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RULE CHANGE · Tier 3 — Programme rules (MCC-100 series)OPEN FOR COMMENT

MCC-100 Programme Standard — Amendment 2: reversal-risk management period for MCC-HYB units (v2.2 → v2.3), with Buffer Pool Management Policy Amendment 1

MCC-100 Programme Standard v2.2 cl. 0183.1 and 0191 → v2.3; Buffer Pool Management Policy v1.0 → v1.1

Opened 27 August 2026Closes 26 September 2026 · 30-day notice (floor 30)27 days left

What is being consulted on

Keeps the 30-year F02 and F05 permanence horizons of MCC-200 cl. 0031.1 and defines, for every MCC-HYB unit, a reversal-risk management period of forty years from its issuance during which the buffer liability and monitoring obligations continue — the rule the ICVCM Assessment Framework (CCP 6) expects — with the consequential change to the buffer release schedule. Opened following the Board’s adoption of Option C of BP-2026-003 (GB-2026-001, Resolution 4.4).

Decision by
Governing Board (MCC-001 cl. 0081), following its decision on BP-2026-003 (GB-2026-001, Resolution 4.4 — Option C adopted); the Buffer Policy amendment under FD-2026-08-24 item 3
After closing
Every material comment receives a written response; the closing protocol is published here; the decision cites the proposal by its hash; on adoption the text is published at /transparency/documents with a version bump and this consultation is linked from it.
Proposal SHA-256
c1af6447f1264dd41ea317556286205e3189127eb9c7acc0481835d531e95fb8
Source file
MCC-100_Amendment2_Reversal_Risk_Management_Period_v0.1_UTKAST.md

Proposal text hash c1af6447…31e95fb8

MCC-100 Programme Standard — Amendment 2: Reversal-risk management period for MCC-HYB units (v2.2 → v2.3), with Buffer Pool Management Policy Amendment 1 (v1.0 → v1.1)

Instrument: Amendment to MCC-100 Programme Standard v2.2 cl. 0183.1 and 0191 (Tier 3; 30 days' public consultation, MCC-001 cl. 0081) and consequential amendment to the Buffer Pool Management Policy v1.0 cl. 0069.2 and 0130 (Tier 5; 14 days, cl. 0083), consulted together and entering into force together. Status: v0.1 DRAFT 26 August 2026 — NOT ADOPTED. Prepared for the Board's decision on BP-2026-003 (constituting meeting, Item 4.4); goes to consultation only if Option C is adopted. Basis: BP-2026-003; ICVCM Assessment Framework CCP 6; MCC-200 v2.0 cl. 0031.1–0031.3 (unchanged); FD-2026-08-24 D5, D12


Amendments to MCC-100 v2.2

A2.1 — cl. 0183.1, add a second paragraph:

0183.1a For every MCC-HYB unit, the project shall manage reversal risk for a reversal-risk management period of forty (40) years from the date of issuance of that unit. During the management period the buffer contribution attributed to the unit remains in the buffer pool subject to the release schedule of the Buffer Pool Management Policy, the monitoring obligations of cl. 0191 continue in respect of the crediting area, and a confirmed reversal is treated under cl. 0191–0193. The family permanence horizon of MCC-200 cl. 0031.1 governs quantification and the crediting period; it does not shorten the management period.

A2.2 — cl. 0183.1, add a third paragraph:

0183.1b The monitoring plan and the financial assurance of an F02 or F05 project shall cover the management period of the last unit the project expects to issue. Where the post-crediting monitoring period of MCC-200 cl. 0031.1 ends before the management period of any issued unit, the project shall continue monitoring at the post-crediting frequency until the last management period has ended.

A2.3 — cl. 0191, after the reversal thresholds, add:

The thresholds apply throughout the reversal-risk management period of cl. 0183.1a. A reversal confirmed after the crediting period but within the management period of any issued unit is a reversal for the purposes of this clause.

Amendments to the Buffer Pool Management Policy v1.0

B1.1 — cl. 0069.2, add: "For MCC-HYB units the longevity-risk score is calibrated to the family permanence horizon; the release schedule of Section [phased release] is applied to each vintage from its issuance date and no release is made for a vintage whose reversal-risk management period (MCC-100 cl. 0183.1a) has not reached the release milestone."

B1.2 — cl. 0130, replace "permanence guarantee period" with "reversal-risk management period (MCC-100 cl. 0183.1a)".

Effect

F02 and F05 keep their 30-year horizons. Every MCC-HYB unit carries a 40-year buffer and monitoring liability from its own issuance. F01 (100-year horizon) and F03/F04 (flow measures, no horizon) are unaffected. The registry records the issuance date per unit already; the management period is issuance date + 40 years and can be shown on the unit and in the buffer ledger without a schema change.

Consultation questions

  1. Is a vintage-dependent monitoring period financeable for reef-restoration and MPA projects, and what assurance instrument should cl. 0183.1b accept?
  2. Should the management period for units issued in the last five years of a crediting period be capped at the end of the post-crediting monitoring period, with a correspondingly higher buffer contribution instead?

Change log — v0.1 DRAFT (26 Aug 2026): first issue, for BP-2026-003.

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