MCC-700 — Governance and Appeals

Document control

Field	Value
Document code	MCC-700
Title	Governance and Appeals
Version	4.0-draft
Status	DRAFT — FOR CONSULTATION
Tier	Tier 2 (Document Hierarchy & Precedence Register, per FD-2026-09-03 item D5)
Date of this draft	3 September 2026
Effective date	None. This document is not in force. It takes effect only on approval under clause 24.1.
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). 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	MCC-700 Governance and Appeals v3.1 (cover) / v3.0 DRAFT (running headers), reclassified by FD-2026-09-03 item D5; the document register records v3.1 as in force (FD-2026-08-24 item D11) until this version is adopted, when its withdrawal as a controlled copy is executed (FD-2026-09-07 item A8: scheduled, not executed)
Language convention	British English; RFC-style normative verbs (SHALL/MUST = mandatory; SHOULD = recommended, deviation to be documented; MAY = optional)
Classification	Public — consultation draft
Consultation period	60 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)

Changelog (summary):

Version	Date	Change	Instrument
2.0	Not in the programme record	Prior framework referenced by v3.1 clause 18.2	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).
3.0 / 3.1	March 2026	Draft framework "For Foundational Review"; its effective-date placeholder was never completed. The document register records v3.1 as in force (FD-2026-08-24 item D11)	None evidenced
4.0-draft	3 September 2026	Full rewrite against the independent audit of 3 September 2026 and Founder Decisions FD-2026-09-03 D1–D8: canonical governance architecture (the Legal Entity plus seven governance bodies); structural separation of first-instance decisions, independent review, appeals and complaints; single Delegated Authority Matrix (Annex A); single project lifecycle state machine (Annex B); voluntary-first Article 6 posture; Transitional Provisions for the founder-governed period; removal of the operational phase calendar and of unevidenced approval claims	FD-2026-09-03 items D1–D8

Document-control rules for publication (normative for the published edition of this document):

• DC-1 The cover, every running header, every running footer, the file name, embedded metadata and the changelog SHALL display the identical document code, version, status and date.
• DC-2 Every page footer SHALL display "Page X of Y" with both numbers populated.
• DC-3 The published edition SHALL contain a real, populated table of contents to heading level 3, hyperlinked in PDF; a placeholder table of contents SHALL NOT be published.
• DC-4 No placeholder text (including bracketed dates or "[to be inserted]") SHALL appear in an edition published with any status other than DRAFT; in a DRAFT edition, every point the Programme has not decided, or on which it proposes a rule for comment, SHALL be listed under Consultation questions and marked in the text (FD-2026-10-01 item 4).
• DC-5 Before any publication, this document SHALL pass the acceptance tests in Section 9 of the independent audit dated 3 September 2026, and a FAIL on any of QA-01 to QA-16 or QA-19 SHALL block any status other than DRAFT / FOR CONSULTATION / PILOT.

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 2.2 — The Programme's legal entity. Proposed: the Programme's operating entity has not yet been incorporated, and the administration proposes that it be incorporated as a Norwegian aksjeselskap (AS). No name is proposed: "Marine Conservation Credits Limited", printed in MCC-700 v3.1 clause 3.1, has no corporate particulars in the programme record and is not carried forward. Basis: FD-2026-10-01 item 3 and Schedule 1 (C1); FDP-2026-001 C1. Decided by: the Governing Board on adoption of the suite; the entity's name and jurisdiction are reserved to it (FD-2026-09-04 item 6). Comments are invited on the proposed form and jurisdiction, and on the provisions of this Standard that depend on incorporation (clauses 2.1–2.4, 4.4, 6.6 and 12.10).

2. Clause 3.2.6 — Conflict-of-interest look-back period. Proposed: 36 months. Basis: FD-2026-10-01 Schedule 1 (Q7); FDP-2026-001 Q7. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether 36 months, rather than the 24 months this draft also offered, is proportionate.

3. Clauses 4.5.5, 4.6.5, 4.7.3, 4.8.4, 4.9.3, 4.10.4 and 4.11.4 — Transitional appointments schedule, terms and remuneration. Proposed: the transitional appointments schedule at clause 4.5.5 — until a body is constituted, the Governing Board exercises its functions (with external technical reviewers for Standards Committee matters and an external safeguards reviewer for Category A projects), and each body is constituted on the trigger shown; the Programme Administrator performs the Secretariat's functions until it is staffed; and the Independent Appeals Panel is external from the start (question 12). Appointments are for three years, staggered. Remuneration is nil during the transitional period and is disclosed as nil. No number of seats, composition or candidate is proposed for any body, because none is in the programme record. Basis: FD-2026-10-01 Schedule 1 (C5); FDP-2026-001 C5. Decided by: the Governing Board on adoption of the suite: appointments are its decision (Annex A row 17), and constituting the Standards Committee and appointing an external member of the appeals panel are reserved to it by name (FD-2026-09-04 item 6). Comments are invited on the schedule and its triggers, and on its placing the transitional exercise of each body's functions with the Governing Board, whereas clauses 1.5 and 23.2, the Status clauses of Section 4 and Annex A note A-1 of this draft place it with the founder.

4. Clauses 4.12 and 19.2 and Annex A row 14 — Institutional home of SD-label certification. Proposed: no proposal is made for the deciding body — MCC-700 v3.1 assigned certification to an "SD Expert Panel" that is not one of the seven governance bodies, and neither this draft nor FD-2026-10-01 Schedule 1 proposes a successor. The interim rule of clause 19.2 is carried as drafted; it refers to the body designated in Annex A row 14, and row 14 designates none. Basis: an open decision of this draft, put to consultation with its interim rule (FDP-2026-001 Part 3; FD-2026-10-01 item 4). Decided by: the Governing Board on adoption of the suite. Comments are invited on which of the seven governance bodies should take SD-label certification decisions.

5. Clause 6.1 — Nominations while the Governing Board has two members. Proposed: the founder owns the nominations process, disclosed as such, until the Governing Board has more than two members; thereafter the Independent Governing Board. Basis: FD-2026-10-01 Schedule 1 (Q4); FDP-2026-001 Q4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the founder should hold this role in that period.

6. Clauses 6.3 and 13.3 — Independent recipient of whistleblowing reports; independent complaints function. Proposed: for both, the external appointee of clause 23.7 (question 12) or external counsel, and never the founder. No one has been appointed to either. Basis: FD-2026-10-01 Schedule 1 (Q5, Q6); FDP-2026-001 Q5 and Q6. Decided by: the Governing Board on adoption of the suite; appointing the external appointee is reserved to it (FD-2026-09-04 item 6). Comments are invited on whether one external person should hold both functions.

7. Clause 6.7 and Annex A note A-4 — Delegated financial authority. Proposed: EUR 25,000 per commitment and EUR 100,000 a year in aggregate; nothing touching the buffer pool is delegated. Basis: FD-2026-10-01 Schedule 1 (Q8); FDP-2026-001 Q8. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether these limits are proportionate.

8. Clause 7.5 — Chair's casting vote. Proposed: none; a tied vote fails for every decision type. Basis: FD-2026-10-01 Schedule 1 (Q1); FDP-2026-001 Q1; an open decision of this draft, shared with MCC-001 clause 9.8.5. Decided by: the Governing Board on adoption of the suite. Comments are invited on the alternative this draft left open: a casting vote for decision types other than constitutional amendments, methodology approvals and appeals, recorded per decision type in Annex A.

9. Clause 9.5 and Annex B notes B-2 and B-4 — ON_HOLD state. Proposed: no ON_HOLD state; a project whose methodology loses eligible status is held at its current state with a dated hold annotation (clause 9.5). Basis: an open decision of this draft, put to consultation with its interim rule (FDP-2026-001 Part 3; FD-2026-10-01 item 4). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether a distinct ON_HOLD state should be added to the platform state machine instead.

10. Clause 10.3 and Annex A row 7 — First-instance body for project registration. Proposed: the Programme Secretariat decides and the Registry Oversight Committee is notified; the designation is revisited at 25 registered projects. Basis: FD-2026-10-01 Schedule 1 (C2, row 7; Q3); FDP-2026-001 C2, option (a). Decided by: the Governing Board on adoption of the suite. Comments are invited on this designation, including how it sits with clause 4.11.2, and on the alternative that the Registry Oversight Committee decides on the Secretariat's recommendation (FDP-2026-001 C2, option (b)).

11. Clause 12.10 — Governing law, arbitral rules and seat. Proposed: Norwegian law, the UNCITRAL rules and a seat in London, for the participant agreements. The proposal is subject to the legal review clause 12.10 requires before adoption, and none has been obtained (Evidence Register ER-2026-001 §B5); governing law depends on the incorporation of the Programme's entity (question 1). Basis: FD-2026-10-01 item 3 and Schedule 1 (Q9); FDP-2026-001 Q9. Decided by: the Governing Board on adoption of the suite. Comments are invited on the proposal and on how the differing seat provisions of the three participant agreements should be reconciled.

12. Clause 23.7 — Interim external appointee for appeals. Proposed: one external appointee on a roster basis, paid per matter, appointed before the first appeal is heard. No one has been appointed. Basis: FD-2026-10-01 Schedule 1 (Q2, C5); FDP-2026-001 Q2. Decided by: the Governing Board on adoption of the suite; appointing an external member of the appeals panel is reserved to it (FD-2026-09-04 item 6). Comments are invited on whether one appointee is sufficient and on the basis of payment.

13. Annex A — The Delegated Authority Matrix as a whole. Proposed: the Matrix as drafted, as one proposal, with the choices set out in questions 10, 14 and 15. Basis: FD-2026-10-01 Schedule 1 (C2); FDP-2026-001 C2. Decided by: the Governing Board on adoption of the suite. Comments are invited on any row, including the owners of rows 20–38 and the maker-checker approval confirmed for rows 24 and 28–30.

14. Annex A note A-2 — Voting thresholds. Proposed: two-thirds for constitutional amendments (subject to MCC-001, which prevails), methodology approvals and appeal decisions; a simple majority for every other decision type, except where the Matrix requires maker-checker (two-person) approval. Basis: FD-2026-10-01 Schedule 1 (C2); FDP-2026-001 C2. FD-2026-08-24 item 1 (D11) recorded two-thirds of votes cast and a quorum of 50 % + 1 for MCC-700. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether each threshold suits its decision type.

15. Annex A row 13 — Project revocation. Proposed: the Independent Governing Board decides, rather than the first-instance registration body of row 7, because revocation is terminal. Basis: FD-2026-10-01 Schedule 1 (C2, row 13); FDP-2026-001 C2. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether revocation should instead rest with the body that decides registration.

16. Annex A row 15 — Owner of claims and marketing approval. Proposed: no proposal is made — this draft designates no owner, and MCC-600, against which approvals are to be given, is not in force. The threshold follows note A-2. Basis: FD-2026-10-01 item 4 (a point asked without a proposal); FD-2026-10-01 Schedule 1 makes none. Decided by: the Governing Board on adoption of the suite. Comments are invited on which body should give these approvals.

17. Annex B note B-3 and transition T5 — Service levels. Proposed: the SLA values in the Annex B table as drafted, including the 30-calendar-day stakeholder consultation at T5 (open point OD-7, which MCC-100 clause 13.8 cites without restating a number). Basis: drafting proposals of this draft, put to consultation as open decisions (FDP-2026-001 Part 3; FD-2026-10-01 item 4). Decided by: the Governing Board on adoption of the suite. Comments are invited on each value, and on any value that does not align with MCC-100.

18. Annex B transition T9 — Suspension of a project on other compliance grounds. Proposed: no proposal is made — Annex A designates no owner for suspending a project on compliance grounds other than safeguards or registry integrity (rows 12a–13 cover safeguards suspension, its confirmation and revocation), and FD-2026-10-01 Schedule 1 makes none. Basis: FD-2026-10-01 item 4 (a point asked without a proposal). Decided by: the Governing Board on adoption of the suite. Comments are invited on which body should take that decision.

Table of contents

1. Purpose, scope and application
2. Legal identity of the programme operator
3. Definitions and interpretation
4. Governance architecture
5. Independence, conflicts of interest and role separation
6. Governance integrity controls
7. Decision-making and voting procedures
8. Delegated authority
9. Project lifecycle governance
10. First-instance decisions
11. Independent review
12. Appeals
13. Complaints against MCC
14. Interface with the safeguards grievance mechanism
15. Validation and verification body oversight
16. Registry, issuance and buffer pool governance
17. Host country and Article 6 governance
18. Methodology governance
19. Sustainable development certification governance
20. Role of AI systems in governance decisions
21. Recordkeeping, transparency and retention
22. Amendments
23. Transitional provisions
24. Entry into force Annex A — Delegated Authority Matrix (normative) Annex B — Project Lifecycle State Machine (normative)

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1. Purpose, scope and application

1.1 This Governance and Appeals Standard (MCC-700) SHALL establish the governance architecture, decision-making authority, independence controls, and the review, appeals and complaints procedures of the Marine Conservation Credits (MCC) Programme.

1.2 This Standard SHALL apply to every governance decision taken under the MCC Programme, including project lifecycle decisions, credit issuance and retirement, methodology approval, validation and verification body (VVB) recognition, safeguards enforcement, buffer pool actions, and appointments to governance bodies.

1.3 This Standard is a Tier 2 instrument under the Document Hierarchy & Precedence Register; precedence is governed by MCC-001 Section 2.

1.4 Where this Standard refers to another MCC document, the reference SHALL be read against the Document Hierarchy & Precedence Register; a requirement of this Standard that depends on a referenced document, form or tool 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: MCC-600 (Claims Code), drafted as v1.0-draft and put to consultation with this suite (claims are governed meanwhile by the Claims Policy v1.1, adopted under FD-2026-08-24 and recorded in the document register as in force); the Record Retention Schedule (MCC-810) and the Information Security Standard (MCC-820), each put to consultation with this suite; MCC-PILOT (Pilot Project Framework); and the operational procedures formerly cited as MCC-OPS. The Definitions Register is in force (clause 3.1). The dependent requirements are identified where they occur and are deferred under clause 1.4.

1.5 During the transitional period defined in Section 23, every reference in this Standard to a governance body that has not yet been constituted SHALL be read as a reference to the founder exercising that body's functions under the Transitional Provisions.

2. Legal identity of the programme operator

2.1 The MCC Programme SHALL be operated by one identified legal entity, whose jurisdiction of incorporation, company number, registered office and beneficial ownership SHALL be publicly disclosed before this Standard is approved.

2.2 The Programme's operating entity has not yet been incorporated (founder's statement of 1 October 2026, recorded in FD-2026-10-01 item 3), so no certificate of incorporation, jurisdiction, company number, registered office or beneficial ownership exists to disclose. The administration proposes a Norwegian aksjeselskap (AS); the entity's name and jurisdiction are reserved to the Governing Board (FD-2026-09-04 item 6). The name "Marine Conservation Credits Limited" printed in MCC-700 v3.1 clause 3.1 has no corporate particulars in the programme record and is not carried forward. The Programme's name is Marine Conservation Credits ("MCC"); no other expansion of "MCC" printed in the prior corpus is a name of the Programme (clause 2.3). (Consultation question 1.)

2.3 Once the particulars in clause 2.2 are evidenced, the exact registered legal name SHALL be used in every MCC document; no variant expansion of "MCC" SHALL appear in any controlled document.

2.4 The legal entity SHALL own the Programme's contracts, intellectual property, liabilities, finances and registry relationships, and SHALL act in Programme matters only through the governance architecture in Section 4.

3. Definitions and interpretation

3.1 Defined terms in this Standard SHALL carry the meanings given 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 the Definitions Register does not define a term, the canonical meanings in Appendix A of the independent audit dated 3 September 2026, as adopted through FD-2026-09-03, SHALL apply.

3.2 In this Standard:

3.2.1 "First-instance decision" means the initial determination of a matter by the body or function designated in Annex A, before any review or appeal.

3.2.2 "Independent review" means reconsideration of a first-instance decision by persons who took no part in it, within the same institutional level, under Section 11.

3.2.3 "Appeal" means a challenge to a decision brought before the Independent Appeals Panel under Section 12.

3.2.4 "Complaint" means an allegation concerning the conduct, service or integrity of MCC itself or of a governance body, handled under Section 13; a complaint is not an appeal.

3.2.5 "Grievance" means a concern raised by a project-affected person or community under the grievance mechanism of the Environmental & Social Safeguards Policy, handled at project and programme level under that policy and interfacing with this Standard under Section 14.

3.2.6 "Independent member" means a member who has no current or recent (within 36 months) commercial, employment, contractual or financial relationship with MCC, any project developer, VVB, credit buyer or intermediary active in the Programme, and no other material interest defined in clause 5.5. (Consultation question 2.)

3.2.7 "Non-commercial chair" means a chair who is an independent member and derives no income from the sale, brokerage or development of carbon or marine outcome credits.

3.3 The normative verbs SHALL/MUST, SHOULD and MAY have the meanings stated in the document control block; each numbered clause of this Standard states one testable requirement.

4. Governance architecture

4.1 The governance architecture of the MCC Programme SHALL comprise the Legal Entity (Section 2), which exercises no governance decision authority, and exactly the following seven governance bodies, with the mandates and minimum independence controls stated in this Section; no body other than those seven SHALL exercise governance authority.

NOTE — The table in FD-2026-09-03 item D4 lists the Legal Entity alongside the seven governance bodies; its Legal-Entity row carries an ownership mandate, not a decision power. Clause 4.1 is a conforming clarification of that table against MCC-001 clauses 9.1.1–9.1.2; no FD-2026-09-03 rule is varied.

4.2 Identical legal names for these bodies SHALL be used in every MCC document; the superseded names used in the prior corpus (including "Board", "Governance Board", "MCC Board of Directors", "Methodology Review Committee", "Methodology Standards Panel", "Review Authority", "Review and Appeals Authority", "Registry Oversight Authority", "Registry Authority", "Safeguards Panel", "Programme Administrator" in a decision-making sense) SHALL NOT be used.

4.3 First-instance decisions, independent review, appeals and complaints SHALL be structurally separated: no person SHALL take part in more than one of these stages on the same matter.

4.4 Legal Entity (not a governance body).

4.4.1 Mandate: the Legal Entity owns contracts, programme IP, liability, finances and registry relationships (Section 2); it exercises no governance decision authority and acts in Programme matters only through the seven governance bodies (clause 2.4).

4.4.2 Minimum control: jurisdiction, company number, registered office and beneficial ownership SHALL be disclosed. The entity has not yet been incorporated, so no corporate particulars exist to disclose (clause 2.2; FD-2026-10-01 item 3); the obligation binds from the date of incorporation.

4.5 Independent Governing Board.

4.5.1 Mandate: strategy, budget, risk appetite, appointments, and final approval of programme rules.

4.5.2 The Independent Governing Board SHALL at all times have a majority of independent members.

4.5.3 The chair of the Independent Governing Board SHALL be a non-commercial chair.

4.5.4 Quorum for every Board decision SHALL be determined under clause 5.7 (recalculated after recusals).

4.5.5 Composition, seats, appointment terms and remuneration: no number of seats and no candidate for a seat is proposed, and none is assumed. The eleven-seat constituency model of MCC-700 v3.1 clause 4.1.2, under which commercial constituencies could outnumber the two independent experts, is superseded and SHALL NOT be reproduced. The administration proposes three-year terms, staggered, for appointments to the Independent Governing Board and to every body in this Section; remuneration of members of nil during the transitional period, disclosed as nil; and the following transitional appointments schedule, under which each body's functions would be exercised as shown until the body is constituted on its trigger. (Consultation question 3.)

Body	Until constituted, functions exercised by	Constituted when
Standards Committee (cl. 4.6)	the Governing Board, with external technical reviewers named for each matter	the first methodology reaches an approval decision
VVB Oversight Committee (cl. 4.7)	the Governing Board	the first VVB application is received
Registry Oversight Committee (cl. 4.8)	the Governing Board	the first issuance request is received
Safeguards & Rights Panel (cl. 4.9)	the Governing Board, with an external safeguards reviewer for Category A projects	the first project is screened as Category A
Independent Appeals Panel (cl. 4.10)	no transitional exercise by the Governing Board: the Panel is external from the start, and until it is constituted clause 23.7 applies	the first appeal is filed
Programme Secretariat (cl. 4.11)	the Programme Administrator	it is staffed

In this schedule, "the Governing Board" means the Governing Board constituted on 26 August 2026 (GB-2026-001, recorded in the decision register as attested by the founder; no executed copy has been filed).

4.5.6 Status: not yet constituted; its functions are exercised by the founder under Section 23 until constituted.

4.6 Standards Committee.

4.6.1 Mandate: recommends programme standards and methodology approvals to the Independent Governing Board or to the delegate recorded in Annex A (none is recorded at this draft).

4.6.2 The Standards Committee SHALL at all times have an independent technical majority.

4.6.3 Every Standards Committee recommendation on a standard or methodology SHALL follow a public consultation and SHALL be issued with written reasons.

4.6.4 The Standards Committee MAY convene technical working groups (including per-methodology working groups); a working group SHALL have advisory status only and SHALL report to the Standards Committee.

4.6.5 Composition, seats and terms: no composition or number of seats is proposed; terms and a transitional arrangement are proposed in the transitional appointments schedule at clause 4.5.5. (Consultation question 3.)

4.6.6 Status: not yet constituted; its functions are exercised by the founder under Section 23 until constituted.

4.7 VVB Oversight Committee.

4.7.1 Mandate: approves VVB programme recognition and scope, monitors VVB performance, and imposes VVB sanctions.

4.7.2 The VVB Oversight Committee SHALL be operationally separate from project approval functions and from any commercial team.

4.7.3 Composition, seats and terms: no composition or number of seats is proposed; terms and a transitional arrangement are proposed in the transitional appointments schedule at clause 4.5.5. (Consultation question 3.)

4.7.4 Status: not yet constituted; its functions are exercised by the founder under Section 23 until constituted.

4.8 Registry Oversight Committee.

4.8.1 Mandate: controls issuance, registry risk, reconciliation and registry security.

4.8.2 Every issuance and every registry action within the Registry Oversight Committee's mandate SHALL be executed under maker-checker approval (no single person SHALL both initiate and approve the same action).

4.8.3 Registry controls SHALL be subject to independent audit at least annually.

4.8.4 Composition, seats and terms: no composition or number of seats is proposed; terms and a transitional arrangement are proposed in the transitional appointments schedule at clause 4.5.5. (Consultation question 3.)

4.8.5 Status: not yet constituted; its functions are exercised by the founder under Section 23 until constituted.

4.9 Safeguards & Rights Panel.

4.9.1 Mandate: high-risk environmental and social review, remedy oversight, and grievance oversight.

4.9.2 The Safeguards & Rights Panel SHALL include members with human-rights expertise and members with marine-livelihood expertise.

4.9.3 Composition, seats and terms: no composition or number of seats is proposed; terms and a transitional arrangement are proposed in the transitional appointments schedule at clause 4.5.5. (Consultation question 3.)

4.9.4 Status: not yet constituted; its functions are exercised by the founder under Section 23 until constituted.

4.10 Independent Appeals Panel.

4.10.1 Mandate: hears appeals under Section 12, de novo or under the defined review standard stated in clause 12.6.

4.10.2 No member of the Independent Appeals Panel SHALL sit on an appeal concerning a decision in which that member was involved at first instance or on independent review.

4.10.3 The Independent Appeals Panel MAY draw members from an external roster of qualified persons.

4.10.4 Composition, roster and terms: no composition or roster is proposed and no member has been appointed; terms are proposed in the transitional appointments schedule at clause 4.5.5, under which the Panel is external from the start and is constituted when the first appeal is filed, clause 23.7 applying until then. (Consultation question 3.)

4.10.5 Status: not yet constituted; during the transitional period appeals are handled as provided in clause 23.7 (the founder SHALL NOT decide appeals against decisions the founder took at first instance).

4.11 Programme Secretariat.

4.11.1 Mandate: administration only, within the delegated authority granted by Annex A.

4.11.2 The Programme Secretariat SHALL NOT approve its own technical work and SHALL NOT override any committee or panel.

4.11.3 The Programme Secretariat SHALL operate a compliance monitoring function that monitors ongoing project compliance and safeguards performance and escalates findings to the competent body under Annex A; the compliance monitoring function SHALL have no decision authority.

4.11.4 Staffing: the Secretariat is not staffed and no staffing is proposed; under the transitional appointments schedule proposed at clause 4.5.5, the Programme Administrator would perform its functions until it is staffed. (Consultation question 3.)

4.11.5 Status: not yet constituted as a staffed function; its functions are exercised by the founder under Section 23 until constituted.

4.12 Advisory input on sustainable development certification is governed by Section 19; the "Sustainable Development Expert Panel" of MCC-700 v3.1 is not one of the seven governance bodies and is discontinued as a body; the institutional home of SD-label certification is not decided (clause 19.2). (Consultation question 4.)

5. Independence, conflicts of interest and role separation

5.1 The same person SHALL NOT hold a standard-setting role and a programme-administration role (the stricter rule of MCC-001 prevails, per FD-2026-09-03 item D4; the permissive multiple-roles rule of MCC-700 v3.1 clause 3.4 is abolished).

5.2 The same person SHALL NOT take part in a first-instance decision and in an appeal or independent review of the same matter.

5.3 A person with a commercial role in a project SHALL NOT hold any oversight seat in respect of that project.

5.4 Every governance body member SHALL disclose all material interests on appointment and at least annually thereafter, and immediately upon a new interest arising.

5.5 A material interest includes: financial interests (ownership, employment, contracts) in an applicant, project developer, VVB, buyer or intermediary; current or former institutional relationships with an applicant; family relationships with decision subjects; intellectual-property ownership or licensing related to a decision subject; and membership of multiple governance bodies where participation could improperly influence judgement.

5.6 A member with a conflict on a matter SHALL recuse from both deliberation and vote on that matter.

5.7 After recusals, quorum SHALL be recalculated on the members entitled to vote; a decision taken without recalculated quorum is invalid.

5.8 Each governance body SHALL maintain a Conflict of Interest Register, updated within ten business days of any change, available for inspection by the Independent Governing Board and published at least annually with lawful redactions.

5.9 MCC SHALL commission an annual independent audit of compliance with this Section and with the role-separation rules of Section 4; the audit report SHALL be filed with the Independent Governing Board and published.

6. Governance integrity controls

6.1 Nominations and fit-and-proper testing. Every candidate for a governance body seat SHALL pass a documented fit-and-proper assessment (integrity, competence, independence status, conflicts) before appointment; the assessment criteria SHALL be published. Until the Governing Board constituted on 26 August 2026 (clause 4.5.5) has more than two members, the nominations process SHALL be owned by the founder, disclosed as such; thereafter by the Independent Governing Board. (Consultation question 5.)

6.2 Removal. A member MAY be removed only for cause stated in writing (including unresolved conflict, breach of this Standard, or unfitness), by the Independent Governing Board under the threshold in Annex A, with the member heard first.

6.3 Whistleblowing. MCC SHALL operate a confidential whistleblowing channel open to staff, governance members, project participants and the public, with protection from retaliation; reports concerning the founder or the Independent Governing Board SHALL be escalated to an independent recipient, who SHALL be the external appointee of clause 23.7 or external counsel, and never the founder; no independent recipient has been appointed. (Consultation question 6.)

6.4 Anti-bribery and corruption. MCC SHALL adopt and publish an anti-bribery and corruption policy binding on all governance members, staff and contractors; breach is cause for removal under clause 6.2 and for sanctions under participant agreements.

6.5 Remuneration. The remuneration policy for governance members SHALL be approved by the Independent Governing Board and published; no member's remuneration SHALL be linked to credit issuance volumes, sales or programme revenue.

6.6 Financial oversight. The Independent Governing Board SHALL approve the annual budget, appoint an external financial auditor, and publish audited annual financial statements. No external financial auditor has been appointed (Evidence Register ER-2026-001 §B5), and the Programme's operating entity has not yet been incorporated (clause 2.2).

6.7 Delegated financial authority. Financial commitments SHALL be entered only within the delegated financial authority limits set by the Independent Governing Board and recorded in Annex A: EUR 25,000 per commitment and EUR 100,000 a year in aggregate, with nothing touching the buffer pool delegated (note A-4). (Consultation question 7.)

7. Decision-making and voting procedures

7.1 Unless Annex A specifies otherwise for a decision type, each governance body SHALL apply the default procedures in this Section.

7.2 Quorum SHALL be a majority of appointed members entitled to vote on the matter, recalculated after recusals under clause 5.7.

7.3 Each member SHALL have one vote; there SHALL be no weighted or constituency voting.

7.4 The default decision threshold SHALL be a majority of votes cast; the thresholds for specific decision types are fixed exclusively in Annex A.

7.5 A tied vote SHALL fail; the chair SHALL NOT have a casting vote. (Consultation question 8.)

7.6 Members MAY abstain; an abstention SHALL be recorded with its reason.

7.7 Every vote SHALL be recorded with voter identities, votes cast, counts and the written rationale of the decision.

7.8 Decisions SHALL be made at the lowest competent level under Annex A; escalation SHALL occur only where Annex A requires it, where bodies conflict, or where an affected party exercises review or appeal rights.

7.9 In cases of uncertainty regarding environmental, social or safeguards impacts, the deciding body SHALL apply the precautionary principle and SHALL require additional evidence or assessment before approval.

8. Delegated authority

8.1 Annex A (Delegated Authority Matrix) is normative and is the single authoritative statement of decision ownership, recommendation duty, consultation duty, voting threshold, conflict rule and appeal route for every Programme decision type.

8.2 Other than MCC-001, this Standard's clause 7.4 (default threshold) and Annex A, no MCC instrument of Tier 2 or below and no clause of this Standard SHALL state a decision threshold or decision owner; any conflicting statement in an instrument of Tier 2 or below is void to the extent of the conflict, and nothing in this clause limits MCC-001.

8.3 Annex A SHALL be generated from, and kept identical to, the Governance RACI & Delegated Authority Matrix in the canonical control tables adopted under FD-2026-09-03; a change to Annex A SHALL follow the amendment process in Section 22.

8.4 Every decision under Annex A SHALL be documented with its rationale, voting record and implementation timeline, and entered in the Programme decision register.

9. Project lifecycle governance

9.1 Annex B (Project Lifecycle State Machine) is normative and is the single authoritative statement of the project lifecycle: for every transition it states the owner, entry criteria, exit criteria, service-level agreement (SLA) and appealability.

9.2 The registry and the platform SHALL implement only the states and transitions of Annex B; no document, screen or workflow SHALL introduce a state or gate not present in Annex B.

9.3 The lifecycle states SHALL be: DRAFT, SUBMITTED, COMPLETENESS_CHECK, SAFEGUARDS_SCREENING, TECHNICAL_REVIEW, STAKEHOLDER_CONSULTATION, GOVERNANCE_REVIEW, REGISTERED, ACTIVE, SUSPENDED, COMPLETED, REJECTED, WITHDRAWN.

9.4 Gate stages SHALL be sequential in the order stated in Annex B; no gate SHALL run concurrently with another gate for the same project, and no stage SHALL be bypassed.

9.5 A project whose applicable methodology loses eligible status (including regression to CONCEPT or DRAFT under FD-2026-09-03 item D6) SHALL be held at its current state with a dated hold annotation; the hold and its reasons SHALL be notified to the developer in writing within five business days. Whether a distinct ON_HOLD state is added to the platform state machine instead of the hold annotation is open for comment (Annex B note B-4). (Consultation question 9.)

9.6 Safeguards screening categories (A, B, C) and their assessment depth SHALL be as defined in the Environmental & Social Safeguards Policy; the decision rights at the SAFEGUARDS_SCREENING and GOVERNANCE_REVIEW gates are fixed in Annex A and Annex B.

10. First-instance decisions

10.1 First-instance decisions SHALL be taken only by the body or function designated for that decision type in Annex A.

10.2 The Programme Secretariat SHALL prepare the technical review and recommendation for each first-instance project decision; it SHALL NOT take the decision except where Annex A expressly delegates a decision type to it.

10.3 The first-instance body for project registration is designated in Annex A row 7: the Programme Secretariat decides and the Registry Oversight Committee is notified, the designation to be revisited at 25 registered projects. Per FD-2026-09-03 item D4 the first-instance body MUST be distinct from the Independent Appeals Panel and from any person hearing review or appeal of the same matter. The combined "Review and Appeals Authority" of MCC-700 v3.1, which could both take first-instance decisions and hear appeals, is abolished. (Consultation question 10.)

10.4 Every first-instance decision SHALL be issued in writing with reasons, the evidence relied on, the applicable clause references, the decision-maker's identity (body and quorum), and a statement of the available review and appeal routes with their deadlines.

10.5 A first-instance decision that is adverse to an applicant, developer, VVB or affected community SHALL identify each ground of refusal separately, so that each ground can be addressed on review or appeal.

11. Independent review

11.1 A person materially affected by a first-instance decision MAY request independent review within thirty calendar days of notice of the decision.

11.2 Independent review SHALL be conducted by one or more persons of the first-instance body's institutional level who took no part in the decision under review.

11.3 The reviewer SHALL confirm, vary or remit the decision, in writing with reasons, within forty-five calendar days of receipt of the review request.

11.4 Independent review SHALL NOT be a precondition to appeal; an affected person MAY appeal directly under Section 12.

11.5 A person who conducted an independent review SHALL NOT take part in any appeal of the same matter.

12. Appeals

12.1 Any person materially affected by a decision listed as appealable in Annex A or Annex B MAY appeal to the Independent Appeals Panel; materially affected persons include project developers, VVBs, host country governments, project-affected communities, and other persons demonstrating a material interest.

12.2 An appeal SHALL be filed within thirty calendar days of notice of the decision (or, where independent review was requested, of the review outcome), stating the grounds, the supporting evidence and the remedy sought.

12.3 The Independent Appeals Panel SHALL acknowledge receipt within five business days.

12.4 The panel constituted for an appeal SHALL contain no person involved in the first-instance decision or its independent review.

12.5 Appeals against refusals of registration, safeguards clearance, issuance, or VVB recognition, and against suspensions and revocations, SHALL be heard de novo (full reconsideration of fact and rule-application on the record before the panel, with power to admit new evidence).

12.6 Appeals against methodology-approval outcomes and other standard-setting decisions SHALL be heard under a defined review standard: whether the decision was taken in conformity with the applicable procedure, on relevant considerations, and within the deciding body's authority; the panel SHALL NOT substitute its own scientific judgement but SHALL remit a non-conforming decision for fresh determination.

12.7 The Independent Appeals Panel SHALL decide each appeal in writing with reasons within sixty calendar days of the close of submissions, upholding, overturning or remitting the decision.

12.8 During an appeal, MCC MAY take interim measures strictly necessary to prevent irreparable harm or to protect Programme integrity; every interim measure SHALL be reasoned, notified to the parties, and reviewed as part of the appeal.

12.9 The decision of the Independent Appeals Panel SHALL be final within the Programme; further recourse SHALL be available only under clause 12.10.

12.10 Post-appeal dispute resolution (mediation or arbitration) SHALL be available only as provided in the applicable participant agreement; the governing law, seat, rules, language and cost allocation of such dispute resolution SHALL be fixed in the participant agreements after legal review and SHALL NOT be asserted in this Standard. The choice of governing law, arbitral seat and rules depends on the incorporation of the Programme's entity (clause 2.2) and on the legal review this clause requires, which has not been obtained; the administration's proposal is put as a consultation question. (Consultation question 11.) Three participant agreements are served — Applicant Terms v1.1, Registry Terms v1.1 and VVB Terms v1.1, which their texts record as adopted by FD-2026-08-24 items B2–B5 (a founder decision the decision register records as attested, with no executed copy filed) — and each carries a governing-law and dispute-resolution article. No legal opinion on them exists (Evidence Register ER-2026-001 §B5), and their seat provisions do not agree with each other: VVB Terms article 13 fixes London, Applicant Terms article 12.2 lets the applicant choose London, Singapore or Geneva, and governing law is printed as "TBD by Board" in texts whose change logs record it as adopted.

12.11 Filing an appeal SHALL NOT of itself suspend the decision appealed, except that no credits SHALL be issued, transferred or retired in reliance on a decision while an appeal against that decision is pending.

12.12 Appeal statistics (numbers filed, outcomes, timeliness against the deadlines in this Section) SHALL be published quarterly.

13. Complaints against MCC

13.1 MCC SHALL operate a complaints procedure, separate from appeals and from the safeguards grievance mechanism, for allegations concerning MCC's own conduct, service failures, staff or governance-body integrity, or breach of this Standard.

13.2 Complaints SHALL be receivable from any person, without fee.

13.3 Complaints SHALL be investigated by a function independent of the subject of the complaint, which SHALL be the external appointee of clause 23.7 or external counsel, and never the founder; no independent complaints function has been appointed, and during the transitional period clause 23.8 applies. (Consultation question 6.)

13.4 The complainant SHALL receive an acknowledgement within five business days and a written outcome with reasons within sixty calendar days, or a reasoned interim update where the investigation requires longer.

13.5 Complaint volumes, categories and outcomes SHALL be published at least annually in anonymised form.

14. Interface with the safeguards grievance mechanism

14.1 Grievances by project-affected persons SHALL be raised and handled under the grievance mechanism of the Environmental & Social Safeguards Policy; this Standard governs only the escalation interface in this Section.

14.2 A grievance unresolved at project level SHALL be escalatable to the Programme level, where it SHALL be investigated by the Programme Secretariat's compliance monitoring function under the oversight of the Safeguards & Rights Panel.

14.3 A grievance disclosing risk of severe or ongoing harm SHALL be triaged immediately on receipt, and the Safeguards & Rights Panel MAY order an immediate stop-work or suspension under Annex A without awaiting any cure period.

14.4 A grievance outcome that is a Programme decision (suspension, conditions, remedy determination) SHALL carry the review and appeal rights of Sections 11 and 12.

14.5 Remedy obligations arising from a grievance SHALL survive the crediting period of the project concerned.

14.6 An urgent-harm stop-work or suspension ordered under clause 14.3 SHALL be tabled for confirmation or lifting by the Independent Governing Board at its next meeting (Annex A row 12b).

15. Validation and verification body oversight

15.1 Every VVB acting in the Programme SHALL be an independent third party recognised by the VVB Oversight Committee for a defined scope under MCC-400.

15.2 VVB recognition, scope, monitoring, suspension and revocation decisions SHALL be taken by the VVB Oversight Committee under Annex A; no such decision SHALL be taken by the Programme Secretariat (this supersedes the Programme Administrator approval power of MCC-400 Article 17 and the Review Authority powers of MCC-700 v3.1 Section 5).

15.3 Competence, impartiality, insurance and accreditation requirements for VVBs SHALL be stated exclusively in MCC-400; this Standard SHALL NOT duplicate them.

NOTE — MCC-700 v3.1 clause 5.2 stated minimum professional liability insurance amounts "aligned by FD-2026-08-24, item D7". That requirement is in force in the VVB Terms v1.1 article 11.1, and this suite carries it in MCC-400 v2.0-draft clause 4.6. FD-2026-08-24 is in the programme record — served in the public document manifest and entered in the decision register — and carries items D7 (VVB insurance, USD 2m per claim / USD 5m aggregate, which MCC-400 clause 4.6 carries as USD 2 million per occurrence and USD 5 million in aggregate) and D13 (the MCC-800 article 27 serial format). The decision register records it as attested by the founder, with no executed copy filed; it was ratified as to substance by the Governing Board in GB-2026-001 item 2, which the register also records as attested (Evidence Register ER-2026-001 §B2).

15.4 On suspension of a VVB, the VVB Oversight Committee SHALL decide case-by-case containment measures, including freezing decisions that rely on the VVB's work, appointing a replacement or reviewer, and notifying affected projects; a suspended VVB SHALL NOT be permitted by default to complete open engagements.

15.5 A VVB SHALL reach its validation or verification conclusions blind to any programme AI recommendation; AI outputs MAY be used only for post-draft discrepancy and quality review, as governed by MCC-850 and MCC-400.

15.6 VVB decisions of the VVB Oversight Committee SHALL carry the review and appeal rights of Sections 11 and 12.

16. Registry, issuance and buffer pool governance

16.1 Credit issuance SHALL be approved by the Registry Oversight Committee under maker-checker control, on the basis of a verification statement from a recognised VVB and satisfaction of every Annex B entry criterion for issuance.

16.2 The Registry Oversight Committee SHALL oversee registry data integrity, security, reconciliation and audit trails under MCC-800.

16.3 The buffer pool SHALL cover only the quantified reversal / non-permanence exposure of stored carbon; it SHALL NOT be used for baseline or quantification uncertainty, leakage, safeguards risk or compliance risk (which SHALL be addressed by conservative deductions, discounting, remedy and enforcement mechanisms respectively, per the Buffer Pool Management standard as rewritten).

16.4 Buffer deduction rates SHALL be set per project under the rewritten Buffer Pool Management standard; no deduction rate stated in a superseded document SHALL be applied.

16.5 A buffer release SHALL require (a) a recommendation of the Registry Oversight Committee, (b) independent actuarial or adequacy assessment of the portfolio, and (c) approval by the Independent Governing Board; a release SHALL NOT be made solely because a project or vintage reaches a date.

16.6 Buffer cancellations to compensate a verified reversal SHALL be executed by the Registry Oversight Committee under maker-checker control and SHALL be published.

16.7 Every verified reversal SHALL be compensated by cancellation or replenishment of an equivalent quantity of units, regardless of cause; pursuit of a responsible party is a separate action and SHALL NOT defer compensation.

17. Host country and Article 6 governance

17.1 The default status of every MCC unit SHALL be NOT AUTHORIZED FOR ARTICLE 6 / VOLUNTARY USE ONLY (FD-2026-09-03 item D3).

17.2 Domestic legal permits and host-country project approval or non-objection SHALL be treated as distinct from Article 6 authorization; neither implies the other.

17.3 Evidence of host-country project approval or non-objection, where required by applicable national law, SHALL be verified before the project completes GOVERNANCE_REVIEW (registration), with continued validity confirmed at issuance per MCC-100 clause 19.2.

NOTE — The former open decision on gate placement (OD-3) was resolved in the MCC-100 consolidation under this clause's express assignment (MCC-100 v3.0-draft, NOTE to clause 16.3): the registration gate stated here, with the issuance-stage continued-validity check at MCC-100 clauses 16.4/19.2. The Host Country Authorisation Procedure v1.0 printed the gate as optional; MCC-HCA v2.0-draft clause 3.2, put to consultation with this suite, states it at registration.

17.4 Article 6 authorization SHALL NOT be a precondition to listing, registration or issuance of any unit; it is recorded, where it exists, as an attribute under clause 17.5.

17.5 The registry SHALL record the Article 6 facts of each unit exclusively as the discrete evidence-backed attributes of the Article 6 Attribute/Status Matrix (canonical control table 5): host-country project approval/non-objection; authorization purpose; authorization date/instrument; first-transfer definition; first-transfer event; corresponding-adjustment reporting evidence; withdrawal/revocation status; and scheme eligibility.

17.6 A corresponding adjustment is an accounting action performed and reported by a participating Party under the Article 6 rules; MCC SHALL record linked documentary evidence of it and SHALL NOT purport to perform, instruct or trigger it, at retirement or otherwise.

17.7 The status "CA evidence recorded" SHALL be applied only where the documentary evidence is linked in the Evidence Register, mirrored to the registry record; the label "CA-Confirmed" SHALL NOT be used.

17.8 No MCC unit SHALL be described as an A6.4ER or as compliance-eligible, CORSIA-eligible or scheme-eligible absent linked scheme-specific approval evidence for the exact programme, unit and vintage scope.

17.9 Review of Letters of Authority and other host-country instruments (issuer authority, signatures, conditions, currency) SHALL be performed by the Programme Secretariat and confirmed at the GOVERNANCE_REVIEW gate by the first-instance registration body under Annex A.

18. Methodology governance

18.1 Methodology approvals, major revisions and status changes SHALL follow Annex A: the Standards Committee recommends after public consultation and independent peer review; the approving body and threshold are fixed in Annex A.

18.2 A major revision (scope expansion, baseline-methodology change, or quantification change) SHALL be treated as a new methodology, with the full approval process including fresh consultation.

18.3 No methodology SHALL carry "Active" or "Approved" status without a complete methodology dossier, public consultation record, independent expert review and a signed approval decision linked in the Evidence Register (FD-2026-09-03 item D6).

18.4 The Methodology Status Register (canonical control table 7) SHALL be the single source of methodology status; the public register SHALL display exactly its content.

18.5 Methodology decisions SHALL carry the appeal rights stated in Annex A, heard under the review standard of clause 12.6.

19. Sustainable development certification governance

19.1 Sustainable development contribution assessment and labelling SHALL be performed as defined in MCC-SDCF, subject to that framework's conformity review against FD-2026-09-03 items D1–D3 before reliance (the framework was outside the audited ten-file inventory). That review was completed on 3 September 2026 as CR-2026-001, which found MCC-SDCF v1.0 non-conforming; MCC-SDCF v2.0-draft is put to consultation with this suite, and the status of MCC-SDCF is reserved to the Governing Board (FD-2026-09-04 item 6).

19.2 The institutional home of SD-label certification decisions is not decided. MCC-700 v3.1 assigned certification to an "SD Expert Panel" that is not one of the seven canonical governance bodies. Interim rule until decided: SD-label certification is a first-instance decision of the body designated in Annex A row 14, with appeal to the Independent Appeals Panel; during the transitional period, Section 23 applies. (Consultation question 4.)

19.3 No SD label SHALL be certified for a project whose underlying methodology status does not permit registration.

20. Role of AI systems in governance decisions

20.1 An AI system SHALL NOT take, and SHALL NOT be the deciding input to, any governance decision; a human decision-maker with authority under Annex A SHALL own every decision.

20.2 Every AI system used to support governance SHALL be publicly described with its purpose, limitations and validated performance for the specific use case, as governed by MCC-850.

20.3 A first-pass human or VVB assessment SHALL be completed blind to AI recommendations; AI outputs MAY be consulted only afterwards, for discrepancy and quality review.

20.4 An AI confidence output SHALL NOT reduce the minimum evidence, sampling or scrutiny applied by any human reviewer or VVB.

20.5 Any person affected by a decision supported by an AI system SHALL be entitled, on review or appeal, to human re-examination independent of the AI system, and to the reasons for the decision in human-readable form.

20.6 The Registry Oversight Committee SHALL receive and review independent audits of governance-supporting AI systems at least annually, under MCC-850.

21. Recordkeeping, transparency and retention

21.1 Every governance body SHALL maintain records of agendas, minutes, voting records, decision memoranda, conflict declarations, appeals, complaints, grievance escalations and audit reports.

21.2 Records SHALL be retained in accordance with the canonical Record Retention Schedule; until that schedule is in force, no governance record SHALL be destroyed. (This replaces the seven-year minimum of MCC-700 v3.1 clause 14.2, which conflicted with ten- and twenty-year requirements elsewhere in the suite; the schedule resolves the conflict once, for all documents.)

21.3 Minutes of every governance body meeting SHALL be published within thirty calendar days of the meeting, with only the redactions permitted by clause 21.4.

21.4 The following MAY be withheld from publication: justified proprietary project information; personal data; legally privileged material; information protected by intellectual-property law; and information whose publication would endanger persons or reveal sensitive traditional knowledge or vulnerable locations.

21.5 MCC SHALL publish a quarterly transparency report covering decisions taken, projects by lifecycle state, credits issued and retired, appeals and outcomes, complaints and grievances received and resolved, and audit findings with corrective actions.

21.6 Every status assertion ("approved", "in force", "operational", "recognised") in any MCC publication SHALL link to a decision or evidence record in the Evidence Register; an assertion without a linked record SHALL NOT be published.

22. Amendments

22.1 This Standard MAY be amended only by: a written proposal; a public consultation of no less than the minimum period MCC-001 clause 12.3 prescribes for Tier 2 amendments; a Standards Committee review and reasoned recommendation; and approval by the Independent Governing Board at the threshold fixed in Annex A.

22.2 Amendments to MCC-001 (Constitution) SHALL follow exclusively the process and threshold stated in MCC-001; on the amendment threshold the Constitution prevails and this Standard defers to it. (This removes the unanimous-consent rule of MCC-700 v3.1 clauses 4.1.4 and 17.2, which conflicted with the Constitution's two-thirds/notice rule.)

22.3 Every amendment SHALL be published as a changelog entry and a clean consolidated text; amendment text SHALL NOT be published as a standalone bolded block within the consolidated document.

22.4 No amendment SHALL take effect before its referenced normative dependencies exist (clause 1.4).

23. Transitional provisions

23.1 Factual basis. The Governing Board was constituted on 26 August 2026 with two members (GB-2026-001, recorded in the decision register as attested by the founder, with no executed copy filed); none of the other governance bodies in Section 4 has been constituted. Who exercises their functions until each is constituted is not settled: clause 23.2 proposes the founder, FD-2026-10-01 Schedule 1 (C5) proposes the Governing Board (question 3), and GB-2026-001 records the Governing Board acting as the Standards Committee (resolutions 3.3 and 4.2). FD-2026-09-03 recorded a ratification meeting planned for 23 September 2026. No record of a Governing Board meeting on 23 September 2026 has been filed. This Section states honestly how governance operates until the bodies exist; nothing in this Standard SHALL be read as asserting that any other body currently exists or has decided anything.

23.2 Founder plenary authority. Until a governance body listed in Section 4 is constituted, its functions under this Standard and Annex A are exercised by the founder.

23.3 Limits. In exercising a body's functions the founder SHALL: (a) comply with the independence and conflict rules of Section 5 as applicable to a sole decision-maker, including recusal where personally conflicted; (b) apply the same entry criteria, evidence requirements and prohibitions (including Sections 16.3, 17 and 20) that would bind the body; (c) not approve any methodology as Active/Approved, issue any credit, or release any buffer during the transitional period unless every Annex A and Annex B criterion is met and evidenced; and (d) not amend MCC-001 other than by the Constitution's own process.

23.4 Decision register. Every exercise of a body's function by the founder SHALL be recorded as a dated Founder Decision in the Programme decision register, following the FD-[date]-[item] convention, and SHALL be tabled for ratification under clause 23.6. The decision register at /governance/decisions is authoritative; it records every founder decision entered in it as attested by the founder, with no executed copy filed, and records no decision as signed.

23.5 Sunset. The founder's exercise of a body's functions under this Section SHALL cease for each body upon that body's constitution; this entire Section lapses when the Independent Governing Board and the Independent Appeals Panel are both constituted and the ratification under clause 23.6 has been completed.

23.6 Ratification. All Founder Decisions taken during the transitional period, including FD-2026-09-03 items D1–D8, SHALL be tabled for ratification, variation or reversal at the next meeting of the Governing Board; until ratification or variation, each remains the binding programme rule.

23.7 Appeals during transition. The founder SHALL NOT decide any appeal or independent review of a decision the founder took at first instance; during the transitional period such an appeal SHALL be decided by one or more independent persons appointed from an external roster who took no part in the decision. One external appointee, engaged on a roster basis and paid per matter, SHALL be appointed before the first appeal is heard; none has been appointed. (Consultation question 12.) If no independent person has been appointed when an appeal is filed, the appeal SHALL be held open, the contested decision SHALL NOT be implemented further, and no issuance, transfer or retirement SHALL rely on it until the appeal is decided.

23.8 Complaints during transition. A complaint concerning the founder SHALL be referred to the independent recipient designated under clause 6.3; pending that designation, complaints SHALL be logged, acknowledged under clause 13.4, and held for the constituted Independent Governing Board.

23.9 Notification. The public document register SHALL state, for as long as this Section operates, that the Programme is founder-governed pre-panel and that the bodies in Section 4 are not yet constituted.

24. Entry into force

24.1 This Standard (MCC-700 version 4.0) SHALL enter into force upon approval by the Independent Governing Board — or, during the transitional period, upon a Founder Decision recorded and tabled for ratification under Section 23 — on a stated date, following the public consultation on this draft and completion of the acceptance tests referenced in rule DC-5.

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

24.3 On entry into force, MCC-700 v3.1 (and its v3.0 draft headers) SHALL be formally superseded and archived as an uncontrolled historical record with a superseded watermark.

24.4 Decisions validly taken before entry into force SHALL NOT be reopened by this Standard alone, except that (a) any decision inconsistent with the prohibitions in clauses 16.3, 17.6–17.8 and 20.1 SHALL be reviewed and corrected, and (b) ratification under clause 23.6 MAY vary or reverse Founder Decisions.

24.5 Within ninety calendar days of entry into force, each constituted governance body SHALL file with the Independent Governing Board an attestation of conformance of its procedures with this Standard.

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Annex A — Delegated Authority Matrix (normative)

NOTE — Every row of this Matrix is the administration's proposal, put to public consultation as one proposal under founder direction FD-2026-10-01 Schedule 1 (C2); no row is a rule in force. The proposal is written into the rows: row 7, first-instance project registration — the Programme Secretariat decides and the Registry Oversight Committee is notified, revisited at 25 registered projects (question 10); the voting thresholds of note A-2 (question 14); row 13, project revocation — the Independent Governing Board (question 15); and rows 24 and 28–30, confirmed as drafted. No owner is proposed for row 14 (question 4) or row 15 (question 16). (Consultation question 13.)

A-1 This Annex is generated from the Governance RACI & Delegated Authority Matrix (canonical control table 4) adopted under FD-2026-09-03 item D4. R = recommends; A = accountable/approves; C = consulted; I = informed; App = appeal route. During the transitional period, every "A" is exercised by the founder under Section 23 and logged for ratification; Section 23.7 governs appeals.

A-2 The voting thresholds in this Matrix are proposed under FD-2026-10-01 Schedule 1 (C2): two-thirds for constitutional amendments (row 1, where MCC-001 prevails), methodology approvals (row 3) and appeal decisions of the Independent Appeals Panel; a simple majority for every other decision type, except where this Matrix requires maker-checker (two-person) approval. Until set, the default threshold of clause 7.4 applies to the founder's transitional exercise of the power, and the conflicting thresholds printed in MCC-700 v3.1 (clause 4.2.4 simple majority versus Section 11's 75% supermajority for methodology approval) are superseded and SHALL NOT be applied. (Consultation question 14.)

#	Decision type	R	A (owner)	C	I	Threshold	App
1	Constitution amendment	Programme Secretariat	Independent Governing Board, per MCC-001's own process	Public consultation	All bodies	Per MCC-001 (Constitution prevails)	—
2	Programme standard adoption/amendment (including amendment of this Standard, per Section 22 and MCC-001 clause 12.3)	Standards Committee	Independent Governing Board	Public consultation; Safeguards & Rights Panel	VVBs; participants	Simple majority	Independent Appeals Panel (process review, cl. 12.6)
3	Methodology approval / major revision	Standards Committee (technical working groups)	Independent Governing Board, or the delegate recorded in this Matrix (none is recorded at this draft)	Peer reviewers; public consultation	Registry Oversight Committee	Two-thirds	Independent Appeals Panel (cl. 12.6)
4	Methodology status change (Methodology Status Register)	Standards Committee	Independent Governing Board	—	Public register	Simple majority	Independent Appeals Panel (cl. 12.6)
5	Minor/technical methodology revision	Standards Committee	Standards Committee	—	Public register	Simple majority	Independent Appeals Panel (cl. 12.6)
6	VVB recognition / scope / suspension / revocation	VVB Oversight Committee	VVB Oversight Committee	Standards Committee	Affected projects	Simple majority	Independent Appeals Panel (de novo)
7	Project registration (first instance)	Programme Secretariat (technical review)	Programme Secretariat — distinct from the Independent Appeals Panel (cl. 10.3); revisited at 25 registered projects (Consultation question 10.)	Safeguards & Rights Panel (Category A/B)	Registry Oversight Committee	Simple majority	Independent Appeals Panel (de novo)
8	Safeguards clearance (Category A)	Safeguards & Rights Panel	First-instance registration body (row 7)	VVB safeguards verification	Affected stakeholders	Simple majority	Independent Appeals Panel (de novo)
9	Credit issuance	Registry Oversight Committee (maker-checker)	Registry Oversight Committee	VVB verification statement	Public register	Maker-checker (two-person)	Independent Appeals Panel (de novo)
10	Buffer release	Registry Oversight Committee	Independent Governing Board	Independent actuary/adequacy assessor	Public register	Simple majority	—
11	Buffer cancellation (reversal compensation)	Programme Secretariat compliance monitoring	Registry Oversight Committee	—	Public register	Maker-checker (two-person)	— (obligatory under cl. 16.7)
12a	Project suspension (safeguards) / urgent-harm stop-work	Safeguards & Rights Panel	Safeguards & Rights Panel	Programme Secretariat	Affected stakeholders	Simple majority	Independent Appeals Panel (de novo)
12b	Confirmation (or lifting) of an urgent-harm suspension	Programme Secretariat compliance monitoring	Independent Governing Board	Safeguards & Rights Panel	Affected stakeholders	Simple majority	Independent Appeals Panel (de novo)
13	Project revocation	Programme Secretariat compliance monitoring	Independent Governing Board (Consultation question 15.)	Safeguards & Rights Panel	Registry; public register	Simple majority	Independent Appeals Panel (de novo)
14	SD label certification	Per MCC-SDCF assessment	Not designated — clause 19.2 (Consultation question 4.)	Standards Committee	Public register	Simple majority	Independent Appeals Panel (de novo)
15	Claims/marketing approval (against MCC-600 once in force)	Programme Secretariat	Not designated; no proposal is made (Consultation question 16.)	Standards Committee	Public	Simple majority	—
16	Complaints against MCC	Independent complaints function (cl. 13.3)	Independent Governing Board	—	Complainant	n/a	External, per participant agreements (cl. 12.10)
17	Governance-body appointments and removals	Nominations process (cl. 6.1)	Independent Governing Board	—	Public	Simple majority	—
18	Budget and delegated financial authority	Programme Secretariat	Independent Governing Board	External auditor	Public (annual statements)	Simple majority	—
20	Enforcement: written warning to a participant (MCC-100 cl. 23.2)	Programme Secretariat compliance monitoring	Independent Governing Board (participant-level enforcement)	Safeguards & Rights Panel (where safeguards-related)	Participant	Simple majority	Independent Appeals Panel (de novo, per MCC-100 cl. 23.6)
21	Enforcement: conditional participation (MCC-100 cl. 23.2)	Programme Secretariat compliance monitoring	Independent Governing Board	Safeguards & Rights Panel (where safeguards-related)	Participant; public register	Simple majority	Independent Appeals Panel (de novo, per MCC-100 cl. 23.6)
22	Enforcement: temporary suspension of a participant (≤12 months per imposition, MCC-100 cl. 23.2)	Programme Secretariat compliance monitoring	Independent Governing Board	Safeguards & Rights Panel (where safeguards-related)	Participant; public register	Simple majority	Independent Appeals Panel (de novo, per MCC-100 cl. 23.6)
23	Enforcement: permanent suspension of a participant (MCC-100 cl. 23.2)	Programme Secretariat compliance monitoring	Independent Governing Board	Safeguards & Rights Panel (where safeguards-related)	Participant; public register	Simple majority	Independent Appeals Panel (de novo, per MCC-100 cl. 23.6)
24	Enforcement: cancellation of specifically affected issued units on a defect finding (MCC-100 cl. 23.5) — distinct from row 11 (buffer cancellation) and row 13 (project revocation)	Programme Secretariat compliance monitoring	Registry Oversight Committee (unit-level, maker-checker)	VVB whose statement is affected; Safeguards & Rights Panel (where safeguards-related)	Unit holders; public register	Maker-checker (two-person)	Independent Appeals Panel (de novo, per MCC-100 cl. 23.6)
25	Enforcement: programme exclusion of a participant and related parties (MCC-100 cl. 23.2)	Programme Secretariat compliance monitoring	Independent Governing Board	Safeguards & Rights Panel	Participant; public register	Simple majority	Independent Appeals Panel (de novo, per MCC-100 cl. 23.6)
26	Enforcement: reinstatement of a participant (MCC-100 cl. 23.7)	Programme Secretariat compliance monitoring	The body that imposed the measure (rows 20–25)	—	Participant; public register	Simple majority	Independent Appeals Panel (de novo — refusal of reinstatement)
27	Reversal determination and proponent replenishment liability (MCC-BPM cll. 9.13, 10.2)	Programme Secretariat compliance monitoring	Registry Oversight Committee	Verifying VVB; independent adequacy assessor where portfolio-level	Proponent; public register	Simple majority	Independent Appeals Panel (de novo)
28	Registry account onboarding determination (MCC-800 cll. 4.7, 7.1–7.3)	Programme Secretariat registry function	Programme Secretariat registry function under Registry Oversight Committee oversight, maker-checker	—	Applicant	Maker-checker (two-person)	Review route per MCC-800 cl. 7.3
29	Registry account suspension, including investigation restrictions (MCC-800 cll. 4.7, 7.18, 25.3)	Programme Secretariat registry function	Programme Secretariat registry function under Registry Oversight Committee oversight, maker-checker	Registry Oversight Committee	Account holder	Maker-checker (two-person)	Independent review and appeal under Sections 11–12 (de novo)
30	Registry account closure (MCC-800 cll. 4.7, 7.20)	Programme Secretariat registry function	Programme Secretariat registry function under Registry Oversight Committee oversight, maker-checker	—	Account holder; public register where required	Maker-checker (two-person)	—
31	Registry continuity and wind-down plan approval, including wind-down funding sizing and periodic review (MCC-800 cll. 21.1, 21.4)	Registry Oversight Committee	Independent Governing Board	External auditor; independent adequacy assessor	Public register	Simple majority	—
32	Cross-registry interoperability agreement approval (MCC-800 cl. 22.1)	Registry Oversight Committee	Independent Governing Board on Registry Oversight Committee recommendation	Standards Committee (where methodology/unit semantics affected)	Public register	Simple majority	—
33	MCC Fee Schedule adoption and amendment, and fee waivers (MCC-100 cl. 13.4; MCC-400 cl. 18.1; MCC-800 cll. 24.1, 24.3) — one instrument, per A-6	Programme Secretariat	Independent Governing Board; waiver decisions delegable by later amendment of this Matrix	Public consultation for schedule changes	Participants; public register	Simple majority	—
34	Material AI model change approval, with the material/minor delegation boundary of MCC-850 cl. 18.6	Programme Secretariat (AI function)	Independent Governing Board, or the delegate recorded per the MCC-850 use-case register	Registry Oversight Committee (AI audit oversight, cl. 20.6)	Public AI register per MCC-850	Simple majority	—
35	Buffer-administration transfer (MCC-BPM cl. 8.9)	Registry Oversight Committee	Independent Governing Board	Independent adequacy assessor	Public register	Simple majority	—
36	Programme-wide buffer contribution-rate increase (MCC-BPM cl. 10.6(c))	Registry Oversight Committee	Independent Governing Board on Registry Oversight Committee recommendation	Independent adequacy assessor; affected proponents	Public register	Simple majority	—
37	Buffer concentration limits (MCC-BPM cl. 12.7)	Registry Oversight Committee	Independent Governing Board	Independent adequacy assessor	Public register	Simple majority	—
38	Acceptance of equivalent replenishment units (MCC-BPM cl. 10.2)	Programme Secretariat compliance monitoring	Independent Governing Board	Registry Oversight Committee; Standards Committee (unit equivalence)	Proponent; public register	Simple majority	Independent Appeals Panel (de novo — refusal of acceptance)

A-3 Prohibited role combinations (clause 5.1–5.3, stricter rule prevails): standard-setting + programme administration; first-instance decision + review/appeal on the same matter; commercial project role + oversight seat on the same project.

A-4 Delegated financial authority limits (clause 6.7): EUR 25,000 per commitment and EUR 100,000 a year in aggregate; nothing touching the buffer pool is delegated. (Consultation question 7.)

A-5 Rows 20–26 were added by conforming revision on 3 September 2026 to designate the decision types that MCC-100 Section 23 mandates; their owners and thresholds form part of the proposal described in the note above this Matrix. Row number 19 is permanently retired (its former content was folded into row 2) and is not reused.

A-6 Rows 27–38 were added by a second bundled conforming instrument on 3 September 2026: rows 27–30 adopt the drafters' properly framed proposals (MCC-BPM cl. 9.13; MCC-800 cl. 4.7), and rows 31–38 designate the decision types found mandated but unowned (MCC-800 cll. 21.1/21.4, 22.1, 24.1/24.3; MCC-400 cl. 18.1; MCC-850 cl. 18.6; MCC-BPM cll. 8.9, 10.2, 10.6(c), 12.7 — whose direct owner statements are void under clause 8.2; MCC-BPM v2.0-draft points them to these rows). The same instrument settles the fee-instrument architecture: there SHALL be one fee instrument, the MCC Fee Schedule, a single Tier 5 instrument covering programme and registry fees, entered in the document register as MCC-FEES (1.0-draft) and not yet put to consultation; no fee amount has been set, every fee amount being reserved to the Governing Board (FD-2026-09-04 items 4 and 6). MCC-100 cl. 13.4 and MCC-400 cl. 18.1, put to consultation with this suite, and the MCC-800 v2.0 draft (cl. 24.1) cite it by that name. The owners and thresholds in rows 27–38 form part of the proposal described in the note above this Matrix.

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Annex B — Project Lifecycle State Machine (normative)

B-1 This Annex implements the single lifecycle state machine required by the independent audit (SYS-12): one owner, entry criteria, exit criteria, SLA and appealability for every transition. The registry and platform SHALL implement only these states and transitions (clause 9.2).

B-2 States (aligned with the platform's project_status pipeline): DRAFT, SUBMITTED, COMPLETENESS_CHECK, SAFEGUARDS_SCREENING, TECHNICAL_REVIEW, STAKEHOLDER_CONSULTATION, GOVERNANCE_REVIEW, REGISTERED, ACTIVE, SUSPENDED, COMPLETED, REJECTED, WITHDRAWN. No other state SHALL be used; a possible ON_HOLD state is open for comment (note B-4). (Consultation question 9.)

B-3 SLA values in this table are proposed for consultation; they are drafting proposals, not evidenced operational commitments, and are confirmed or varied on approval of this Standard, together with their alignment with MCC-100. (Consultation question 17.) "Owner" means the body accountable for the transition decision under Annex A; during the transitional period, Section 23 applies.

#	Transition	Owner	Entry criteria (to start the stage)	Exit criteria (to pass the gate)	SLA (proposed)	Appealable?
T1	DRAFT → SUBMITTED	Project developer (act); Programme Secretariat (receipt)	Developer account in good standing; declared methodology has a status permitting submission per the Methodology Status Register	Complete submission package lodged; receipt acknowledged in writing	Acknowledgement within 5 business days	No (administrative)
T2	SUBMITTED → COMPLETENESS_CHECK	Programme Secretariat	Submission received	All mandatory documents present against the published checklist; fees position recorded	10 business days	No; a completeness rejection returns the file to the developer with reasons and MAY be resubmitted
T3	COMPLETENESS_CHECK → SAFEGUARDS_SCREENING	Programme Secretariat (screening per the Environmental & Social Safeguards Policy); Safeguards & Rights Panel (Category A review)	Completeness confirmed	Risk category (A/B/C) assigned with reasons; Category A: Safeguards & Rights Panel review complete; exclusions screened	20 business days (Category C/B); 40 business days (Category A)	Yes — category assignment and screening refusal (de novo)
T4	SAFEGUARDS_SCREENING → TECHNICAL_REVIEW	Programme Secretariat (review); validation input from recognised VVB where required by MCC-100/MCC-400	Screening passed	Technical review report complete; methodology applicability, baseline, additionality and quantification checks documented; validation report (where required) received and blind to AI outputs per cl. 20.3	40 business days	Yes — adverse technical determination (de novo)
T5	TECHNICAL_REVIEW → STAKEHOLDER_CONSULTATION	Programme Secretariat	Technical review passed	Public consultation of the period stated in the SLA column completed; comments logged; developer responses to material comments published	30 calendar days consultation (open point OD-7; this cell is the value's single authoritative statement — MCC-100 cl. 13.8 cites this row without restating a number) + 15 business days processing (Consultation question 17.)	No (procedural stage); failure to run consultation is a process ground on later appeal
T6	STAKEHOLDER_CONSULTATION → GOVERNANCE_REVIEW	First-instance registration body (Annex A row 7)	Consultation record complete	Governance review passed: safeguards clearance confirmed; host-country domestic-permit evidence verified where required (cl. 17.3); no unresolved exclusion, conflict or double-counting flag	20 business days	Yes — refusal (de novo)
T7	GOVERNANCE_REVIEW → REGISTERED	First-instance registration body (Annex A row 7)	All prior gates passed sequentially (cl. 9.4)	Registration decision in writing with reasons (cl. 10.4); methodology status permits registration (cl. 18.3); registry record created	10 business days	Yes — refusal (de novo)
T8	REGISTERED → ACTIVE	Programme Secretariat	Registration complete	Monitoring plan activated; crediting-period start conditions met and evidenced	10 business days after start conditions evidenced	No (administrative)
T9	ACTIVE → SUSPENDED	Safeguards & Rights Panel (safeguards grounds, incl. immediate urgent-harm stop-work, cl. 14.3); Registry Oversight Committee (registry-integrity grounds); other compliance grounds: no owner is designated in Annex A rows 12a–13 and none is proposed (Consultation question 18.)	Documented non-compliance, deterioration, withdrawn consent, fraud indication, or urgent harm	Suspension decision in writing with reasons, conditions for reinstatement, and effect on pending issuances (none proceed)	Urgent harm: immediate; otherwise 10 business days from finding	Yes (de novo); appeal does not lift an urgent-harm suspension pending decision
T10	SUSPENDED → ACTIVE	The body that suspended	Reinstatement conditions evidenced	Written reinstatement decision; verification of remedy where applicable	20 business days from evidence of cure	Yes — refusal of reinstatement (de novo)
T11	SUSPENDED → REJECTED (revocation)	Annex A row 13 body	Suspension unresolved, or critical violation (human-rights abuse, irreversible damage, fraud)	Revocation decision in writing; credit consequences determined under MCC-800 due-process rules (no retroactive cancellation of validly issued credits without a defect finding)	40 business days	Yes (de novo)
T12	ACTIVE → COMPLETED	Programme Secretariat	Crediting period ended and final verification concluded, or project term ended	Final monitoring/verification obligations discharged; post-crediting obligations (incl. remedy survival, cl. 14.5, and reversal-monitoring obligations per the permanence standard) recorded	20 business days	No (administrative); disputes over final issuance follow T-I below
T13	Any pre-REGISTERED state → REJECTED	The gate owner for the current stage	Gate criteria conclusively failed	Written rejection with each ground stated separately (cl. 10.5)	Within the stage SLA	Yes (de novo)
T14	Any state → WITHDRAWN	Project developer (act); Programme Secretariat (record)	Developer's written withdrawal	Withdrawal recorded; fees and data-retention consequences per participant agreement; public register updated	5 business days	No (developer's own act)
T-I	Issuance (event within ACTIVE, not a state change)	Registry Oversight Committee (Annex A row 9)	Every prerequisite of MCC-100 clause 19.2 (the authoritative list, incorporated here by reference)	Maker-checker approval; serials assigned under the versioned serial specification; public record	15 business days from complete verification package	Yes — reduction or refusal of issuance (de novo)
T15	COMPLETENESS_CHECK, SAFEGUARDS_SCREENING or TECHNICAL_REVIEW → DRAFT (return for revisions)	The gate owner for the current stage	Remediable deficiencies identified that do not warrant rejection; due-process controls of MCC-100 clause 13.10 satisfied	Written return notice stating each deficiency separately and the resubmission route; gates already passed are not reopened on resubmission (MCC-100 cl. 13.10(d), matching T2's resubmission logic); no return after STAKEHOLDER_CONSULTATION has begun (MCC-100 cl. 13.11)	Within the current stage's SLA	No — a return is not a rejection and carries a resubmission right; a rejection on the same facts remains appealable under T13

B-4 States beyond the platform pipeline. One candidate addition remains open for comment, not adopted: an ON_HOLD state for projects whose methodology regresses in status (clause 9.5) — currently handled as a dated hold annotation on the current state. (Consultation question 9.)

B-4A A LISTED public-visibility marker state is not adopted at this revision (former open item B-4(b)/OD-6, closed 3 September 2026 by the resolution recorded at MCC-100 v3.0-draft clause 13.18 and this conforming revision): listing is a description of a SUBMITTED project's public visibility, is not a lifecycle state, and confers no approval (Definitions: "Listing"). Adoption of a LISTED state hereafter requires amendment of this Standard under Section 22.

B-5 Every transition record SHALL capture: the decision owner and quorum, the criteria evidence, timestamps against the SLA, and the appeal window; SLA performance SHALL be published in the quarterly transparency report (clause 21.5).

B-6 No transition SHALL be executed by an AI system (clause 20.1), and no gate SHALL be reordered, parallelised or skipped for any project, including pilot projects.

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End of MCC-700 v4.0-draft. Status: DRAFT — FOR CONSULTATION. Not in force.