MCC-APP — Appeals Procedure v1.0-draft

Document control

Field	Value
Document code	MCC-APP (code assigned by the programme administration for this consultation; entered in the Document Register on adoption)
Title	Appeals Procedure
Version	1.0-draft
Status	DRAFT — FOR CONSULTATION
Date of this draft	4 September 2026
Tier	Tier 3 (operational procedure subordinate to MCC-001 and MCC-700) — drafting proposal, not decided. See cl. 2.6 — MCC-001 v3.0-draft cl. 9.10.3 reserves "appeal mechanics" to the Tier 2 document, and the Board may prefer this text as an annex to MCC-700 rather than a free-standing instrument. (Consultation question 1.)
Effective date	None. This procedure is not in force. No appeal may be made under it, no time limit in it runs, and no body is constituted by it, until it enters into force under Section 24.
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	MCC-700 v3.0/v3.1 cll. 2.2, 4.4.1, 4.4.2, 5.4, 6.1.4.1, 7.1.2.3, 11.1 (row "Appeal determination"), 12.1, 13.2, 13.4, 14.1, 14.4, 14.5, 15.1–15.8, 16.2, 18.1 (no commencement date inserted — cl. 1.5); MCC-700 v2.0 §§2.1.2, 9.1–9.7, 12.3.4 (recovered from Drive 01_Gamle_versjoner, 14 March 2026 — cl. 1.6); MCC-700 v4.0-draft cll. 3.2.1–3.2.7, 4.10.1–4.10.5, 4.11.3, 5.1–5.3, 5.7, 6.3, 7.5, 8.2, 10.3–10.5, 11.1–11.5, 12.1–12.12, 13.1–13.5, 14.1–14.6, 15.6, 20.5, 21.1, 21.5, 23.1–23.9, Annex A rows 2–38, Annex B rows T3, T4, T6, T7, T9, T10, T11, T13, T15 and T-I; MCC-001 v2.0 cl. 0055; MCC-001 v3.0-draft cll. 9.7.2, 9.8.5, 9.8.7, 9.9.1–9.9.8, 9.10.1, 9.10.3; MCC-001 Charter Amendment 1 v0.2 A1.2; MCC-100 v2.1/v2.2 cll. 0019, 0029, 0037, 0272, 0286–0293, and Amendment 1 cl. 0057.1; MCC-100 v3.0-draft cll. 13.10, 13.11, 22.7, 23.1–23.8; MCC-400 v1.1 arts. 29, 30, 72–76; MCC-400 v2.0-draft cll. 1.4, 3.1–3.5; MCC-800 v1.0 arts. 30, 48, 51, 52, 65; MCC-800 v2.0-draft cll. 4.1, 8.8, 11.5, 14.3; MCC-ESS v1.0 cll. 0106–0124 and the grievance-stage table; MCC-ESS v2.0-draft cll. 20.6–20.13, 21.1–21.8, 22.7; MCC-REST v1.0-draft §10 and cl. 11.1; MCC-ROI v1.0-draft cll. 11.2, 11.5, 11.10–11.18, 13.3; Applicant Terms v1.1 arts. 10.2, 10.3; VVB Terms v1.1 arts. 5.2, 8; MCC Programme Bible v2.0 §§"Governance", "Appeals and Dispute Resolution"; MIR-2026-001 rev 3 §§0, 3.6, 3.8, 6.
Supersedes	None (new document). It is the first operational text of the appeals procedure the Programme has referred to since March 2026. It supersedes nothing and repeals nothing; the appeal rights it serves are conferred elsewhere and are unaffected by it.
Language convention	British English; RFC-style normative verbs (SHALL/MUST = mandatory; SHOULD = recommended, deviation to be documented; MAY = optional). One requirement per numbered clause.
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)

NOTE (non-normative). Five instruments confer a right of appeal. Five name a body to hear one. None of those bodies exists.

MIR-2026-001 rev 3 §3.6 records an operational Appeals Procedure as referred to and never written. That is right, and this draft is it. But the more useful finding is what the search for it turned up.

The Programme has conferred a right of appeal, in writing, in five separate instruments, over six months, and has named a different forum each time: the Review and Appeals Authority (MCC-700 v3.0/v3.1 cl. 4.4, seven members); the Appeals Body (MCC-700 v2.0 §9.1, three members); the Appeal Officer (MCC-100 cll. 0029, 0037, 0287, 0292); the Appeals Panel of three (Programme Bible v2.0); and the Independent Appeals Panel (MCC-700 v4.0-draft cl. 4.10, MCC-001 v3.0-draft cl. 9.9.5). Not one of the five has a single appointee. governance_appointments holds two rows, both against the Governing Board, and every other body record in governance_bodies — seventeen rows in all across two governance epochs at 1 October 2026, the Independent Appeals Panel among them — is a description of an intention. The Programme has been telling people they may appeal, to a body it has never constituted. MCC-700 v4.0-draft cl. 4.10.5 says so in terms: "Status: not yet constituted".

It is not only on paper. Until 7 September 2026 the public accreditation page told a refused VVB that the decision "may be appealed under MCC-700 Section 15 within 30 days" (the text was replaced that day, PR #259, and now states that there is at present no forum); the KYC Account Opening Procedure §8 says refusals "state grounds and the appeal route"; the Applicant Terms in force give an appeal address, appeal@mcc-credits.org, and a fourteen-day Board decision. Section 15 of MCC-700 v3.1, which the document register records as in force (FD-2026-08-24 item D11), has no recorded commencement date (cl. 1.5). The address routes to a body that does not exist. Nothing has yet been filed — which is the only reason no one has found this out the hard way.

Three corrections to the record are made in Section 23 and should be read before anything else here.

First: MCC-700 v2.0 exists. The v4.0-draft changelog records it as "Not in the programme record" with an evidence line — "No such instrument is in the programme record; the programme's document corpus was searched on 3 September 2026" — and document_register carries the same note. It is in Drive, in 01_Gamle_versjoner, dated 14 March 2026, and its Section 9 is a complete appeals procedure: an Appeals Body of three on four-year terms, an admissibility stage, a standard of review, an interim-suspension test, a fee with refund on reversal, and — at cl. 12.3.4 — the one rule the corpus otherwise lacks: "Until the Appeals Body is constituted, appeals against Governance Decisions shall be heard by a temporary panel of three independent persons appointed by the Governing Board." The absent instrument had been drafted six months ago and filed under old versions. What is genuinely absent is any record of its adoption. This is the sixth "does not exist" the Programme has recorded and been wrong about, and the fourth caused by searching one shelf.

Second: MCC-400 does not reserve VVB appeals to itself. The reservation in MCC-400 v2.0-draft cl. 1.4 covers competence, impartiality, insurance, sampling independence, rotation, cooling-off and oversight. Appeals are expressly sent the other way: cl. 3.4 routes every recognition refusal, suspension and withdrawal to "the independent review and appeal rights of MCC-700 Sections 11 and 12", heard de novo, and the in-force text does the same at MCC-400 v1.1 arts. 30 and 76. This Procedure therefore covers accreditation appeals and states no VVB impartiality rule of any kind (cl. 2.4).

Third: a grievance store exists and an appeal store does not. grievance_records is in the database with a public filing form at /grievances, an API route and an administrative screen; it holds no rows because nothing has been filed. There is no appeals table, no appeals column, no appeals route and no appeals page anywhere in the platform: the only files in the repository with "appeal" in the name are the MCC-700 v3.1 .docx and .pdf, and this draft. The public page that would receive an appeal is titled "Grievances and appeals" and, for appeals, points the reader at MCC-700. Section 4 draws the boundary the page collapses.

What this draft does not do. It confers no right of appeal — MCC-700 does that. It constitutes no body — only an appointment does that. It sets no voting threshold and no decision owner; those are fixed exclusively in MCC-700 Annex A (MCC-700 v4.0-draft cl. 8.2). And it does not pretend that an appeal filed tomorrow could be heard. Section 12 says plainly what happens to it: it is registered, it is held open, and the decision it challenges goes no further while it waits.

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. Document control (Tier) and clause 2.6 — form of this instrument. Proposed: a free-standing Tier 3 procedure (operational procedure subordinate to MCC-001 and MCC-700), cross-referenced from MCC-700 Section 12. The alternative is a numbered annex to MCC-700 v4.0, so that MCC-001 v3.0-draft cl. 9.10.3, which reserves "appeal mechanics" to the Tier 2 document, is satisfied on its face; the choice changes nothing in the substance of this Procedure. Basis: the drafting proposal in the document control and cl. 2.6, put to consultation under FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on which form better meets MCC-001 v3.0-draft cl. 9.10.3.

2. Clause 2.7 — appeal routes in the participant agreements. Proposed: where Applicant Terms v1.1 art. 10.3 or VVB Terms v1.1 art. 5.2 and this Procedure both apply to the same challenge, the Programme applies whichever gives the appellant the longer period and the more independent forum, and records which it applied. Conforming the agreements to MCC-700 by amendment is, in the clause's words, the cleaner answer, and requires a decision this Procedure cannot take. Basis: cl. 2.7 as drafted (see also cll. 24.4 and 25.7); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the agreements should be amended to conform to MCC-700.

3. Clause 2.8 — a notice-of-appeal form. Proposed: while no form exists, Section 8 states the required content of a notice of appeal directly; if that content is issued as a form, it is issued as MCC-FORM-014 (Notice of Appeal) in the Forms Suite, and Section 8 is then replaced by a reference to it. The Forms Suite runs MCC-FORM-001 to MCC-FORM-013 and contains no appeal form. Basis: cl. 2.8 as drafted; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the content should be issued as a form.

4. Clause 3.9 — look-back period for independence. Proposed: 36 months, one figure for both the independence look-back of MCC-700 v4.0-draft cl. 3.2.6 and the conflict-of-interest look-back of MCC-ROI v1.0-draft cl. 6.6, as MCC-ROI proposes; this Procedure adopts the figure that resolves the point there and proposes no third. Basis: FD-2026-10-01 Schedule 1 (Q7); MCC-ROI v1.0-draft cll. 3.6 and 6.6; Annex A, FI-APP-8. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether 36 months is the right period.

5. Clause 5.2 — the "materially affected" test. Proposed: a person is materially affected where the decision directly alters that person's rights, obligations or legitimate expectations within the Programme — the test of MCC-700 v2.0 §9.2.1, used because no instrument in the current suite supplies one. Basis: cl. 5.2 as drafted; MCC-700 v2.0 §9.2.1; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether this test should be confirmed or another substituted.

6. Clause 6.4 — decisions excluded from appeal. Proposed: the exclusions of MCC-700 v2.0 §9.2.3(a) to (c) — Charter amendments, the annual budget, and internal administrative matters not directly affecting participants — are adopted, because a rule of general application is challenged through consultation and amendment rather than by appeal, and because MCC-700 v4.0-draft Annex A already marks rows 1, 17, 18 and 33 with no appeal route. Basis: cl. 6.4 as drafted; MCC-700 v2.0 §9.2.3; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether each of the three exclusions should be adopted.

7. Clauses 11.7(c) and 12.9 — who hears an appeal before the Independent Appeals Panel exists. Proposed: one external appointee, on a roster basis, paid per matter, required before the first appeal is heard; no rate of payment is proposed. FD-2026-10-01 Schedule 1 (C5) proposes that each governance body's functions are exercised by the Governing Board until that body is constituted; the Independent Appeals Panel is the exception and must be external from the start, because the Board takes first-instance decisions and cannot hear an appeal from itself. None is appointed and no roster is designated. None of the five appellate forums named in the Programme's instruments has an appointee (cl. 23.1), and until an appointment is made an appeal is registered and held open under Section 12. Basis: FD-2026-10-01 Schedule 1 (C5, Q2); FD-2026-09-03 item D4 and FD-2026-09-04 item 6 (each recorded in the decision register as attested by the founder, with no executed copy filed); FDP-2026-001 C2 and C5. Decided by: the Governing Board on adoption of the suite; the appointment itself is reserved to the Board (FD-2026-09-04 item 6). Comments are invited on the interim arrangement, including how a single appointee sits with the minimum of three persons in cl. 10.3 and with the temporary panel of three in MCC-700 v2.0 §12.3.4 (cl. 10.4), and on C5's placing the transitional exercise of each body's functions with the Governing Board, whereas clauses 22.2 and 22.3 of this Procedure, following MCC-700 v4.0-draft cl. 23.2, place it with the founder.

8. Clause 12.10 — an appeal held open for a long period. Proposed: no choice is proposed between the two courses the clause sets out — reconsideration afresh by the respondent body at first instance once a decision has been held under cl. 12.4 for a stated period, or continuation of the hold — because, as the clause records, neither is comfortable. If reconsideration is chosen, the period proposed is 180 calendar days from the filing of the appeal. Basis: cl. 12.10 as drafted; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on which course the Programme should take, and on the period.

9. Clause 13.8 — the independent recipient of protected disclosures. Proposed: the external appointee proposed at question 7, or external counsel — never the founder. The same proposal is made for the independent complaints function on which cll. 4.7 and 20.8 rely. None is appointed. Basis: FD-2026-10-01 Schedule 1 (Q5, Q6); FDP-2026-001 Q5 and Q6; MCC-700 v4.0-draft cl. 6.3. Decided by: the Governing Board on adoption of the suite; the designation is an appointment, and FD-2026-10-01 makes none (item 6). Comments are invited on whether the recipient should be the appeals appointee or separate external counsel.

10. Clause 16.3 — the test for an interim order. Proposed: an interim order is granted only where the appellant shows both an arguable case that the decision is likely to be disturbed and that the harm to the appellant from the decision taking effect outweighs the harm to Programme integrity from suspending it — the two-limb test of MCC-700 v2.0 §9.6.1, the only test the corpus has ever stated. Basis: cl. 16.3 as drafted; MCC-700 v2.0 §9.6.1; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the test should be confirmed.

11. Clause 19.4 — appeal fee. Proposed: no appeal fee is charged, because a grievance is free (MCC-ESS v1.0 cl. 0107), a complaint is free (MCC-700 v4.0-draft cl. 13.2), and a fee that deters a vexatious appeal deters an affected community first. If a fee is adopted, it is set in the Fee Schedule, refunded on reversal (MCC-700 v2.0 §9.7.2) and waived for project-affected persons and communities. Basis: cl. 19.4 as drafted; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to the Board (FD-2026-09-04 item 6; FD-2026-10-01 item 6). Comments are invited on whether any fee should be charged for an appeal.

12. Clause 20.6 — governing law, seat and rules for recourse beyond the Programme. Proposed: Norwegian law, UNCITRAL rules and a seat in London, for the participant agreements to which MCC-700 v4.0-draft cl. 12.10 refers. The proposal depends on the incorporation of the Programme's legal entity, which has not yet taken place, and is subject to the legal review required before adoption, which has not been obtained (Evidence Register ER-2026-001 §B5). Basis: FD-2026-10-01 item 3 and Schedule 1 (C1, Q9); FDP-2026-001 Q9. Decided by: the Governing Board on adoption of the suite; the name and jurisdiction of the entity are reserved to the Board (FD-2026-09-04 item 6). Comments are invited on the proposed law, seat and rules.

13. Clause 24.2 — entry into force ahead of the suite. Proposed: this Procedure may be brought into force earlier, attached to MCC-700 v3.1 as the Programme's register records it (cl. 23.3), so that an appellant has a written route before the rewritten suite completes, because a procedure that operates only when someone appeals costs nothing while nobody does. Basis: cl. 24.2 as drafted; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite, unless it decides earlier, under cl. 24.2, to bring this Procedure into force ahead of the suite. Comments are invited on whether this Procedure should take effect before the suite, which FD-2026-10-01 Schedule 1 (C4) proposes to adopt as one instrument when the longest consultation period has closed.

14. Clause 25.3 — one standard of review. Proposed: the split in MCC-700 v4.0-draft cll. 12.5 and 12.6 — de novo for refusals, suspensions and revocations affecting a participant; process review for methodology approvals and other standard-setting decisions — is the single standard of review (Section 14), and MCC-700 v2.0 §9.4.3 and MCC-700 v3.0/v3.1 cl. 15.6 are superseded expressly rather than by implication. Basis: Section 14 and cl. 25.3 as drafted; Annex A, OD-APP-10; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether this split is the right single standard.

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1. Purpose, scope and application

1.1 This Procedure SHALL establish how an appeal against a Programme decision is made, registered, heard and decided, and what follows from it.

1.2 This Procedure gives operational effect to appeal rights conferred elsewhere. It SHALL NOT be read as conferring, extending, restricting or removing any right of appeal.

1.3 This Procedure SHALL apply to every appeal against a decision of the MCC Programme, by whichever body or function the decision was taken, and to every person on whom an instrument of the Programme confers a right to appeal it.

1.4 This Procedure gives effect to the appeal rights stated in MCC-700 v3.0/v3.1 Section 15 and, on its approval, MCC-700 v4.0-draft Sections 11 and 12, together with the decision-type appeal routes in MCC-700 v4.0-draft Annex A and the transition appealability column of Annex B.

1.5 What the record says of their commencement. MCC-700 v3.0/v3.1 cl. 18.1 provides that the Framework "shall enter into force upon approval by the Governing Board on [Date to be inserted]"; the date was never inserted, and no approving instrument is recorded. MCC-700 v3.1, which the document register records as in force (FD-2026-08-24 item D11), therefore has no recorded commencement date (cl. 23.3). MCC-700 v4.0 is a consultation draft whose own control block reads "None. This document is not in force." No appeal has been filed under either (cl. 23.7). This Procedure states that plainly and does not assert that any person has been denied a right they held.

1.6 MCC-700 v2.0 Section 9 is a complete appeals procedure and its text exists (cl. 23.2). No record of its adoption exists either. Its own cl. 12.1 required adoption "by a two-thirds majority vote of the total membership" of a Governing Board that was not constituted until 26 August 2026. This Procedure therefore treats MCC-700 v2.0 as evidence of what the Programme intended, and as a drafting source, and not as an instrument in force.

1.7 Where this Procedure refers to a governance body that has not been constituted, the reference takes effect on that body's constitution. Nothing in this Procedure imposes a duty on, or asserts the existence of, a body that does not exist.

1.8 This Procedure SHALL be free of charge to use to the extent Section 19 provides, and SHALL be capable of being used by a person without legal representation.

2. Relationship to other instruments

2.1 MCC-700 prevails. Where this Procedure conflicts with MCC-700, MCC-700 prevails. Where it conflicts with MCC-001, MCC-001 prevails. This Procedure states no decision threshold, no quorum and no decision owner; those are fixed exclusively in MCC-700 Annex A (MCC-700 v4.0-draft cl. 8.2).

2.2 What is appealable is fixed elsewhere. The list of appealable decisions is that of MCC-700 v3.0/v3.1 cl. 15.2 and, on approval, MCC-700 v4.0-draft Annex A ("App" column) and Annex B ("Appealable?" column). Section 5 reproduces those lists for the reader's convenience and SHALL NOT be read as adding to or subtracting from them; where Section 5 and the source diverge, the source governs.

2.3 The two-stage structure is MCC-700's. MCC-700 v4.0-draft separates independent review (Section 11 — reconsideration within the same institutional level by persons who took no part) from appeal (Section 12 — to a separate body). This Procedure governs both, states them separately, and does not merge them. Independent review SHALL NOT be a precondition to appeal (cl. 11.4 of that draft).

2.4 VVB matters. MCC-400 v2.0-draft cl. 1.4 reserves VVB "competence, impartiality, insurance, sampling independence, rotation, cooling-off and oversight" exclusively to that Standard. This Procedure respects that reservation absolutely and states no VVB impartiality, rotation or cooling-off rule. It does state the procedure for an appeal against a VVB recognition, scope, sanction, suspension, withdrawal or renewal decision, because MCC-400 does not reserve those appeals — it refers them out: v2.0-draft cl. 3.4 to "MCC-700 Sections 11 and 12 … heard de novo by the Independent Appeals Panel (MCC-700 clause 12.5 and Annex A row 6)", and the in-force v1.1 to "the procedures of MCC-700" at art. 30 (denial) and art. 76 (suspension and withdrawal). Whether a VVB's conduct breached an impartiality rule is determined under MCC-400; how the resulting decision is challenged is determined here.

2.5 The registry. Nothing in this Procedure creates any power over the registry ledger. Section 17 states what an appeal cannot do to an issued, transferred, retired or cancelled unit, and refers the reader to the mechanisms that can.

2.6 Constitutional reservation. MCC-001 v3.0-draft cl. 9.10.3 provides that "the detailed governance procedures, thresholds and appeal mechanics SHALL be set in the Tier 2 governance document (MCC-700)". This Procedure is drafted as subordinate operational detail and adds no mechanic that MCC-700 does not authorise. Whether this text should be adopted as a free-standing Tier 3 procedure, or as a numbered annex to MCC-700 v4.0 so that cl. 9.10.3 is satisfied on its face, is put to consultation. The drafting proposal is a free-standing procedure cross-referenced from MCC-700 Section 12; it is not decided, and the choice changes nothing in the substance below. (Consultation question 1.)

2.7 Participant agreements. Applicant Terms v1.1 art. 10.3 and VVB Terms v1.1 art. 5.2 each state an appeal route of their own, and neither matches MCC-700 (cl. 25.7). Where a participant agreement and this Procedure both apply to the same challenge, the Programme SHALL apply whichever gives the appellant the longer period and the more independent forum, and SHALL record which was applied. Whether the participant agreements are instead conformed to MCC-700 by amendment, which is the cleaner answer and requires a decision this Procedure cannot take, is put to consultation. (Consultation question 2.)

2.8 Forms. No form for a notice of appeal exists. The operational forms suite runs MCC-FORM-001 to MCC-FORM-013 and contains none. Section 8 therefore states the required content of a notice of appeal directly. Whether that content is issued as MCC-FORM-014 (Notice of Appeal) and added to the Forms Suite — at which point Section 8 SHALL be replaced by a reference to it and SHALL NOT restate its fields — is put to consultation. The Programme Bible's numbering skips 009, 011 and 012; this Procedure does not claim those numbers. (Consultation question 3.)

3. Definitions

3.1 "First-instance decision" means the initial determination of a matter by the body or function designated for it, before any review or appeal (MCC-700 v4.0-draft cl. 3.2.1).

3.2 "Independent review" means reconsideration of a first-instance decision by persons who took no part in it, within the same institutional level (MCC-700 v4.0-draft cl. 3.2.2).

3.3 "Appeal" means a challenge to a decision brought before an appellate body under Section 10 (MCC-700 v4.0-draft cl. 3.2.3).

3.4 "Complaint" means an allegation concerning the conduct, service or integrity of MCC itself or of a governance body. A complaint is not an appeal (MCC-700 v4.0-draft cl. 3.2.4).

3.5 "Grievance" means a concern raised by a project-affected person or community under the grievance mechanism of the Environmental and Social Safeguards Policy. A grievance is not an appeal (MCC-700 v4.0-draft cl. 3.2.5; Section 4 below).

3.6 "Appellant" means the person who files an appeal.

3.7 "Respondent body" means the body or function that took the decision appealed against, whether or not it is constituted at the time of the appeal.

3.8 "Appellate body" means the body competent to decide the appeal under Section 10.

3.9 "Independent" carries the meaning of MCC-700 v4.0-draft cl. 3.2.6 on that Standard's approval; until then, the meaning in the Definitions Register. That clause now proposes 36 months for its own look-back (MCC-700 v4.0-draft consultation question 2); MCC-ROI v1.0-draft cl. 3.6 proposes 36 months for both, and this Procedure adopts whatever figure resolves that open item rather than proposing a third. (Consultation question 4.)

3.10 "Recusal" means withdrawal from both deliberation and decision on a matter, as distinct from abstention, which is a vote cast (MCC-ROI v1.0-draft cll. 3.7, 11.2).

3.11 "De novo" means full reconsideration of fact and rule-application on the record before the appellate body, with power to admit new evidence (MCC-700 v4.0-draft cl. 12.5).

3.12 "Business day" means a day other than a Saturday, Sunday or a day published in advance on the Programme's public calendar as a non-working day. Where an instrument states a period in calendar days, this Procedure does not convert it.

3.13 "The Appeals Register" means the register constituted by Section 21.

4. Appeal, review, complaint and grievance: where the boundary runs

4.1 The distinguishing question is what the person is asking to be changed. An appeal asks that a decision of the Programme be changed. A grievance asks that a harm be investigated and remedied. A complaint asks that MCC's own conduct be examined. The three are separate channels and SHALL NOT be collapsed into one another (MCC-001 v3.0-draft cl. 9.9.8; MCC-700 v4.0-draft cll. 13.1, 14.1).

4.2 A grievance is not an appeal. A grievance is raised by a project-affected person or community about a project's conduct, impacts or its own grievance mechanism, under the Environmental and Social Safeguards Policy — at project level in the first instance (MCC-ESS v1.0 cll. 0106 to 0113; MCC-ESS v2.0-draft cl. 20.3), escalatable to the Programme-level channel where the project mechanism failed or the concern is with the Programme (MCC-ESS v1.0 cl. 0111; v2.0-draft cl. 20.8). It requires no Programme decision to exist, and it is available to a person on whom no instrument confers a right of appeal.

4.3 An appeal is not a grievance. An appeal requires an identified decision, a person materially affected by it, and a ground on which it is said to be wrong. It is not an investigation of a harm, and the appellate body has no investigatory mandate beyond the appeal before it (cl. 15.6).

4.4 The boundary is crossed at the point a grievance produces a decision. A grievance outcome that is itself a Programme decision — a suspension, the imposition of conditions, a remedy determination, a refusal to act — carries the review and appeal rights of MCC-700 Sections 11 and 12 (MCC-700 v4.0-draft cl. 14.4; MCC-ESS v2.0-draft cll. 20.9, 22.7). At that point, and only at that point, this Procedure applies to it.

4.5 A grievance SHALL NOT be re-characterised as an appeal in order to bring it within a time limit, and an appeal SHALL NOT be re-characterised as a grievance in order to avoid one. Where a filing is capable of being either, the Programme SHALL treat it as both, register it in both registers, and tell the filer in writing that it has done so and what each route will do.

4.6 Filing a grievance SHALL NOT extend the period for appealing a decision (Section 7), and SHALL NOT be a precondition to appealing one. Filing an appeal SHALL NOT stop, pause or narrow a grievance investigation, and SHALL NOT relieve any person of a remedy obligation (MCC-ESS v2.0-draft cl. 22.5).

4.7 A complaint is neither. An allegation about MCC's conduct, service, staff or governance-body integrity is a complaint under MCC-700 v4.0-draft Section 13, receivable from any person without fee, investigated by a function independent of its subject. A complaint SHALL NOT be used to reopen a decision that could have been appealed, and an appeal SHALL NOT be refused on the ground that the appellant has also complained.

4.8 Independent review sits inside the appeal channel, not beside it. A person materially affected by a first-instance decision MAY request independent review within thirty calendar days (MCC-700 v4.0-draft cl. 11.1). Review is optional, is not a precondition to appeal (cl. 11.4), and a person who conducted a review SHALL NOT take part in any appeal of the same matter (cl. 11.5). Where review is requested, the appeal period runs from notice of the review outcome (cl. 7.2 below).

4.9 The Programme SHALL publish, on the same public page, a plain statement of the four channels and what each is for, and SHALL NOT title a page or a form in a way that merges them. The page presently at /grievances is titled "Grievances and appeals" and offers a grievance form only; on entry into force of this Procedure that page SHALL either carry an appeal route or SHALL cease to name appeals in its title (cl. 24.3(d)).

5. What may be appealed, and by whom

5.1 A person materially affected by an appealable decision MAY appeal it. Materially affected persons include project developers, VVBs, host country governments, project-affected communities, and other persons demonstrating a material interest (MCC-700 v3.0/v3.1 cl. 15.1; v4.0-draft cl. 12.1).

5.2 A person is materially affected where the decision directly alters that person's rights, obligations or legitimate expectations within the Programme (MCC-700 v2.0 §9.2.1, adopted here as the test because no instrument in the current suite supplies one). The test is put to consultation for confirmation, or substitution of another, at approval. (Consultation question 5.)

5.3 A community or group MAY appeal through a representative, and the appellate body SHALL NOT refuse an appeal for want of a formal representative mandate where the representative's authority is evidenced in the manner the community itself uses.

5.4 An appeal MAY be made by a person acting anonymously only where the appellate body can nevertheless verify material effect; where it cannot, the appeal SHALL be registered and referred to the grievance or complaints channel, which accept anonymous filings (MCC-ESS v1.0 cl. 0109; MCC-700 v4.0-draft cl. 13.2), and the appellant SHALL be told this in writing.

5.5 The decisions listed as appealable in MCC-700 v3.0/v3.1 cl. 15.2 are: project registration rejection; safeguards clearance denial; credit issuance reduction or denial; project suspension or revocation; VVB accreditation rejection or revocation; and methodology approval rejection.

5.6 On approval of MCC-700 v4.0, the appealable decisions are those marked in the "App" column of Annex A and the "Appealable?" column of Annex B. They include, in addition to cl. 5.5: standard adoption and amendment; methodology status change and minor revision; VVB recognition, scope, suspension and revocation; safeguards category assignment and screening refusal; adverse technical determinations; governance-review and registration refusals; urgent-harm suspensions and their confirmation; refusal of reinstatement; every enforcement measure under MCC-100 Section 23 including cancellation of specifically affected units; reversal determinations and replenishment liability; registry account suspension; SD-label certification; and refusal to accept equivalent replenishment units.

5.7 A decision supported by an AI system carries, on review or appeal, an entitlement to human re-examination independent of the AI system and to the reasons in human-readable form (MCC-700 v3.0/v3.1 cl. 16.2; v4.0-draft cl. 20.5; MCC-100 cl. 0272; MCC-100 v3.0-draft cl. 22.7). An appellant MAY take that entitlement as a ground of appeal in its own right.

5.8 A refusal at any pre-registration stage carries appeal rights whether or not the project was advanced through the remaining stages first (MCC-100 Amendment 1 cl. 0057.1, in force).

6. What may not be appealed

6.1 The following are not appealable, and an appeal against one SHALL be registered and then rejected as inadmissible with written reasons: a return for revisions, which is not a rejection and carries a resubmission right (MCC-700 v4.0-draft Annex B row T15; MCC-100 v3.0-draft cl. 13.10); a completeness rejection, which returns the file for resubmission (Annex B row T2); a withdrawal, being the developer's own act (row T14); and a purely administrative transition (rows T1, T8, T12).

6.2 A decision of the appellate body itself is not appealable (MCC-700 v2.0 §9.2.3(d); cl. 20.5 below).

6.3 An informative flag, score, tier or prioritisation output is not a decision and is not appealable; it confers nothing and alters nothing (MCC-100 Amendment 1 cll. 0061.1, 0061.2). Where such an output is said to have influenced a decision, that is a ground of appeal against the decision, not an appeal against the output.

6.4 Whether the exclusions of MCC-700 v2.0 §9.2.3(a) to (c) — Charter amendments, the annual budget, and internal administrative matters not directly affecting participants — are adopted is put to consultation. The drafting proposal is that they are, because a general-application rule is challenged through the consultation and amendment process rather than by appeal, and because Annex A already marks rows 1, 17, 18 and 33 with no appeal route. It is not decided. (Consultation question 6.)

6.5 Nothing in this Section restricts access to any judicial or administrative remedy, and use of this Procedure SHALL NOT be a precondition to such access (MCC-ESS v2.0-draft cl. 20.13, applied here by analogy).

7. Time limits binding the appellant

7.1 An appeal SHALL be filed within thirty calendar days of notice of the decision (MCC-700 v3.0/v3.1 cl. 15.3; v4.0-draft cl. 12.2; MCC-100 cl. 0291; MCC-400 v1.1 art. 30 as implemented on the public accreditation page).

7.2 Where independent review was requested, the thirty days run from notice of the review outcome and not from the original decision (MCC-700 v4.0-draft cl. 12.2).

7.3 The period runs from the date the appellant received written notice, not the date the decision was taken. Where the Programme cannot evidence the date of receipt, the period SHALL be taken to run from the date of the first communication the appellant acknowledges.

7.4 A decision notice that does not state the available review and appeal routes and their deadlines does not start the period (MCC-700 v4.0-draft cl. 10.4). Where a notice omits them, the period runs from the date a conforming notice is given.

7.5 The appellate body MAY extend the period by not more than fifteen calendar days on written request showing good cause (MCC-700 v2.0 §9.3.1). A request for an extension SHALL be decided within five business days and SHALL NOT itself consume the period.

7.6 Where no appellate body exists to decide an extension request, the request SHALL be granted and recorded (cl. 12.4). A person SHALL NOT lose an appeal right because there was nobody to ask.

7.7 An appeal filed out of time SHALL be registered, and its admissibility determined under cl. 9.4; late filing SHALL NOT be a ground for refusing to register it.

8. How an appeal is made

8.1 An appeal SHALL be made in writing, by any means the Programme publishes for the purpose, including the registry platform, email and post, and SHALL be accepted in any of the Programme's published working languages.

8.2 A notice of appeal SHALL state:

8.2(a) the appellant's name and contact details, and the capacity in which the appeal is brought;

8.2(b) the decision appealed against, identified by its date, its reference and the body or function that took it;

8.2(c) how the appellant is materially affected by it;

8.2(d) the grounds of appeal, addressing each ground of the decision separately where the decision stated its grounds separately (MCC-700 v4.0-draft cl. 10.5);

8.2(e) the evidence relied on, and whether any of it was before the original decision-maker;

8.2(f) the remedy sought (MCC-700 v3.0/v3.1 cl. 15.3; v4.0-draft cl. 12.2; v2.0 §9.3.2); and

8.2(g) whether the appellant requests an interim order under Section 16, and if so on what basis.

8.3 A notice that omits an item in cl. 8.2 SHALL NOT be rejected. The Programme SHALL register it, identify the omissions in writing within five business days, and allow not fewer than fourteen calendar days to supply them; the appeal is treated as filed on the date of the original notice.

8.4 An appellant SHALL NOT be required to use a particular form, template or format while none is published (cl. 2.8).

8.5 An appellant MAY be represented, or unrepresented, and SHALL NOT be disadvantaged in the conduct of the appeal by being unrepresented.

8.6 The Programme SHALL, on request and without charge, supply the appellant with the decision record, the reasons, the evidence relied on and the clause references, so far as they are not lawfully withheld (MCC-700 v3.0/v3.1 cl. 14.3; v4.0-draft cl. 10.4). Where a document is withheld, the fact of withholding and the ground SHALL be stated.

9. Registration, acknowledgement and admissibility

9.1 Every appeal SHALL be entered in the Appeals Register on receipt, with a reference issued to the appellant, whether or not it is admissible and whether or not an appellate body exists.

9.2 Receipt SHALL be acknowledged in writing within five business days (MCC-700 v3.0/v3.1 cl. 15.3; v4.0-draft cl. 12.3).

9.3 The acknowledgement SHALL state the reference, what happens next, the applicable time limits binding the Programme, and — where cl. 12.1 applies — that no appellate body is presently constituted and what that means for the appellant.

9.4 Admissibility SHALL be determined within ten business days of a complete notice, on three questions only: whether the appellant is eligible, whether the appeal is in time, and whether the decision is appealable (MCC-700 v2.0 §9.4.1(b)). Admissibility SHALL NOT be determined on the merits.

9.5 An admissibility determination SHALL be given in writing with reasons, and is itself a first-instance decision within cl. 3.1 carrying independent review under MCC-700 v4.0-draft Section 11. It SHALL NOT be determined by any person who took the decision appealed against.

9.6 Where no appellate body exists, admissibility SHALL NOT be determined by the respondent body or by the founder in respect of a decision the founder took (cl. 12.3). It SHALL be held, with the appeal, under Section 12.

9.7 An inadmissible appeal SHALL be recorded as inadmissible with the ground stated, and the appellant SHALL be told which other channel, if any, is open (Section 4).

10. Who hears an appeal: the independence requirement

10.1 An appeal decided by the person who took the decision is not an appeal. No person SHALL take part in an appeal, or in an independent review, of a decision in which that person took part at first instance, in any capacity (MCC-700 v2.0 §2.1.2; v4.0-draft cll. 4.10.2, 5.2, 11.2, 12.4; MCC-001 v3.0-draft cll. 9.9.6, 9.9.8; MCC-100 v3.0-draft cl. 23.6). This prohibition admits no exception by disclosure, by consent, by urgency, or by the absence of anyone else.

10.2 A person who conducted an independent review SHALL NOT take part in any appeal of the same matter (MCC-700 v4.0-draft cl. 11.5).

10.3 The minimum composition of an appellate body. An appeal SHALL be heard by not fewer than three persons, of whom:

10.3(a) none took part in the first-instance decision or its independent review;

10.3(b) a majority are independent within cl. 3.9;

10.3(c) the chair is independent and derives no income from the sale, brokerage or development of carbon or marine outcome credits (MCC-700 v4.0-draft cl. 3.2.7); and

10.3(d) at least one has adjudicative, legal or dispute-resolution competence (MCC-700 v2.0 §9.1.2; v3.0/v3.1 cl. 4.4.2, which reserves two of seven seats to independent legal or regulatory experts and one to a mediator).

10.4 The figure of three is not invented here. It is the figure of MCC-700 v2.0 §9.1.1 ("three members appointed by the Governing Board"), of its transitional rule at §12.3.4 ("a temporary panel of three independent persons"), and of the Programme Bible's Level 1 Appeals Panel ("3 members", majority 2 of 3). Every instrument in the corpus that has ever stated a number for an appellate panel has stated three. It is also the smallest number that is odd, that exceeds the quorum floor of two in MCC-ROI v1.0-draft cl. 11.10, and that can produce a majority without a casting vote — which matters, because MCC-700 v4.0-draft cl. 7.5 and MCC-001 v3.0-draft cl. 9.8.5 both provide that a tied vote fails and that no chair holds a casting vote.

10.5 A panel of two SHALL NOT hear an appeal. On a tie the motion fails, and an appeal that fails for want of a majority is not a decision on the appeal; it is the appellant being told nothing, at the end of the process. The floor in cl. 10.3 is therefore three and not two, and this is the single point at which this Procedure sets a higher floor than MCC-ROI cl. 11.10 — which fixes the minimum for an ordinary decision, not for an adjudication.

10.6 An appellate body MAY draw its members from an external roster of qualified persons (MCC-700 v4.0-draft cl. 4.10.3; MCC-001 v3.0-draft cl. 9.9.7). A member drawn from a roster is subject to Section 11 and to the Register of Interests on the same terms as an appointed member (MCC-ROI v1.0-draft cl. 4.6, which records the same question as open).

10.7 The Governing Board SHALL NOT sit as an appellate body while it has fewer than three appointed members. This follows from cl. 10.3 and from MCC-ROI v1.0-draft cl. 11.17, and it is stated here so that it need not be derived at the meeting.

10.8 The Programme Secretariat SHALL NOT decide, influence or hold any approval power over an appeal (MCC-001 v3.0-draft cl. 9.7.2; MCC-400 v2.0-draft cl. 3.2). It SHALL administer appeals — receiving them, maintaining the Register, servicing the appellate body — and nothing more.

10.9 No appeal SHALL be decided, in whole or in part, by an AI system, and no AI output SHALL stand as a reason for an appellate decision (MCC-700 v3.0/v3.1 cl. 16.1; v4.0-draft cl. 20.1; Programme Bible Tier 3 "Human Only": appeals).

10.10 Which body. On approval of MCC-700 v4.0, the appellate body is the Independent Appeals Panel (cl. 4.10.1, Annex A "App" column). Until then, the instruments the document register records as in force name the Review and Appeals Authority of MCC-700 v3.1 (cl. 4.4) and the Appeal Officer of MCC-100 (cl. 0292), neither of which has an appointee, and give appeals or a final appeal to the Board (MCC-700 v3.1 cl. 15.4; MCC-100 cl. 0292; Applicant Terms art. 10.3; VVB Terms art. 5.2), which cannot hear an appeal from a decision it took at first instance (FD-2026-09-04 item 6). Section 12 states what happens in the meantime; it does not name a body, because naming one would not constitute it.

11. Recusal, quorum and the two-member Board

11.1 This Section is consistent with, and does not compete with, MCC-ROI v1.0-draft cll. 11.10 and 11.14 to 11.18. Where the two texts touch the same question, MCC-ROI states the rule and this Section states its application to an appeal.

11.2 Recusal, not abstention. Where a member of any body holds an interest screened as a conflict on an appeal, that member SHALL recuse — withdraw from deliberation and decision — and SHALL NOT merely abstain (MCC-ROI v1.0-draft cl. 11.2). MCC-700 v3.0/v3.1 cl. 12.1 offers abstention as a response to a conflict and cl. 13.2 requires recusal; the contradiction is recorded at cl. 25.1 and resolved here as MCC-ROI resolves it, in favour of recusal.

11.3 The contradiction bites hardest here. An abstention leaves a conflicted member in the room, in receipt of the papers, and counted in the quorum, while the body decides whether the decision that member took was wrong. On an appeal there is no reading on which that is adequate.

11.4 A recused member SHALL NOT be counted in the quorum for the appeal, and quorum SHALL be recalculated on the members entitled to vote (MCC-700 v4.0-draft cl. 5.7; MCC-001 v3.0-draft cl. 9.8.7; MCC-ROI v1.0-draft cl. 11.5), subject to the floors in cl. 10.3 and MCC-ROI cl. 11.10.

11.5 A decision on an appeal taken with a recused member counted in the quorum, present in the deliberation, or voting, is invalid and SHALL be retaken; invalidity is not cured by that member's vote having been immaterial (MCC-ROI v1.0-draft cl. 11.6).

11.6 The two-member Board. The Governing Board has two members. Where the Board is asked to hear an appeal against a decision one of them took, that member recuses under cl. 10.1, one member remains, and the Board is inquorate for the item under MCC-ROI v1.0-draft cl. 11.10 and cl. 10.3 above. The consequence is not that the remaining member decides alone. The consequence is that the Board does not decide.

11.7 Where cl. 11.6 applies, the ladder in MCC-ROI v1.0-draft cl. 11.14 SHALL be applied in order, and which limb was applied SHALL be recorded:

11.7(a) defer the appeal to a sitting at which three or more persons are entitled to decide it;

11.7(b) cure by appointment, by appointing further members through the ordinary nomination and fit-and-proper process (MCC-700 v4.0-draft cl. 6.1), the appointment not being made by the recused member; or

11.7(c) refer out, to one or more independent persons who took no part in the matter and hold no interest in it, appointed from an external roster — the mechanism MCC-700 v4.0-draft cl. 23.7 establishes for transitional appeals. No roster exists. The administration proposes, as the interim arrangement, one external appointee on a roster basis, paid per matter, required before the first appeal is heard; none is appointed (FD-2026-10-01 Schedule 1, Q2). This is the same point as MCC-700 v4.0-draft cl. 23.7 and MCC-ROI v1.0-draft cl. 11.14(c); until an appointment is made this limb is unavailable and cl. 12 applies. (Consultation question 7.)

11.8 Where none of cl. 11.7(a) to (c) is available, the appeal is not decided, and is recorded and published as "not decided — no independent forum", with the appeal reference, the date and the reason (MCC-ROI v1.0-draft cl. 11.15). Section 12 states what follows for the appellant.

11.9 There is no urgency exception. A conflicted person SHALL NOT resume an appeal on the ground that nobody else can hear it, SHALL NOT waive his or her own conflict, and SHALL NOT be authorised to hear it by any resolution of a body, by a chair, or by his or her own decision under transitional authority (MCC-ROI v1.0-draft cl. 11.16; MCC-700 v4.0-draft cl. 23.7, first sentence). An undecided appeal is a cost the Programme bears; an appeal decided by the person it concerns is a defect the Programme cannot cure.

11.10 Every member of an appellate body SHALL declare interests and be screened under MCC-ROI before sitting, and SHALL declare at the opening of each appeal whether any interest arises on it (MCC-ROI v1.0-draft cll. 5.1, 5.4). A member who has not filed and had screened a declaration SHALL NOT sit.

12. What happens to an appeal filed before an appellate body exists

12.1 On the date of this draft, no appeal against a decision of the Programme can be heard. No appellate body named in any instrument of the Programme has an appointee; the founder may not hear an appeal against a decision the founder took (MCC-700 v4.0-draft cl. 23.7); the Governing Board of two is inquorate for such an appeal (cl. 11.6); and the external roster that would supply an independent decision-maker has not been designated. This Section states what the Programme does with an appeal in that condition. It does not pretend a body exists.

12.2 An appeal filed while no appellate body is competent to hear it SHALL be registered, acknowledged and held open. It SHALL NOT be rejected, dismissed, deemed withdrawn, or treated as lapsed by the passage of time.

12.3 The appeal SHALL NOT be decided by the respondent body, by any person who took the decision appealed against, or by the founder in respect of a decision the founder took (MCC-700 v4.0-draft cl. 23.7).

12.4 While an appeal is held open under cl. 12.2:

12.4(a) the decision appealed against SHALL NOT be implemented further;

12.4(b) no issuance, transfer or retirement SHALL rely on it; and

12.4(c) no step SHALL be taken in reliance on it that would be difficult or impossible to reverse if the appeal succeeded.

Clauses 12.4(a) and (b) are the consequence MCC-700 v4.0-draft cl. 23.7 itself supplies for exactly this case, and are adopted verbatim in substance rather than replaced by a new rule.

12.5 Clause 12.4 does not reverse what has already happened, does not restore a state that has passed, and does not lift an urgent-harm stop-work or suspension, which stands pending decision (MCC-700 v4.0-draft Annex B row T9; MCC-ESS v2.0-draft cl. 21.7). It stops the decision going further; it does not undo it.

12.6 The appellant SHALL be told, in writing, at acknowledgement: that no appellate body is presently constituted; that the appeal is held open and not refused; what cl. 12.4 means for the decision in the meantime; and the date by which the Programme expects a body to be available, or that no such date can yet be given.

12.7 The Programme SHALL report to the appellant in writing every sixty calendar days for as long as the appeal is held open, whether or not there is anything to report.

12.8 The number of appeals held open under this Section, and the age of the oldest, SHALL be published in the quarterly transparency report and on the public appeals page, whether or not the number is nil (cl. 21.6).

12.9 The cure is appointment, not procedure. The Programme SHALL constitute an appellate body meeting cl. 10.3, or designate the external roster of cl. 11.7(c), and until it does so this Section operates. The appointment is reserved to the Governing Board (FD-2026-09-04 item 6); the interim arrangement proposed is the one at cl. 11.7(c), and no appointment has been made. (Consultation question 7.)

12.10 Whether a decision that is held under cl. 12.4 for more than a stated period — the drafting proposal is 180 calendar days from the filing of the appeal — SHALL be reconsidered afresh by the respondent body at first instance, so that a person is not left indefinitely with a decision that neither takes effect nor is reviewed, is put to consultation. The alternative is that the hold simply continues. Neither is comfortable; the Board should choose which discomfort it prefers, and say so. (Consultation question 8.)

12.11 This Section lapses for each class of appeal on the constitution of a body competent to hear it, and in whole when an appellate body meeting cl. 10.3 is constituted (MCC-700 v4.0-draft cl. 23.5).

13. Conduct of an appeal

13.1 The appellate body SHALL notify the respondent body of the appeal and SHALL require its written response within fifteen business days, with the decision record and the evidence relied on (MCC-700 v2.0 §9.4.1(c)).

13.2 Both parties SHALL have an opportunity to make written submissions, and to see and answer what the other has said. Nothing SHALL be put before the appellate body that a party has not had the opportunity to answer, save where it is lawfully withheld, in which case the fact and the ground SHALL be disclosed.

13.3 The appellate body MAY hear oral representations where it considers it appropriate, and SHALL do so where the appeal turns on a disputed question of fact that written submissions cannot resolve (MCC-700 v2.0 §9.4.1(e)).

13.4 The appellate body MAY request further information from either party or from any body of the Programme, and MAY commission independent expert advice where the appeal raises a technical question it is not competent to resolve alone (MCC-700 v2.0 §9.4.2). Expert advice obtained SHALL be disclosed to both parties before it is relied on.

13.5 An appeal SHALL be conducted in a language the appellant can use, with interpretation or translation provided at the Programme's cost where necessary; cost SHALL NOT be a reason to conduct an appeal in a language the appellant does not use.

13.6 The appellate body SHALL close submissions on a stated date, notified to both parties, from which the decision period in cl. 18.2 runs.

13.7 An appellant MAY withdraw an appeal at any time in writing; the withdrawal SHALL be recorded, and the hold under cl. 12.4 ends on the date of withdrawal.

13.8 No person SHALL be subjected to retaliation for filing, supporting or taking part in an appeal. A credible allegation of retaliation SHALL be handled under the whistleblowing arrangements required by MCC-700 v4.0-draft cl. 6.3 and, where it concerns a project, as a grievance with urgent-harm triage (MCC-ESS v1.0 cl. 0123; v2.0-draft cl. 20.10). The administration proposes that the independent recipient of protected disclosures be the external appointee proposed at cl. 11.7(c), or external counsel, and never the founder; none is appointed (FD-2026-10-01 Schedule 1, Q5). This is the same point as MCC-700 v4.0-draft cl. 6.3 and MCC-ROI v1.0-draft cl. 12.6. (Consultation question 9.)

14. Standard of review

14.1 The standard of review SHALL be that fixed by MCC-700 for the class of decision appealed, and this Procedure sets none of its own.

14.2 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 appellate body, with power to admit new evidence (MCC-700 v4.0-draft cl. 12.5; MCC-400 v2.0-draft cl. 3.4).

14.3 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 appellate body SHALL NOT substitute its own scientific judgement, and SHALL remit a non-conforming decision for fresh determination (MCC-700 v4.0-draft cl. 12.6).

14.4 The distinction is deliberate: a refusal that affects one participant is reconsidered in full; a rule of general application is examined for whether it was properly made, because substituting one scientific view for another on appeal would make the appellate body the standard-setter (MCC-001 v3.0-draft cl. 9.9.1).

14.5 This is not the only standard the corpus states, and the conflict is recorded rather than drafted away. MCC-700 v2.0 §9.4.3 provides expressly that "the Appeals Body shall not conduct a de novo review", applying instead a four-limb test of procedural conformity, evidential adequacy, reasonableness and freedom from material procedural irregularity. MCC-700 v3.0/v3.1 cl. 15.6 makes the second-level appeal a review "on record (limited to evidence already presented)". The successor draft reverses both for participant-affecting decisions. See cl. 25.3.

14.6 Where an appeal is heard de novo and the appellate body admits evidence that was not before the original decision-maker, it SHALL record what was admitted and why, and SHALL consider whether the correct course is to remit rather than to substitute its own decision (cl. 15.3).

15. Powers on appeal

15.1 On determining an appeal the appellate body SHALL do one of the following, and SHALL say which:

15.1(a) uphold the decision, leaving it in effect;

15.1(b) vary the decision, substituting its own determination in whole or in part, where the appeal was heard de novo under cl. 14.2;

15.1(c) remit the decision to the respondent body for fresh determination, with directions as to what SHALL be reconsidered and by when; or

15.1(d) quash the decision, so that it is of no effect from a stated date and the matter stands as it stood before it was taken.

15.2 Clause 15.1 states in four words the three outcomes MCC-700 states in three — "uphold, overturn or remit" (v4.0-draft cl. 12.7), "uphold, overturn, or remand" (v3.0/v3.1 cl. 15.5), "uphold, modify, or reverse" (v2.0 §9.5.1). Varying and quashing are the two things "overturn" is capable of meaning, and an appellant is entitled to know which happened to the decision.

15.3 The appellate body SHOULD remit rather than vary where the fresh material, the technical judgement required, or the identity of the proper decision-maker makes remittal the sounder course; a deviation from this recommendation SHALL be reasoned in the decision.

15.4 On a remittal the respondent body SHALL redetermine the matter within twenty business days of the appellate decision, or within any different period the appellate body specifies (MCC-700 v2.0 §9.5.3). The redetermination is a fresh first-instance decision and carries its own review and appeal rights.

15.5 A remittal SHALL NOT be redetermined by any person who took the decision remitted, and a redetermination on the same facts reaching the same result SHALL state, clause by clause, how each of the appellate body's directions was addressed.

15.6 The appellate body SHALL NOT initiate proceedings of its own motion, and SHALL NOT decide a matter that has not been the subject of a prior decision (MCC-700 v2.0 §9.5.2).

15.7 The appellate body SHALL NOT amend an instrument of the Programme, set a fee, appoint or remove a member of a body, or exercise any authority reserved to another body in MCC-700 Annex A.

15.8 The appellate body MAY find that a decision was procedurally defective without disturbing its outcome, and SHALL record such a finding where it makes one, so that the defect is corrected in later decisions of the same kind.

16. Effect of an appeal on the decision appealed against

16.1 Filing an appeal SHALL NOT of itself suspend the decision appealed against, except that no credits SHALL be issued, transferred or retired in reliance on that decision while an appeal against it is pending (MCC-700 v4.0-draft cl. 12.11).

16.2 The exception in cl. 16.1 is not discretionary and requires no application. It exists because issuance, transfer and retirement are the steps this Programme cannot take back (Section 17).

16.3 An appellant MAY apply for an interim order suspending or modifying the effect of the decision pending determination. The appellate body SHALL grant one only where the appellant shows both (a) an arguable case that the decision is likely to be disturbed, and (b) that the harm to the appellant from the decision taking effect outweighs the harm to Programme integrity from suspending it (MCC-700 v2.0 §9.6.1). This two-limb test, which is recovered from the v2.0 text and is the only test the corpus has ever stated, is put to consultation for confirmation. (Consultation question 10.)

16.4 An application for an interim order SHALL be decided within ten business days, in writing with reasons, and the reasons SHALL be published in the same terms as the eventual decision (cl. 20.4).

16.5 The Programme MAY take interim measures strictly necessary to prevent irreparable harm or to protect Programme integrity while an appeal is pending; every such measure SHALL be reasoned, notified to the parties, and reviewed as part of the appeal (MCC-700 v3.0/v3.1 cl. 15.8; v4.0-draft cl. 12.8).

16.6 An appeal SHALL NOT lift an urgent-harm stop-work order or safeguards suspension pending decision (MCC-700 v4.0-draft Annex B row T9; MCC-ESS v2.0-draft cl. 21.7). The order remains appealable, and the appeal remains a full appeal; what does not happen is automatic relief.

16.7 Where an appeal is held open under Section 12, cl. 12.4 applies in place of cl. 16.1, and is wider: the decision is not implemented further at all.

17. The registry ledger: what an appeal cannot do

17.1 No appeal creates any power over the registry ledger. An appellate body SHALL NOT direct that a ledger entry be edited or deleted, that a serial be changed or reused, that a retirement be reversed, or that an audit record be amended.

17.2 A serial, once assigned, "shall never be reused, reassigned, or modified, even if the credit is subsequently cancelled or the batch is voided" (MCC-800 v1.0 art. 30, in force).

17.3 Retirement is irreversible. "Once a credit unit has been retired, it may not be reactivated, transferred, or re-retired under any circumstances" (MCC-800 v1.0 art. 48, in force). An appeal that succeeds after retirement is answered by a published statement about the retirement and by whatever remedy is owed outside the ledger, and not in the ledger (MCC-REST v1.0-draft cl. 10.4).

17.4 The audit trail is never rewritten. "No audit record may be modified, deleted, or overwritten after creation" (MCC-800 v1.0 art. 65, in force), enforced in the database by the triggers prevent_audit_update and prevent_audit_delete. Where the audit trail records something incorrectly, the correction is a compensating entry referencing the entry it corrects (MCC-REST v1.0-draft cl. 10.6; MCC-800 v2.0-draft cl. 14.3).

17.5 Where an appeal succeeds against a decision under which units were issued that should not have been, the remedy is cancellation on a defect finding, taken by the body designated for it in MCC-700 Annex A row 24, recorded with its ground and decision reference, with a fresh issuance where the correct quantity is greater than nil (MCC-800 v1.0 arts. 51 and 52; MCC-100 v3.0-draft cl. 23.5; MCC-REST v1.0-draft cl. 10.2). The appellate body's power is to remit the question to that body with its findings; it is not to cancel.

17.6 A cancellation so directed SHALL follow the notice and due-process requirements of the Registry Operations Standard, including notification of affected holders before it takes effect (MCC-800 v2.0-draft cl. 11.5), and is itself appealable.

17.7 This Section is written before the first issuance deliberately. The registry holds no credit unit today: credit_units, retirements, credit_cancellations and issuance_requests are all empty. A rule for what an appeal may do to a unit is worth nothing if it is written after the first unit needs correcting (MCC-REST v1.0-draft cl. 10.8, adopted here by analogy).

18. Time limits binding the Programme

18.1 The Programme is bound by the following limits, each of which is a requirement of this Procedure and not an aspiration:

Step	Limit	Source
Acknowledge receipt of an appeal	5 business days	MCC-700 v3.0/v3.1 cl. 15.3; v4.0-draft cl. 12.3
Notify the appellant of omissions in a notice	5 business days	cl. 8.3
Decide an extension request	5 business days	cl. 7.5
Determine admissibility	10 business days from a complete notice	MCC-700 v2.0 §9.4.1(b)
Decide an application for an interim order	10 business days	cl. 16.4
Respondent body's response to the appeal	15 business days	MCC-700 v2.0 §9.4.1(c)
Decide the appeal, in writing with reasons	60 calendar days from the close of submissions	MCC-700 v4.0-draft cl. 12.7
Redetermine a remitted matter	20 business days	MCC-700 v2.0 §9.5.3
Report to an appellant whose appeal is held open	every 60 calendar days	cl. 12.7
Publish the decision	30 calendar days from the decision	cl. 20.4
Publish appeal statistics	quarterly	MCC-700 v4.0-draft cl. 12.12

18.2 The sixty-day decision period runs from the close of submissions under cl. 13.6, not from filing, and the closing date SHALL be notified to both parties so that the appellant can see when it started.

18.3 Where the Programme will miss a limit in cl. 18.1, it SHALL notify the appellant before the limit expires, with the reason and a new date, and SHALL record the default in the Appeals Register.

18.4 A default by the Programme SHALL NOT determine the appeal. An appeal is not allowed by default and is not dismissed by default; it is decided on its merits, late.

18.5 Where a default exceeds thirty calendar days, the appellate body SHALL reconsider of its own motion whether the decision appealed against should continue to take effect pending determination (cl. 16.3), and SHALL record the outcome of that reconsideration.

18.6 Every default, its length and its reason SHALL be published in the quarterly transparency report against the limit missed, by count and by longest instance (MCC-700 v4.0-draft cl. 12.12: appeal statistics include "timeliness against the deadlines in this Section").

18.7 A limit binding the Programme SHALL NOT be extended by agreement with the respondent body. It MAY be extended with the appellant's written agreement, which SHALL be recorded.

19. The cost of appealing

19.1 An appellant SHALL NOT be required to pay for: the decision record and evidence supplied under cl. 8.6; interpretation or translation under cl. 13.5; expert advice the appellate body commissions under cl. 13.4; or the appellate body's own costs.

19.2 Each party SHALL bear its own costs of participating (MCC-700 v3.0/v3.1 cl. 15.7, which allocates costs on that basis for external dispute resolution).

19.3 No appeal fee is set by this Procedure, and none is in force. MCC-700 v2.0 §9.7.1 required the Governing Board to establish a published schedule of appeal fees "set at a level that does not create a material barrier to access", with the fee refunded in full where the decision is reversed (§9.7.2). The MCC Fee Schedule v1.0-draft contains no appeal fee and no reference to appeals; the Programme has no fee for appealing because it has never set one.

19.4 Whether an appeal fee is adopted at all is put to consultation. The drafting proposal is that no fee is charged, because a grievance is free (MCC-ESS v1.0 cl. 0107), a complaint is free (MCC-700 v4.0-draft cl. 13.2), and a fee that deters a vexatious appeal deters an affected community first. If the Board adopts a fee, it SHALL be set in the Fee Schedule and not here, SHALL carry the refund of MCC-700 v2.0 §9.7.2, and SHALL carry a waiver for project-affected persons and communities. (Consultation question 11.)

19.5 No fee, deposit or undertaking as to costs SHALL be required as a condition of registering an appeal under Section 9.

20. The decision, publication and finality

20.1 The appellate body SHALL issue its decision in writing with reasons, stating: the outcome under cl. 15.1; the grounds of appeal and how each was determined; the evidence relied on and any new evidence admitted; the clause references applied; the identity of the members who decided and any recusals; and any directions and their deadlines (MCC-700 v4.0-draft cl. 12.7; v2.0 §9.5.1).

20.2 Where the members did not agree, the decision SHALL record that fact and the numbers, and a member SHALL be entitled to have a dissent recorded (MCC-700 v2.0 §6.6, applied here by analogy).

20.3 The decision SHALL be sent to the appellant and to the respondent body on the same day.

20.4 The decision SHALL be published within thirty calendar days, with redactions permitted only on the grounds in MCC-700 v3.0/v3.1 cl. 14.3 and v4.0-draft cl. 21.4, and the fact of redaction SHALL be disclosed. An appellant who is a natural person MAY request that the appellant's name be withheld, and the request SHALL be granted; the decision and its reasoning are published either way.

20.5 The decision of the appellate body is final within the Programme (MCC-700 v4.0-draft cl. 12.9). There is no appeal against it, and no body of the Programme may reopen it.

20.6 Recourse beyond the Programme is available only as the applicable participant agreement provides (MCC-700 v4.0-draft cl. 12.10). This Procedure names no governing law, no forum, no seat and no arbitral rules, and cannot. No separate legal entity has yet been incorporated for the Programme (FD-2026-10-01 item 3; MCC-700 v4.0-draft cl. 4.4.2). Governing law is printed as a "TBD by Board" placeholder in participant agreements whose change logs record them as adopted, and the seat provisions of those agreements do not agree with each other. For the participant agreements to which MCC-700 v4.0-draft cl. 12.10 refers, the administration proposes Norwegian law, UNCITRAL rules and a seat in London; the proposal depends on the incorporation of the Programme's legal entity, which has not yet taken place, and is subject to the legal review required before adoption, which has not been obtained (FD-2026-10-01 item 3 and Schedule 1, Q9; Evidence Register ER-2026-001 §B5). (Consultation question 12.)

20.7 Clause 20.5 does not make an appellate decision unchallengeable outside the Programme, and nothing in this Procedure purports to exclude any right a person has under an applicable law (cl. 6.5).

20.8 An appellate decision binds the respondent body, which SHALL implement it within the period in cl. 15.4 (MCC-700 v2.0 §§9.5.2, 9.5.3). Non-implementation is a matter for the complaints channel and, where a member of a body is responsible, is cause within MCC-700 v4.0-draft cl. 6.2.

21. Records and the Appeals Register

21.1 There SHALL be one Appeals Register of the Programme, covering every appeal against a decision of the Programme whatever the decision type, and there SHALL NOT be a separate register per body. One Programme, one register, with a section for each decision type.

21.2 The Register SHALL record, for every appeal: the reference; the date of filing and the date of receipt of notice of the decision appealed; the decision appealed and its reference; the appellant's status (not necessarily the appellant's name — cl. 21.5); the admissibility determination and its date; whether an interim order was sought and its outcome; the appellate body and its members; every recusal; every default by the Programme under cl. 18.3; the outcome under cl. 15.1; the date of decision; the date of publication; and, where applicable, that the appeal is held open under Section 12 and since when.

21.3 The Register SHALL distinguish an appeal that is held open for want of a forum from an appeal that is pending before a constituted body. The two are not the same thing and SHALL NOT be counted together.

21.4 The Register SHALL record an appeal that was not decided under cl. 11.8 as "not decided — no independent forum", with the reason, and that record SHALL be published (MCC-ROI v1.0-draft cl. 11.15).

21.5 The Register SHALL be published, subject to the redaction grounds in cl. 20.4. The name of a natural-person appellant SHALL be withheld on request (cl. 20.4); the identity of a corporate appellant, and of every member of the appellate body, SHALL be published.

21.6 The published Register SHALL show the counts even when they are nil, and SHALL say why a count is nil. "No appeal has been filed" and "appeals cannot presently be heard" are different statements and both SHALL appear where both are true.

21.7 Records of appeals SHALL be retained for not less than seven years (MCC-700 v3.0/v3.1 cl. 14.2) and under the Record Retention Schedule (MCC-810 v1.0-draft) on its adoption.

21.8 Appeals and their outcomes SHALL be included in the quarterly transparency report (MCC-700 v3.0/v3.1 cl. 14.4; v4.0-draft cll. 12.12, 21.5), reported by decision type, outcome and timeliness.

21.9 The Register requires a store that does not exist. There is no appeals table, no appeals column and no appeals surface anywhere in the platform (cl. 23.5). Clause 24.3 makes the store a precondition to entry into force; a register that has nowhere to live is a promise, and the Programme has enough of those.

22. Transitional provisions

22.1 The duties in this Procedure attach to a body on that body's constitution. Nothing here imposes a duty on, or asserts the existence of, a body that has not been constituted (MCC-700 v4.0-draft cl. 23.1).

22.2 Where the founder exercises the functions of an unconstituted body (MCC-700 v4.0-draft cl. 23.2), the founder SHALL comply with this Procedure as a first-instance decision-maker, and SHALL NOT decide any appeal or independent review of a decision the founder took (cl. 23.7 of that draft; cl. 10.1 above).

22.3 Where the founder is personally conflicted on an appeal he would otherwise be competent to decide, MCC-ROI v1.0-draft cl. 13.3 applies with full force: the matter SHALL NOT be decided by him, the ladder in cl. 11.7 applies, and where no limb is available the appeal is not decided and is recorded under cl. 11.8.

22.4 The Appeals Register SHALL open on the date this Procedure enters into force, and SHALL be published within thirty calendar days of that date.

22.5 A decision taken before entry into force is not reopened by this Procedure. Where such a decision is challenged after entry into force by a person who was never given a conforming notice of appeal rights, the period in cl. 7.1 runs from the date a conforming notice is given (cl. 7.4).

22.6 The public document register SHALL state, for as long as this Section operates, that no appellate body of the Programme is constituted and that appeals are handled under Section 12 (MCC-700 v4.0-draft cl. 23.9).

22.7 This Section lapses when an appellate body meeting cl. 10.3 is constituted (cl. 12.11).

23. The position as at 4 September 2026

This Section is a finding of fact recorded on the date of this draft, so that the Board may act on it. It is not an allegation of misconduct against any person, and it does not assert that any obligation has been breached.

23.1 Five appeal rights, five named forums, no appointees. The corpus confers a right of appeal in MCC-700 v2.0 §§2.4.2 and 9.2, MCC-700 v3.0/v3.1 cll. 2.2 and 15.1, MCC-100 cll. 0286 and 0290 to 0292, the Programme Bible's "Appeals and Dispute Resolution" table, and MCC-700 v4.0-draft cl. 12.1 with MCC-001 v3.0-draft cl. 9.9.5. It names, respectively, the Appeals Body; the Review and Appeals Authority with the Governing Board above it and external dispute resolution above that; the Appeal Officer with the Governance Board as final appeal; the Appeals Panel of three with the Governing Board and independent arbitrators above it; and the Independent Appeals Panel. governance_appointments holds two rows, both against the Governing Board, both appointed 26 August 2026 by GB-2026-001: Leif Martin Klakken (Founder seat, MEMBER) and Lord Chris Grayling (Independent expert seat, CHAIR). No appointment exists against any other body. Of the five named appellate forums, none exists.

23.2 MCC-700 v2.0 exists, and it contains the procedure that was recorded as missing. The v4.0-draft changelog records v2.0 as "Not in the programme record" and carries an evidence line asserting its absence from the programme record; document_register carries the same note. The document is in Drive, in the folder 01_Gamle_versjoner, file MCC-700_Governance_and_Appeals_v2.0.docx, last modified 14 March 2026. Its Section 9 runs to seven sub-sections and states the Appeals Body's composition, who may file, what is appealable and what is not, timelines, an admissibility stage, the review process, the standard of review, the powers on determination, implementation deadlines, an interim-suspension test, and fees with refund on reversal. Its cl. 12.3.4 states the transitional rule the rest of the corpus lacks. The instrument that was described as never written had been written, and shelved under old versions. What is genuinely absent is any record of its adoption: its own cl. 12.1 required a two-thirds vote of a Governing Board that did not exist until 26 August 2026.

23.3 MCC-700's commencement: the text and the register disagree. Clause 18.1 of v3.0 and v3.1 reads "shall enter into force upon approval by the Governing Board on [Date to be inserted]". document_register records MCC-700 v3.1 with status = IN_FORCE, adopting_instrument = NULL and adopted_on = NULL. Both statements are in the Programme's own record and they cannot both be right. This Procedure does not choose between them; it records the conflict at cl. 25.6 and proceeds on the text, which is the more conservative reading and the one that does not attribute a breach to anyone.

23.4 v3.1 differs from v3.0 in one clause. The change log in Drive (MCC-700_v3.1_ENDRINGSLOGG.md, 24 August 2026, authority FD-2026-08-24 item D7) records a single material change, at cl. 5.2, aligning a professional-indemnity figure to MCC-400 art. 16. Clauses 12.1, 13.2, 15 and 18.1 are identical in the two versions, and citations in this Procedure to "v3.0/v3.1" are exact for both.

23.5 The platform has a grievance channel and no appeal channel. grievance_records exists in the production database, with a public filing form at /grievances, an API route at /api/grievances, an administrative screen at /portal/admin/grievances, defined statuses and categories, rate limiting, and an issuance gate that blocks issuance while a grievance on a project is open. It holds no rows. Against that: a query of information_schema.columns across the entire public schema returns no table and no column whose name contains "appeal" or "dispute"; there is no /appeals route, page or API; and the only two files in the whole repository with "appeal" in the filename are MCC-700_Governance_and_Appeals_v3.1.docx, its PDF and this draft. The audit log holds 240 rows across ten action types, none of which concerns an appeal. A person can file a grievance today. A person cannot file an appeal.

23.6 Live surfaces promise the route that does not exist. Until 7 September 2026 the public VVB accreditation page told a denied applicant that the decision "may be appealed under MCC-700 Section 15 within 30 days", and a withdrawn VVB that withdrawal was "appealable under MCC-700 Section 15" (replaced that day, PR #259). The KYC Account Opening Procedure §8 says refusals "state grounds and the appeal route". The Applicant Terms in force at art. 10.3 give an appeal address and a fourteen-day Board decision. The public page at /grievances is titled "Grievances and appeals"; until 4 September 2026 its step 3 escalated to "independent dispute resolution (level 4, MCC-700 section 15 Appeals)" (PR #241), and it now states that the fourth level is not available. Section 15 has no recorded commencement date (cl. 23.3); the Review and Appeals Authority has no members; and the Governing Board of two cannot hear an appeal against a decision either member took.

23.7 Nothing has been filed, and that is the only reason none of this has been tested. The Appeals Register would be empty on any view: no appeal exists, no appellate decision exists, and the registry holds no unit against which an appeal could bite. Two project rows exist, both at status SUBMITTED — MCC-2026-0001 (Gulf of Gabès Ghost Gear Recovery) and MCC-DRAFT-7C51FD88 (Norwegian Ghost Gear Recovery Project). Neither is registered; neither has passed a gate that generates an appealable refusal; and neither carries the is_demonstration flag, the demonstration cohort of 17 projects having been archived on 31 August 2026 into demo_archive_20260831. They are not a pipeline and are not registered projects.

23.8 What the Board actually has to do. The instrument is the easy part and is written here. The forum is the hard part and needs three names. MCC-700 v2.0 §12.3.4 shows the Programme's own answer from March: "a temporary panel of three independent persons appointed by the Governing Board". That is one resolution. Until it is passed, every appeal right in the corpus is a sentence, and cl. 12.4 is the whole of what an appellant gets.

23.9 The finding is not that anyone has withheld a right. No right has yet crystallised, because no appealable decision has yet been taken against anyone. The finding is that the Programme has published, on live pages and in participant agreements, a route to a body it has never constituted, and has not until now had a document that says what happens when someone takes that route. That is what this Procedure is for, and it is why it should be in force before the first refusal is issued and not after.

24. Entry into force

24.1 This Procedure SHALL enter into force on approval by the Governing Board — or, during the transitional period, on a Founder Decision recorded and tabled for ratification under MCC-700 v4.0-draft Section 23 — on a stated date, following the public consultation on this draft.

24.2 This Procedure SHALL NOT be brought into force before the appeal rights it serves are in force. Where MCC-700 v4.0 is approved, this Procedure takes effect no earlier than that Standard. Whether this Procedure may instead be brought into force earlier, attached to MCC-700 v3.1 as the Programme's register records it (cl. 23.3), so that an appellant has a written route before the rewritten suite completes, is put to consultation. The drafting proposal is that it may, because a procedure that operates only when someone appeals costs nothing while nobody does, and is the difference between a route and a sentence when somebody does. (Consultation question 13.)

24.3 Preconditions to entry into force. This Procedure SHALL NOT be brought into force until:

24.3(a) an appellate body meeting cl. 10.3 is constituted, or the external roster of cl. 11.7(c) is designated, or the Board resolves expressly that Section 12 is to operate in the interval and that resolution is published;

24.3(b) a store exists in the platform that records every field in cl. 21.2, distinguishes an appeal held open from an appeal pending, and records a default under cl. 18.3;

24.3(c) a published appeals page exists that satisfies Section 21 and states the counts required by cl. 21.6; and

24.3(d) the statements on the live surfaces listed at cl. 23.6 are conformed to what exists — including the title of the page at /grievances (cl. 4.9) and the accreditation-status text that cited MCC-700 Section 15 (conformed on 7 September 2026, PR #259).

24.4 On entry into force, the appeal procedures stated in Applicant Terms v1.1 art. 10.3 and VVB Terms v1.1 art. 5.2 SHALL be read with cl. 2.7 until those agreements are conformed by amendment.

24.5 This draft is published with status DRAFT — FOR CONSULTATION. It confers no rights and imposes no obligations. No appeal may be made under it, no time limit in it runs, and no body is constituted by it.

25. Contradictions recorded

Recorded, not resolved by drafting. Each is put to the Board.

25.1 Abstention against recusal, within one instrument. MCC-700 v3.0/v3.1 cl. 12.1 lists among the standard voting procedures: "Abstention: Members may abstain if conflict of interest exists or insufficient information is available." Clause 13.2 of the same instrument requires members to "Recuse themselves from voting on matters where a conflict exists" and to "Not participate in deliberations on conflicted matters." It bites here: an appeal is the one decision on which a conflicted person remaining in the room is least defensible. Clause 11.2 resolves it in favour of recusal, as MCC-ROI v1.0-draft cl. 11.2 does, and the resolution is the same one so that the Programme does not operate two answers.

25.2 Five appellate bodies, one programme. The Appeals Body (v2.0), the Review and Appeals Authority (v3.0/v3.1), the Appeal Officer (MCC-100), the Appeals Panel (Programme Bible) and the Independent Appeals Panel (v4.0-draft, MCC-001 v3.0-draft) are five different forums for the same function, in instruments that do not repeal one another. The v4.0-draft abolishes the Review and Appeals Authority by name (cl. 4.2) and governance_bodies records why — it "could both take first-instance decisions and hear appeals of them" — but MCC-100's Appeal Officer and the Bible's Appeals Panel are untouched by that abolition and remain in texts the Programme serves.

25.3 The standard of review is stated three ways. MCC-700 v2.0 §9.4.3: "The Appeals Body shall not conduct a de novo review", applying procedural conformity, evidential adequacy, reasonableness and freedom from material procedural irregularity. MCC-700 v3.0/v3.1 cl. 15.6: Level 2 is reviewed "on record (limited to evidence already presented)". MCC-700 v4.0-draft cl. 12.5: participant-affecting refusals, suspensions and revocations are heard de novo, with power to admit new evidence. Section 14 applies the v4.0 rule because it is the successor and because every other draft in the rewritten suite cross-refers to it; the earlier rules are not repealed by anything. (Consultation question 14.)

25.4 Finality is stated three ways. MCC-100 cl. 0292: appellate decisions "shall be final and binding". MCC-700 v2.0 §9.5.2: "final and binding on all parties". MCC-700 v3.0/v3.1 cl. 15.6 and 15.7: the Governing Board decision is final "unless Level 3 appeal is available", and Level 3 is external mediation or arbitration whose "neutral decision is binding on all parties unless a legal claim exists". MCC-700 v4.0-draft cl. 12.9 and 12.10: final within the Programme, with external recourse only as the participant agreements provide. Those agreements do not agree with each other on the seat, and print governing law as a "TBD by Board" placeholder (cl. 20.6).

25.5 The number of levels is stated three ways. MCC-700 v3.0/v3.1 cl. 15.4: three levels (internal reconsideration, Governing Board, external dispute resolution). Programme Bible: three levels with different bodies, thresholds and timelines (45, 60, 90 days). MCC-700 v4.0-draft: one level of independent review and one appeal, with external recourse outside the Programme. MCC-100 cl. 0292: two (Appeal Officer, then Governance Board).

25.6 A standard recorded as in force with no instrument bringing it into force. document_register records MCC-700 v3.1 as IN_FORCE with a null adopting instrument and a null adoption date, while cl. 18.1 of the text leaves the commencement date as "[Date to be inserted]" (cl. 23.3). The same register records 25 instruments as in force, 12 of them with no adopting instrument (1 October 2026). Both statements cannot be right about the same document, and this Procedure does not decide which is.

25.7 The participant agreements state their own appeal procedures. Applicant Terms v1.1 art. 10.3 gives an appeal against suspension and termination to an independent reviewer who "issues recommendation (20 days)", with the Board making a "final decision (14 days)" and "no further appeal within MCC" — a two-step route with a recommending reviewer and a deciding Board, which is neither MCC-700's structure nor its timetable, and which routes the final decision to the body whose decision is under challenge. VVB Terms v1.1 art. 5.2 gives an applicant an "appeal" against a VVB assignment, decided by the Board in 20 days; no MCC-700 list makes a VVB assignment appealable at all.

25.8 The grievance ladder terminates in an unnamed body. MCC-ESS v1.0 cl. 0117 escalates unresolved grievances "to the MCC Governance Board or an independent dispute resolution mechanism", and the Policy's own stage table gives the appeal stage as "Independent review of grievance decision — 30 days after request — MCC governance body". Which governance body is not stated in the Policy, in MCC-700 v3.0/v3.1 cl. 6.1.4.1, or anywhere else.

25.9 An appeal fee is required by one instrument and priced by none. MCC-700 v2.0 §9.7.1 requires a published schedule of appeal fees; the MCC Fee Schedule v1.0-draft contains none, and no other instrument sets one (cl. 19.3).

25.10 No legal entity, and therefore no forum. No operating company is incorporated (MCC-700 v4.0-draft cl. 4.4.2). There is no controller, no jurisdiction and no governing law that this Procedure could name, and the obligation to hear an appeal rests on the Programme's own instruments and on nothing else — which is why the instrument has to exist, has to be published, and has to be honest about what it cannot deliver yet.

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Annex A — Open items (index)

Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions at the head of this text and marked in the text. The references below indexed those points when this draft was prepared, and are kept so that each can be traced.

Ref	Clause	Where it now stands
OD-APP-1	2.6	Consultation question 1
OD-APP-2	2.7	Consultation question 2
OD-APP-3	2.8	Consultation question 3
OD-APP-4	5.2	Consultation question 5
OD-APP-5	6.4	Consultation question 6
OD-APP-6	12.10	Consultation question 8
OD-APP-7	16.3	Consultation question 10
OD-APP-8	19.4	Consultation question 11
OD-APP-9	24.2	Consultation question 13
OD-APP-10	25.3	Consultation question 14
FI-APP-1	Document control	Stated in the document control: code MCC-APP, assigned by the programme administration for this consultation
FI-APP-2	Document control	Consultation question 1
FI-APP-3	Document control	Stated in the document control: the Programme Administrator, transitionally (FD-2026-10-01 Schedule 1, C3)
FI-APP-4	Document control	Stated in the document control: 30 days (FD-2026-10-01 Schedule 1, C4) from the opening recorded on the consultation register
FI-APP-5	11.7(c), 12.9	Consultation question 7
FI-APP-6	13.8	Consultation question 9
FI-APP-7	20.6	Consultation question 12
FI-APP-8	3.9	Consultation question 4

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Evidence line

Checked on 4 September 2026, across all four sources and the running platform, before recording anything in this instrument as absent. MIR-2026-001 rev 3 §0 requires exactly this: "Before any further entry is acted on, it should be checked against all four: the served document manifest, document_register, the review corpus, and Drive."

1. In-force text corpus — all 34 files in ~/mcc-review/txt, searched in full for "appeal", "appeals", "grievance", "dispute", "review panel", "Independent Review Panel", "recusal" and "abstention". Read in the relevant part: MCC-700 Governance and Appeals v3.0 in full (§§1–18, with §§4.4, 11.1, 12.1, 13.2, 14.1–14.5, 15.1–15.8, 16.2 and 18.1 read closely); MCC-100 Programme Standard v2.1 CONSOLIDATED (cll. 0018, 0019, 0028–0038, 0272, 0276–0297); MCC-100 Amendment 1 (Parts C and D, cll. 0053.4–0053.8, 0057.1, 0061.1–0061.3); MCC-400 v1.1 CONSOLIDATED (arts. 2–5, 29, 30, 72–78); MCC-800 Registry Operations v1.0 (arts. 3–5, 30, 48, 51, 52, 65, 72–75, 103–106); MCC-ESS v1.0 (cll. 0092–0124 and the grievance-stage table in full); MCC-001 Charter and Constitution v2.0 (searched for "appeal": no occurrence); MCC Programme Bible v2.0 (§§"Governance", "Appeals and Dispute Resolution", "Document Hierarchy", the AI tiering table, Stage 1); MCC Applicant Terms v1.0 (arts. 10.2, 10.3, 12); MCC VVB Terms v1.0 (arts. 5.1, 5.2, 8); MCC Registry Terms v1.0 (art. 15); MCC CA/Double-Counting Policy v1.0 (cll. 0122, 0154, 0165).
2. Adopted content served publicly — apps/web/content/adopted/ (15 files listed); applicant-terms.md and vvb-terms.md read at their appeal articles; transparency-policy.md; programme-factsheet.md.
3. Document manifest — apps/web/src/lib/documents/manifest.ts (331 lines), confirming MCC-700 is served as v3.1 with the v4.0-draft recorded as its successor, MCC-100 as v2.2, MCC-400 as v1.1, and MCC-400 Addendum 1 and MCC-850 Amendments 1–2 as STAYED.
4. Proposals (the rewritten suite) — apps/web/content/proposals/ (39 files listed). Read: mcc-700-governance-v4-0-draft.md in full (615 lines: document control, Sections 3–5, 10–15, 20–24, Annex A rows 1–38 and rules A-3 to A-6, Annex B rows T1–T15, T-I and rules B-1 to B-6) — before drafting anything here, precisely because the successor may already carry the machinery, and it does; mcc-roi-register-of-interests-v1-0-draft.md in full, with cll. 11.2, 11.5–11.18 and 13.3 read closely as this Procedure is required to be consistent with them; mcc-rest-restatement-and-correction-v1-0-draft.md §10 in full and cl. 11.1; mcc-400-vvb-standard-v2-0-draft.md cll. 1.3–1.5, 2.1–2.6, 3.1–3.5; mcc-100-programme-standard-v3-0-draft.md cll. 22.6–22.9, 23.1–23.8; mcc-ess-safeguards-v2-0-draft.md cll. 20.6–20.13, 21.1–21.8, 22.1–22.8; mcc-800-registry-operations-v2-0-draft.md cll. 4.1, 4.2, 8.8, 11.5; mcc-001-charter-v3-0-draft.md cll. 9.7.1–9.10.3; mcc-forms-operational-suite-v1-0-draft.md document control and §1 (no appeal form exists in MCC-FORM-001 to 013); mcc-fees-fee-schedule-v1-0-draft.md (searched for "appeal" and "grievance": no occurrence); kyc-account-opening-procedure-v1-0.md §§7–9.
5. Platform source — apps/web/src searched in full for "appeal", "Appeal", "grievance", "Grievance": 126 matches, every one read by file. Grievance surfaces: lib/grievances.ts, app/grievances/page.tsx, app/grievances/GrievanceForm.tsx, app/api/grievances/route.ts, app/portal/admin/grievances/*, lib/audit.ts, lib/rate-limit.ts, app/governance/page.tsx, app/transparency/page.tsx, app/sitemap.ts. Appeal references, all textual, none functional: lib/vvb-accreditation.ts (DENIED and WITHDRAWN status text citing MCC-700 §15), lib/governance-register.ts (the REVIEW_AND_APPEALS_AUTHORITY body record, target 7, no appointees), app/vvb/accreditation/page.tsx, app/governance/register/page.tsx, app/about/page.tsx, lib/documents/manifest.ts, lib/consultation-proposals.ts. A repository-wide filename search for "appeal" returns exactly two files: the MCC-700 v3.1 .docx and .pdf.
6. Database — Supabase project ifflkkpowmzjoochwavf, read-only SELECTs only, no write of any kind. information_schema.columns queried across the whole public schema for any table or column matching "appeal" or "dispute": zero rows. Full contents of governance_appointments (2 rows), governance_bodies (14 rows, both epochs, including INDEPENDENT_APPEALS_PANEL as a record and REVIEW_AND_APPEALS_AUTHORITY with the note explaining its abolition), document_register (MCC-700, MCC-100, MCC-400 and annex rows), decision_register (6 rows). Row counts: grievance_records 0, credit_units 0, retirements 0, credit_cancellations 0, issuance_requests 0, coi_declarations 0, interest_disclosures 1, projects 2, audit_log_entries 240 across ten action types (TRANSITION, CREATE, UPDATE, APPROVAL, SUBMISSION, ASSIGNMENT, ISSUANCE, RETIREMENT, DELETE, LOGIN — none an appeal action).
7. Drive — folder 00_Styring_og_Vedtak (1X7rHCCmVcBCs1v5aC5Je-jOaYvE4-DvG) listed; full-text searches for "Appeals Procedure", "Notice of Appeal" and title searches for "Appeal" and "MCC-APP". Read in full: MCC-700_Governance_and_Appeals_v2.0.docx (1RziDj9zD79pLEDjI9r4pfwoj-wn5oQE5, folder 01_Gamle_versjoner, modified 14 March 2026); MCC-700_v3.1_ENDRINGSLOGG.md; MCC_Missing_Instruments_Register_MIR-2026-001_rev3_2026-09-04.md. No file in Drive is an operational appeals procedure, and no notice-of-appeal form exists in any form.
8. Not found, after searching all seven of the above — no instrument, annex, schedule, page, route or table constituting or naming an appellate body with an appointee; no appeals register in any medium; no notice-of-appeal form; no appeal fee in any fee instrument; no record of any appeal ever having been filed, and none of any appellate decision ever having been taken.
9. Corrected here, having been recorded elsewhere as absent — MCC-700 v2.0 and its Section 9 appeals procedure (cl. 23.2), recorded on 4 September 2026 as "[not in current corpus]" in the MCC-700 v4.0-draft changelog and in the document_register note; and the premise that MCC-400 reserves accreditation appeals to itself (cl. 2.4), which it does not — both MCC-400 v1.1 arts. 30 and 76 and MCC-400 v2.0-draft cl. 3.4 refer them out to MCC-700.
10. Could not be verified, and is not asserted — whether MCC-700 v2.0 was ever put to any body for adoption; the outcome of the draft resolutions proposed to the Governing Board in the board pack of 23 September 2026 (no record of a Governing Board meeting on 23 September 2026 has been filed); and whether the founder's stated signature of FD-2026-09-04 has been received into the record (when this draft was prepared, decision_register recorded SIGNED_COPY_NOT_RECEIVED; it now records FD-2026-09-04 as attested by the founder on 4 September 2026, with no executed copy filed).

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End of MCC-APP v1.0-draft. Status: DRAFT — FOR CONSULTATION. Not in force. No appeal may be made under this Procedure, no time limit in it runs, and no appellate body is constituted by it.