendation field or numeric confidence score to the VVB or any other engagement participant (MCC-850's non-disclosure rules).

11.7 The VVB SHALL identify every difference between its first-pass findings or conclusions and the AI findings, and SHALL disposition each difference in writing, as either: (a) first-pass position maintained, with reasons and the evidence relied on; or (b) first-pass position revised, only on the basis of additional evidence obtained by the VVB under its own procedures — a revision SHALL NOT rest on the AI finding alone.

11.8 No Stage 2 disposition SHALL reduce the evidence, sampling or scrutiny recorded in the First-Pass Record; Stage 2 MAY only add procedures under clause 10.6.

11.9 The disposition record — each difference, its disposition and reasons — SHALL form part of the validation or verification report and SHALL be published with the report, subject to clause 12.5's redactions.

11.10 If any AI output reaches any engagement team member before the First-Pass Record is locked, the VVB SHALL report the exposure through the platform within two business days; the VVB Oversight Committee SHALL then determine the containment measures (replacement of exposed team members, re-performance of affected work, or documented mitigation), and the engagement SHALL NOT support any registration or issuance until that determination is made and discharged.

11.11 For Category A (high-risk) projects under the Environmental & Social Safeguards Policy, the VVB SHALL perform full independent verification of every safeguards-relevant matter regardless of any AI output, with AI outputs used in Stage 2 as supporting input only.

11.12 First-Pass Records and disposition records SHALL be made available to the Programme for AI calibration under MCC-850; calibration use is one-way — no calibration output, cohort statistic or model update SHALL alter any requirement of this Standard for any engagement.

11.13 Where a first pass identifies an issue that the AI findings missed, that fact SHALL be treated as calibration input to the AI system under MCC-850 and SHALL NOT be treated as an adverse indicator against the VVB.

NOTE. This Section replaces the workflow of the stayed Section 18 (Articles 98–106), under which each engagement began with the team's review of the AI Analysis Sidebar and AI outputs steered sampling, document-review focus and site-visit scope before the VVB formed any independent view — the anchoring design the audit identified as the core VVB defect (400-06; 850-05). It preserves, in stronger form, the guardrails printed in the Addendum as modifications made on its adoption, whose record, MCC-BDR-2026-002, is recorded in the decision register as unsigned (Article 95.1: no reliance on non-operational components; Article 99.1: no sampling reduction without calibration evidence; Article 103.1: no reduction in Degraded Mode; Article 106: no disclosure of recommendation fields or numeric scores): under this Standard no AI output of any component, in any operational state, at any calibration level, can reduce anything (clauses 10.3, 10.6, 11.8), so the component-status and degraded-mode machinery is subsumed rather than restated. Component operational-status publication remains an MCC-850 obligation and is not restated here.

12. Validation and verification reports

12.1 Every validation report SHALL state, at minimum: the project identity and developer; the methodology and version; the scope, statement types and assurance level; the team composition and competence mapping; the sampling plan summary; findings and their resolution; the Stage 2 disposition record; the validation conclusion (positive, positive with conditions, or negative) with reasons; safeguards assessment conclusions; the internal peer-review statement; and the VVB's identity, recognition scope and statement of independence.

12.2 Every verification report SHALL state, in addition: the monitoring period; the verified quantity per statement type, with the VVB's adjustments to the developer's quantification and reasons; the recommended issuance volume per instrument; the durability-class and buffer-contribution verification where applicable; and the sustainable development and safeguards implementation assessments.

12.3 Where the engagement covers both GHG and marine-outcome statements, the report SHALL present a separately identifiable conclusion for each statement (clause 10.5); a single blended conclusion SHALL NOT be issued.

12.4 A positive conclusion SHALL NOT be issued while any major non-conformity is unresolved.

12.5 Reports SHALL be submitted through the registry platform and become public on completion of the relevant workflow, subject only to: redaction of commercially sensitive information per MCC-100 clause 20.7; and the MCC-850 non-disclosure rules for AI recommendation fields and numeric confidence scores.

12.6 Reports SHALL follow the prescribed MCC report templates once published; until then, the clause 12.1–12.3 content requirements apply directly.

12.7 A negative conclusion, and any conclusion later found to have been procured by misrepresentation, SHALL be reported by the VVB to the Programme Secretariat within five business days and processed under MCC-100 Section 23 (MCC-100 clause 18.11).

13. Performance monitoring and annual review

13.1 The Programme Secretariat's compliance monitoring function SHALL monitor each recognised VVB continuously against the indicators of clause 13.2 and SHALL prepare an annual performance review file for each VVB.

13.2 The performance indicators SHALL be: (a) timeliness of engagement completion against the engagement plan; (b) report quality, as assessed by post-engagement review and internal peer-review outcomes; (c) quantification accuracy, as compared with independent spot-check recalculations; (d) resolution of findings within prescribed timeframes; (e) COI and procedural compliance, including First-Pass Record integrity under Section 11; and (f) CPD compliance.

13.3 No performance indicator SHALL measure a VVB's rate of agreement or disagreement with AI findings, its deviation from cohort or model statistics, or its speed relative to AI-derived expectations; quality SHALL be assessed through sampled outcome review of the VVB's actual work.

NOTE. This removes the stayed Section 18's performance metrics (Articles 110–111: "deviation rate from AI findings" and sanctions for "systematic patterns of unsupported deviation"), which penalise legitimate expert judgement and reintroduce anchoring through the back door (audit 400-06; 850-07).

13.4 The VVB Oversight Committee SHALL conduct an annual performance review of each recognised VVB and SHALL record exactly one outcome per review in the registry: SATISFACTORY, IMPROVEMENT_REQUIRED or UNSATISFACTORY.

GENERATED CONTENT. The outcome values are quoted verbatim from the platform's performance-review outcome enumeration. The implemented enumerations and transitions are those in the platform schema and the workflow transition guard; the schema drift audit reports zero column drift and zero enum drift as at 3 September 2026 (Evidence Register ER-2026-001 §A3).

13.5 An outcome of IMPROVEMENT_REQUIRED SHALL require the VVB to submit a corrective action plan within thirty days, whose implementation the compliance monitoring function SHALL track to closure.

13.6 An outcome of UNSATISFACTORY SHALL be referred to the suspension and withdrawal process of Section 15.

13.7 Review outcomes SHALL be communicated to the VVB within fifteen business days of the review, recorded on the registry, and published on the public VVB register.

13.8 Every recognised VVB SHALL be subject to at least one oversight activity (performance review, witness audit or spot check) in every twelve-month period.

14. Witness audits and spot checks

14.1 The VVB Oversight Committee SHALL conduct at least one witness audit of every recognised VVB per Recognition Cycle, and additional witness audits where performance history, complaints or risk warrant.

14.2 A witness-audit assessor SHALL evaluate: methodology application; evidence gathering and the risk/materiality basis of sampling; conduct of the blind first pass and the integrity of the First-Pass Record; site-visit procedures where applicable; findings identification and communication; quantification review; Stage 2 disposition quality; and report quality.

14.3 The witness-audit assessor SHALL issue a Witness Audit Report with a recommendation to the VVB Oversight Committee (no action, corrective actions, or referral to Section 15).

14.4 Witness audits of a first-recognition applicant are governed by clauses 5.7 and 5.10(c).

14.5 The VVB Oversight Committee MAY commission unannounced spot checks on any engagement, including re-review of completed reports, independent recalculation of quantification, inspection of the First-Pass Record and its lock integrity, follow-up interviews with developers, and examination of working papers.

14.6 The VVB SHALL make complete working papers for any engagement available within five business days of a request under this Section.

15. Suspension, denial, lapse and withdrawal

15.1 The VVB Oversight Committee SHALL suspend a recognition (status SUSPENDED) where: (a) an annual review outcome is UNSATISFACTORY; (b) corrective actions are not addressed within the prescribed timeframe; (c) an undeclared material conflict of interest is discovered; (d) the VVB's clause 4.2 ISO accreditation is suspended, withdrawn or lapses; (e) the First-Pass Record regime of Section 11 is materially breached; or (f) the VVB engages in fraud, misrepresentation or conduct that compromises Programme integrity.

15.2 Suspension SHALL take effect on notification, and a suspended VVB SHALL NOT accept new engagements.

15.3 A suspended VVB SHALL NOT complete open engagements by default; on every suspension the VVB Oversight Committee SHALL decide case-by-case containment, including: freezing every pending decision that relies on the VVB's work; appointing a replacement VVB or an independent reviewer for open engagements; determining whether completed engagements require re-examination; and notifying every affected project developer (MCC-700 clause 15.4).

NOTE. This replaces MCC-400 v1.1 Article 73, under which a suspended VVB completed engagements in progress — exposing issuance to a known competence or integrity failure (audit 400-04).

15.4 No registration or issuance SHALL rely on work of a suspended VVB until the clause 15.3 containment determination is made and any directed re-examination is complete.

15.5 Suspension SHALL be lifted only by written decision of the VVB Oversight Committee on evidence that every ground is fully addressed.

15.6 The VVB Oversight Committee SHALL withdraw recognition (status WITHDRAWN) where: (a) suspension grounds are not remedied within twelve months; (b) the VVB requests voluntary withdrawal; (c) the VVB ceases to exist or loses good standing; or (d) an investigation establishes fraud or a fundamental integrity failure.

15.7 A provisional recognition not converted within its eighteen-month validity (clause 5.11), and a full recognition that expires without a timely renewal application (clause 16.2), SHALL be recorded as LAPSED.

15.8 Suspension, withdrawal and denial decisions SHALL be published on the public VVB register with their reasons, subject to MCC-100 clause 20.7 redactions, and are appealable de novo under clause 3.4; an appeal SHALL NOT of itself lift a suspension (MCC-700 clause 12.11 applies to reliance on the VVB's work).

15.9 Sanctions against a VVB as a Programme participant beyond recognition measures (warnings, conditional participation, exclusion) SHALL follow MCC-100 Section 23 and the decision types of MCC-700 Annex A rows 20–26.

16. Renewal

16.1 A recognised VVB SHALL apply for renewal at least six months before the end of its Recognition Cycle, with updated evidence of: continued clause 4.2 ISO accreditation; Lead Auditor qualifications and CPD records; insurance; and a summary of engagements completed in the cycle.

16.2 On receipt of a timely renewal application, the registry status SHALL be RENEWAL_IN_PROGRESS and the existing recognition SHALL continue in force until the renewal decision; absent a timely application, recognition SHALL lapse at expiry (status LAPSED).

16.3 The renewal assessment SHALL include a desk review of the application and the full performance record, and SHALL include a witness audit where the performance history warrants it.

16.4 The VVB Oversight Committee SHALL decide renewal (full recognition, provisional recognition with conditions, or denial) and SHALL communicate the decision no later than thirty days before the current cycle expires where the application was timely.

17. Assignment and rotation

17.1 VVB assignment to engagements SHALL be managed through the registry platform, considering: scope coverage; absence of conflicts under Section 8; capacity; geographic practicability for site visits; and performance history.

17.2 No AI-generated score, ranking or confidence output SHALL determine or influence VVB assignment; assignment criteria SHALL be applied by the Programme Secretariat administratively and recorded.

17.3 The same VVB SHALL NOT perform both the validation and the first verification of the same project.

17.4 No VVB SHALL perform more than three consecutive verifications for the same project; at least the next two verifications SHALL then be performed by a different recognised VVB before the original VVB may be re-engaged.

17.5 No individual auditor SHALL serve on more than three consecutive verifications for the same project; the VVB SHALL implement documented auditor rotation.

17.6 The VVB Oversight Committee MAY direct a change of VVB at any time where independence or performance concerns arise; the direction SHALL be reasoned and is appealable under clause 3.4.

18. Fees

18.1 Programme fees for recognition (application, assessment, annual maintenance, renewal, scope extension, witness audits) SHALL be set out in the MCC Fee Schedule (the single fee instrument, adopted under MCC-700 Annex A row 33); this Standard states no fee amount. Every fee amount is reserved to the Governing Board (FD-2026-09-04 items 4 and 6); whether FD-2026-08-24 item D9, which adopted "the amounts B2–B5", already set any of them is a question the MCC Fee Schedule (1.0-draft, clauses 2.1 and 3.3) puts to the Board; the recognition fees proposed for the Fee Schedule are put to consultation. (Consultation question 4.)

18.2 Engagement fees are a commercial matter between the VVB and the project developer, subject to clauses 8.3 (no contingency) and 4.5 (independence); the VVB Oversight Committee MAY investigate any fee arrangement that appears to compromise independence.

18.3 Neither the Programme nor any VVB SHALL publish, promise or price any fee or effort reduction premised on AI outputs reducing the VVB's evidence, sampling or scrutiny; no such reduction exists under this Standard (clause 10.3).

NOTE. This removes the stayed Section 18's engagement-economics provisions (Articles 107–109 and 113–115), which published indicative AI-reduced effort, fees and compressed timelines keyed to AI confidence and to a Continuous Monitoring Engine that the Addendum as printed itself records as not operational. Engagement timelines are agreed in the engagement plan; no AI-premised timeline compression is available.

18.4 Project developers SHALL NOT be charged separately for any Programme AI output; AI systems are Programme infrastructure governed by MCC-850.

19. Records and transparency

19.1 The VVB SHALL maintain complete working papers for every engagement — including the First-Pass Record, the Stage 2 disposition record, the sampling plan and all evidence relied on — and SHALL retain them in accordance with the canonical MCC Record Retention Schedule; until that Schedule is in force, no engagement record SHALL be destroyed.

NOTE. This replaces the seven-year local retention period of MCC-400 v1.1 Article 71, which conflicted with ten- and twenty-year requirements elsewhere in the suite (audit 400-08; SYS-11, as corrected by Phase 0: the divergence spanned 7, 10 and 20 years).

19.2 The VVB SHALL make working papers available to the Programme within five business days of a request under Section 14 or by the VVB Oversight Committee.

19.3 The public VVB register SHALL display, for every applicant and VVB: the current vvb_accreditation_status value, the recognition scope, the recognition and expiry dates, annual review outcomes, and any suspension, withdrawal or denial with reasons (subject to clause 15.8 redactions).

19.4 Every status assertion concerning a VVB in any Programme publication SHALL link to the underlying decision record in the Evidence Register (MCC-700 clause 21.6).

20. Use of AI systems by VVBs

20.1 A VVB SHALL NOT use any AI system — the Programme's or its own — to form, substitute for or determine any validation or verification conclusion; AI use by a VVB is permissible only as an assistive tool within Stage 2 or for non-judgemental administrative tasks, consistent with MCC-100 Section 22 and MCC-850.

20.2 A VVB deploying any AI tool of its own in an engagement SHALL disclose the tool, its purpose and its limitations in the engagement plan, and SHALL NOT apply it to Stage 1 in any way that imports third-party or model-generated assessments of the project into the blind first pass.

20.3 Each Lead Auditor SHALL complete the Programme's AI-workflow training module (covering the Section 11 two-stage workflow, the limitations of the Programme's AI systems, and the documentation duties of this Standard) before leading any engagement; completion counts toward clause 7.6 CPD.

NOTE. This replaces the stayed Section 18's "Layer Familiarisation Module" (Articles 116–118), reoriented from familiarisation with AI reliance to training in the blind-first-pass discipline. The module's content, publication and governance are owned by this Standard; its treatment of the Programme's AI systems SHALL conform to MCC-850 (in particular its Sections 11 and 17), and its AI-related content SHALL be reviewed on each material model change approved under MCC-700 Annex A row 34.

21. Transitional provisions — the first-recognition path

21.1 Factual basis. At the date of this draft, no VVB is recognised or accredited under this Standard or any predecessor version, no VVB engagement has been performed under the Programme, and the VVB Oversight Committee has not been constituted (FD-2026-09-03 item D8, reasons §4; MCC-700 Section 23). Nothing in this Standard asserts otherwise. The registry holds zero VVB accreditations, zero validation and verification bodies and zero engagements, and no VVB application or engagement was initiated in reliance on MCC-400 v1.1 (Evidence Register ER-2026-001 §B5).

21.2 The entry into force of MCC-400 Addendum 1 v1.0 (Section 18) is stayed under FD-2026-09-03 item D8; nothing in this Standard revives the stayed instrument, and on this version's entry into force the stayed instrument is formally superseded and withdrawn.

21.3 The expedited provisional accreditation route of MCC-400 v1.0 Article 87 (reduced-process entry for VVBs approved under other crediting programmes during a "Pilot Phase") SHALL NOT be applied; every first recognition SHALL pass through the full Section 5 pipeline, with other-programme approvals treated as supporting evidence only (clause 4.4).

21.4 Until at least one project reaches a lifecycle state requiring an engagement, the clause 5.7 witness audit SHALL be conducted as a simulated engagement on Programme-provided case materials, and full recognition SHALL remain conditional on the witnessed live engagement of clause 5.10(c).

21.5 During the transitional period of MCC-700 Section 23, the founder exercises the VVB Oversight Committee's functions under clause 3.5; the founder SHALL NOT grant any recognition unless every requirement of Sections 4 and 5 is met and evidenced, and every such decision SHALL be logged for ratification.

21.6 No engagement SHALL be assigned for a project whose methodology status in the Methodology Status Register does not permit the corresponding lifecycle stage, and no engagement SHALL be represented as pending or expected while none is assigned.

21.7 The VVB advisory panel of MCC-400 v1.0 Article 89 (tied to a superseded "Alpha Phase" calendar) is not carried forward; consultation with VVBs on amendments to this Standard follows clause 22.4 and MCC-001 clause 12.3.

21.8 Every point listed under Consultation questions in this Standard SHALL be resolved, and its resolution recorded in the Evidence Register or decision register, before this Standard may carry any status other than DRAFT — FOR CONSULTATION.

22. Entry into force

22.1 This Standard (MCC-400 version 2.0) SHALL enter into force upon approval under the decision type of MCC-700 Annex A row 2 applied at Tier 3 (per MCC-001 clause 12.3) — during the transitional period, by Founder Decision logged and tabled for ratification — on a stated date, following the public consultation on this draft.

22.2 This draft is published with status DRAFT — FOR CONSULTATION and confers no rights and imposes no obligations until entry into force.

22.3 On entry into force, MCC-400 v1.1 (with its v1.0 base text) and the stayed MCC-400 Addendum 1 v1.0 SHALL be formally superseded and archived as uncontrolled historical records with superseded watermarks and their printed identities noted.

22.4 Amendments to this Standard SHALL follow: a written proposal; a public consultation of no less than the MCC-001 clause 12.3 Tier 3 minimum notice period; a Standards Committee review and reasoned recommendation; and approval under MCC-700 Annex A; every amendment SHALL be published as a changelog entry and a clean consolidated text stating the instrument that creates the resulting version number.

22.5 Unless the approving decision states otherwise for cause recorded with reasons, the effective date of an amendment SHALL be no earlier than ninety days after approval, to allow recognised VVBs time to adjust; where no VVB is recognised, the approving body MAY set a shorter period, stating that fact.

---

Annex A — Recognition status model (normative)

A-1 This Annex states the semantics this Standard attaches to each value of the registry platform's vvb_accreditation_status enumeration. The platform SHALL implement only these statuses and transitions for VVBs; every transition SHALL be recorded with its decision reference.

GENERATED CONTENT. Status values are quoted verbatim from the platform enumeration (pipeline: APPLICATION_SUBMITTED → ASSESSOR_ASSIGNED → DESK_REVIEW → COMPETENCE_ASSESSMENT → WITNESS_AUDIT → PROVISIONAL → FULLY_ACCREDITED; non-pipeline: SUSPENDED, RENEWAL_IN_PROGRESS, DENIED, LAPSED, WITHDRAWN). The semantics column is fixed by this Standard. The implemented enumerations and transitions are those in the platform schema and the workflow transition guard; the schema drift audit reports zero column drift and zero enum drift as at 3 September 2026 (Evidence Register ER-2026-001 §A3).

Status	Meaning under this Standard	Entered from	Governing clauses
APPLICATION_SUBMITTED	Complete application received and acknowledged	(new applicant)	5.2, 5.3
ASSESSOR_ASSIGNED	Accreditation assessor assigned by the VVB Oversight Committee	APPLICATION_SUBMITTED	5.3, 3.3
DESK_REVIEW	Desk review in progress or completed with a proceed recommendation	ASSESSOR_ASSIGNED	5.4
COMPETENCE_ASSESSMENT	Lead Auditor examinations, case studies (including simulated blind first pass) and interviews in progress	DESK_REVIEW	5.5, 5.6
WITNESS_AUDIT	Witnessed engagement (live, or simulated per clause 21.4) in progress or under assessment	COMPETENCE_ASSESSMENT	5.7, 14.2
PROVISIONAL	Provisional recognition granted, with conditions and enhanced oversight; valid at most 18 months	WITNESS_AUDIT	5.8–5.10
FULLY_ACCREDITED	Full recognition for the stated scope; 5-year Recognition Cycle	PROVISIONAL; RENEWAL_IN_PROGRESS (renewal granted)	5.11, 5.12, 16.4
RENEWAL_IN_PROGRESS	Timely renewal application under assessment; recognition continues in force	FULLY_ACCREDITED	16.1, 16.2
SUSPENDED	Recognition suspended; no new engagements; containment per clause 15.3	PROVISIONAL; FULLY_ACCREDITED; RENEWAL_IN_PROGRESS	15.1–15.5
DENIED	Application or renewal refused with reasons; appealable de novo	any pipeline stage; RENEWAL_IN_PROGRESS	5.13, 16.4, 3.4
LAPSED	Provisional validity expired unconverted, or cycle expired without timely renewal	PROVISIONAL; FULLY_ACCREDITED	5.11, 15.7, 16.2
WITHDRAWN	Recognition withdrawn (voluntary or directed); permanent removal from the register	SUSPENDED; PROVISIONAL; FULLY_ACCREDITED	15.6

A-2 A LAPSED or WITHDRAWN VVB that seeks recognition again SHALL reapply as a new applicant. Whether DENIED may be entered directly from any pipeline stage, as the table above provides, or only from a completed assessment is to be confirmed against the platform's configured transitions rather than assumed. (Consultation question 5.)

Annex B — Scope-of-recognition families (normative)

B-1 The methodology-family values for recognition scope are the canonical families below; a recognition SHALL state, per family, the service types and statement types covered.

GENERATED CONTENT. The family codes, names, activities and instruments are generated verbatim from the canonical Family–Methodology–Instrument Matrix (control table 2, FD-2026-09-03 item D2). The specialist-competence column is this Standard's consultation proposal populating the matrix's open "VVB scope" column (the matrix notes that column as still to be populated); it is proposed, not decided. (Consultation question 6.) This table supersedes the MCC-400 v1.1 Article 32 scope table, whose family taxonomy (F01 mangrove restoration … F05 kelp) conflicted with the canonical map (SYS-02).

Family	Canonical name	Instruments in scope	Specialist competence required (proposed)
F01	Coastal blue-carbon removals/restoration	MCC-CC (+ optional MCC-CB label)	Blue-carbon science; coastal wetland ecology and restoration; marine sediment carbon; remote sensing; GHG quantification
F02	Coastal blue-carbon avoided loss/protection	MCC-CC (where approved avoided-loss method exists)	Blue-carbon science; land/sea-use change and driver analysis; baseline and leakage assessment; remote sensing
F03	Sustainable fisheries and fishing-gear interventions	Split: MCC-CC (LCA/GHG leg) and MCC-MOU (marine outcome)	Fisheries science; fishing-gear technology; life-cycle assessment (for GHG statements); chain-of-custody and supply-chain evidence
F04	Marine pollution prevention/removal	MCC-MOU by default; MCC-CC only under separate approved GHG methodology	Marine pollution science; waste-management systems; mass-balance and chain-of-custody verification
F05	Marine habitat and biodiversity conservation	MCC-MOU (+ co-benefit statements)	Marine ecology; MPA governance; biodiversity outcome metrics; coral, oyster or kelp biology as applicable

B-2 A VVB recognised for a family SHALL be recognised for GHG statements in that family only where its team competence covers the family's GHG quantification basis (including LCA competence for F03 GHG statements, clause 7.5).

Annex C — Two-stage engagement workflow (informative)

NOTE (non-normative). This Annex summarises Sections 10 and 11 for operational reference; the binding requirements are the clauses cited.

Step	Actor	Action	Platform control	Record
1	Platform	Assignment within scope; COI declaration accepted	Engagement cannot open without accepted COI declaration (8.4)	Assignment + COI record
2	VVB	Engagement plan filed (team, competence mapping, timeline, site-visit position)	AI outputs withheld from all VVB users (11.3)	Engagement plan (9.2)
3	VVB	Stage 1 — blind first pass: risk/materiality sampling plan set; evidence gathered; findings and draft conclusions formed — no AI output seen (11.2)	AI sidebar locked; access logged (11.3)	First-Pass Record locked: immutable, time-stamped (11.4)
4	Platform	Releases AI findings only after lock	Recommendation fields and numeric confidence never disclosed (11.6)	Release log
5	VVB	Stage 2 — AI discrepancy review: every difference dispositioned in writing; revisions only on the VVB's own additional evidence; procedures may only be added, never reduced (11.7–11.8, 10.6)	Disposition record required before report submission	Disposition record (11.9)
6	VVB	Internal peer review with access to First-Pass Record and dispositions (9.9)	—	Peer-review statement
7	VVB	Report with separately identifiable conclusions per statement type (12.3)	Publication with 12.5 redactions	Public report
8	Programme	First-pass and disposition records feed AI calibration one-way (11.12–11.13)	No calibration output alters any engagement requirement	Calibration input log

---

End of MCC-400 v2.0-draft. DRAFT — FOR CONSULTATION. This document confers no rights and imposes no obligations until entry into force under clause 22.1.