MCC-REST — Restatement and Correction Policy v1.0-draft

Document control

Field	Value
Document code	MCC-REST (code assigned by the programme administration for this consultation; entered in the Document Register on adoption)
Title	Restatement and Correction Policy
Version	1.0-draft
Status	DRAFT — FOR CONSULTATION
Date of this draft	4 September 2026
Tier	Tier 5 (operational policy). It changes no rule; it says what happens when something the Programme published was wrong.
Effective date	None. This policy is not in force.
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	Transparency Policy v1.1 Article 6 (Corrections and Restatements) and Article 8.1; MCC-100 v2.1 cl. 0040 and cl. 0256; MCC-700 v3.0 §11.1, §12.2, §14.4 and §14.5; MCC-800 v1.0 art. 16, 30, 48, 50–52, 63, 65, 66; FD-2026-08-24 item D16 (change discipline); MCC-800 Re-issue Note for v1.1. Read with two texts not yet adopted: the Rule Change and Public Consultation Procedure v1.0 §6–§9 (its notice period ended on 8 September 2026, and its closing protocol, published on 24 September 2026, recommends adoption, which rests on FD-2026-09-04 — recorded in the decision register as attested by the founder, with no executed copy filed — while whether a text may be adopted on an attested decision is referred to the Governing Board, MCC-CLS-2026-001 §B.1 and Part E item 4) and MCC-800 v2.0-draft cl. 11.2, 14.3, 15.3 and S1.15.
Supersedes	None (new document). On entry into force it becomes the only place the Programme states how a published error is put right.
Language convention	British English; RFC-style normative verbs.
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). Why this document exists, and why now.

Between 31 August and 4 September 2026 the Programme corrected itself at least ten times. It deleted a hard-coded figure of 605,000 tCO₂e that a public register page displayed precisely because the database behind it was empty. It removed a demonstration cohort of 17 projects and 28,769 credit units, a fabricated news item and a mis-cited claims authority. It stayed five open rule-change consultations by published notice. It corrected six unverifiable statements out of the served privacy notice. It withdrew the authority under which a system-status page had been published, that authority being a provision that is stayed and has never been in force. It found that its own instrument register omitted every annex, an omission that had caused two successive reviews to record an instrument that was in force and publicly served as never having existed. It reissued the Missing Instruments Register twice in one day, as revisions 2 and 3, each correcting a finding of the last. It consolidated the board pack with nine corrections to its own premises.

Not one of those corrections was governed by a rule. Each was made well or badly on judgement alone. Some were announced, some were not; some preserved what they replaced, some did not; none was counted. The Transparency Policy has promised a corrections process since March 2026 and points to one; the process it points to has never been written.

A programme that corrects itself this often and has no correction policy is one restatement away from an inconsistent one. That is the whole argument for this document.

Consultation questions

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

1. Clause 5.2 — the materiality test. Proposed: a correction is material if a reasonable reader, knowing the corrected position, might have done something different (cl. 5.1), judged by that test alone and not by how embarrassing the error is (cl. 5.2). Basis: this draft (cll. 5.1–5.2; Annex, question 2); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the test is right.

2. Clause 6.2 — the silent-fix rung (R0). Proposed: R0 is retained, available only where the change cannot mislead, and so confined to class C1 (cl. 6.2). Basis: this draft (cl. 6.2; Annex, question 1); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether R0 should be available at all, or every change to a published statement should carry a note.

3. Clause 8.3 — the two-business-hour tier. Proposed: the tier applies to any statement on which a person could act to their detriment within the day, not only to register figures (cl. 8.3, first row). Basis: this draft (cl. 8.3; Annex, question 4); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the tier should apply only to register figures.

4. Clause 9.8 — retention of superseded published text. Proposed: permanent retention. Basis: this draft (cl. 9.8); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the Record Retention Schedule (MCC-810 v1.0-draft) should state a period for superseded published text other than "permanent", and if so what would justify a shorter one.

5. Clause 11.6 — the interim provisions (b) and (c). Proposed: no proposal is made — the clause was drafted as though the Governing Board were not yet constituted; it was constituted on 26 August 2026 (GB-2026-001), and the premise is corrected in this text. Basis: GB-2026-001; FD-2026-08-24. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether (b) and (c) should govern Board-reserved corrections until an executed copy of the Board's constituting minute (GB-2026-001) is filed, or be deleted.

6. Clause 11.8 — correction authority for unit and transaction records (class C6). Proposed: no proposal is made — MCC-800 v2.0-draft routes defect findings and cancellations through the governance decision matrix, and this Policy does not duplicate that routing. Basis: this draft (cl. 11.8); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether a standing correction authority should also sit with the Registry Oversight function for class C6, or whether every registry correction should reach the Board.

7. Clause 12.7 — what the quarterly correction summary names. Proposed: the public Correction Register (cl. 9.1) carries the detail of each correction and the quarterly summary carries the count. Basis: this draft (cl. 12.7); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the summary should also name each material correction individually.

8. Annex, question 7 — where this Policy sits. Proposed: a standalone Tier 5 policy, under the code MCC-REST assigned by the programme administration for this consultation; tier and code are entered in the Document Register on adoption. Basis: this draft (document control; cl. 13.1); FD-2026-10-01 item 5. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether this Policy should instead be an annex to the Transparency Policy, whose Article 6 it implements.

9. Annex, question 8 — citing this Policy in Transparency Policy Article 6. Proposed: Article 6 is amended to cite this Policy; this draft proposes the citation but does not draft the amendment. Basis: this draft (Annex, question 8); Transparency Policy v1.1 §9.1. Decided by: the Governing Board on adoption of the suite; an amendment to the Transparency Policy requires its approval (Transparency Policy v1.1 §9.1). Comments are invited on whether Article 6 should cite this Policy, or be left as the promise this Policy keeps.

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1. Purpose and scope

1.1 This Policy SHALL govern what the Programme does when something it has published was wrong: how the error is classified, how the remedy is chosen, who chooses it, how quickly, what is recorded, and what a reader is able to see afterwards.

1.2 This Policy applies to everything the Programme publishes or serves: normative instruments and their annexes and schedules; registers; the public register of projects and units; served web pages; notices, news items and consultation documents; board and decision records that are published; and any statement the Programme makes about itself, its capabilities, its status or its history.

1.3 This Policy does not decide what a rule should say. Changing a rule is governed by the Rule Change and Public Consultation Procedure and by the amendment clauses of the instrument concerned. This Policy decides only how an untruth already published is put right, and it hands over to the change procedure at the point where the remedy becomes an amendment (clause 6.6).

1.4 This Policy does not create a power to alter the registry ledger or the audit trail. Section 10 states, and does not weaken, the immutability rules already in force.

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2. Authority

2.1 The instrument that calls for this Policy is the Transparency Policy v1.1, Article 6, headed "CORRECTIONS AND RESTATEMENTS". Its operative words are reproduced here in full, because they are the whole of the Programme's written law on the subject and they are six numbered steps and four bullet points:

6.1 Data Error Correction Process — "If published data incorrect:"

1. "Error identified (by MCC, stakeholder, or auditor)"
2. "Correction assessed (is this truly an error? documentation review)"
3. "Correction approved (MCC Board or technical staff, per significance)"
4. "Corrected data republished (with notation: 'Corrected [date]')"
5. "Original data archived (for audit trail; not deleted)"
6. "Stakeholder notification (if material; email to affected parties)"

6.2 Restatement Policy — "Material restatement (if major historical data wrong):"

• "Public announcement (press release)"
• "Comprehensive explanation (what was wrong, why, how corrected)"
• "Impact assessment (if restatement affects market price/confidence)"
• "Remediation plan (how to restore trust)"

2.2 Article 6 is the authority for this Policy and this Policy is its implementation. Three things about Article 6 explain why an implementing instrument is needed and are the reason for Sections 4 to 9:

(a) it addresses "published data" only, and most of what the Programme got wrong between 31 August and 4 September 2026 was not data — it was a citation, a claim, a status, an authority, or an entry that was missing;

(b) it distributes the approval between "MCC Board or technical staff, per significance" without saying what significance is or where the line falls; and

(c) it requires "Corrected data republished (with notation: 'Corrected [date]')" and "Original data archived (for audit trail; not deleted)" without saying where the archive is, how a reader reaches it, or how a reader satisfies themselves that the archived text is the text that was served.

2.3 This Policy adds nothing to Article 6's promises. It states how each of them is kept.

2.4 Article 8.1 of the Transparency Policy establishes a stakeholder feedback route with a "Response provided to requester (within 30 days)" and "Decision published (if policy change)". That route is a correction route as well as a disclosure route, and clause 11.5 uses it.

2.5 Change discipline is already adopted. Founder Decision FD-2026-08-24 (recorded in the decision register as attested by the founder, with no executed copy filed) adopts item D16 — "endringsdisiplin og annullering av de fabrikkerte vedtaksreferansene" (change discipline, and annulment of the fabricated decision references). The MCC-800 Re-issue Note for v1.1 records what D16 was adopted against: MCC-800 v1.0 art. 27 was "stille etterredigert" — silently edited after the fact — "without a version bump or change log — exactly the practice item D16 a forbids". Section 7 of this Policy is that prohibition, restated so that it covers pages and claims and not only instrument text.

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3. Definitions

3.1 In this Policy:

Published statement means anything the Programme has made available to a person outside the Programme — an instrument, an annex, a schedule inside another instrument, a register row, a served page, a notice, a news item, an API response, a document sent to an identified counterparty, or a figure printed in any of them. A schedule inside another instrument is a published statement. An annex is a published statement. A page in the application that is in no register is a published statement.

Error means a divergence between a published statement and the truth it asserts, whatever caused it: a slip, an arithmetic mistake, a stale figure, a citation to a provision that does not apply, a claim for which no evidence exists, an omission that makes what remains misleading, or a normative clause that states something the Programme did not decide.

Correction means the act of putting an error right, by any rung of the ladder in Section 6.

Correction note means a dated, published statement that records what was wrong, what it now says, when it changed and on whose authority.

Restatement means a correction that changes a figure, a status or a conclusion the Programme has previously published and on which a reader may have relied, such that the earlier published position no longer stands. Every restatement is a correction; not every correction is a restatement.

Withdrawal means the removal of a published statement from service without a corrected successor, accompanied by a correction note that says why.

Superseded text means the exact bytes of the published statement as served immediately before the correction.

Silent fix means a correction made without a correction note.

Registry ledger means the unit, batch, holding, transfer, retirement and cancellation records of the MCC Registry. Audit trail means the append-only record required by MCC-800 art. 63. Neither is a published statement for the purposes of the ladder in Section 6; both are governed by Section 10.

3.2 Where a term is defined in the MCC-100 Annex — Definitions Register, that definition prevails. This Policy defines only terms the Definitions Register does not.

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4. What can be wrong: the taxonomy

4.1 Every correction SHALL be classified on discovery into exactly one of the seven classes below. The class is recorded in the correction record (Section 9) and determines the starting rung of the ladder. The class is not the answer; it is where the answer starts.

Class	What it is	Examples from the Programme's own record	Starting rung
C1 — Presentation	A typographical, spelling, formatting, renumbering or broken-link error in a published document, which changes no number, date, obligation, status or claim	null date fields rendered as "1/1/1970"	R0
C2 — Arithmetic	A calculation, unit, conversion or cross-reference error that changes a figure a reader may act on	leakage rate stated as 0.4 % where the arithmetic gives 41 %; Mg C labelled Mg CO₂e	R2
C3 — Untrue statement of fact	A published assertion about the world, the Programme or the system that is not true, or for which no evidence exists	analytics cookies described where no analytics library is loaded; standard contractual clauses described where none is recorded	R1
C4 — Unauthorised normative text	A clause, threshold or obligation in an instrument that states something no decision of the Programme establishes; or a citation to an authority that is stayed, repealed or non-existent	a status page published "under MCC-400 art. 95.1", a provision whose entry into force is stayed and which has never applied; fabricated decision references annulled by FD-2026-08-24 item D16	R3
C5 — Register figure	A number, count, status or aggregate displayed on a public register surface that does not match the underlying record	605,000 tCO₂e of hard-coded sample credits on the public register page, displayed while the database held none	R1
C6 — Unit or transaction record	A defect in an issued unit, a serial, a holding, a transfer, a retirement or a cancellation	none has ever arisen: the registry holds zero credit units	Section 10, not the ladder
C7 — Register-of-record omission	An instrument, annex, decision or document that exists and is in force but is absent from the register that is meant to list it	the instrument register omitted every annex, so an in-force, publicly served annex was recorded twice as never having existed	R1

4.2 A statement may carry errors of more than one class. Where it does, each error SHALL be classified separately and the correction SHALL take the highest rung any of them requires. A single correction instrument MAY carry several classified errors, as Guidance Errata No. 1 does.

4.3 C4 is the class the Programme has been worst at seeing. A citation to a provision that is stayed is not a formatting problem; it is the assertion of an authority that does not exist. Where a published statement rests on a clause, a decision or a body, the correction process SHALL verify that the clause is in force, that the decision is recorded and signed, and that the body is constituted, before it treats the statement as merely mis-worded.

4.4 C7 is the class that is invisible from inside. An omission from a register produces no wrong statement anywhere; it produces a reader who concludes that something does not exist. The Programme has made this error twice about the same instrument. Accordingly: a review that concludes an instrument has never existed SHALL NOT record that conclusion until it has checked the register, the served corpus, the proposals directory, the annexes and schedules inside other instruments, and the application's own routes. A schedule inside another instrument is not a file. An annex is not necessarily in the review corpus. A page in the application is in no register unless someone put it there.

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5. Materiality

5.1 A correction is material if a reasonable reader of the published statement, knowing the corrected position, might have done something different: submitted differently, priced differently, relied on it in their own disclosure, commented on a consultation, brought an appeal, or declined to proceed.

5.2 Materiality SHALL be judged by that test alone. It SHALL NOT be judged by how embarrassing the error is, how it arose, how long it stood, how many people are known to have read it, or how much work the correction creates. An error that reflects badly on the Programme and misleads nobody is immaterial. An error that reflects on nobody and misleads a reader is material. (Consultation question 1.)

5.3 A correction is material, without further assessment, where it changes any of the following in a published statement: a quantity; a price or fee; a date; an obligation or prohibition; a status (of an instrument, a project, a unit, a consultation, a body or an accreditation); an authority relied on; or a claim the Programme has made about itself. Clause 7.2 makes the same list the boundary of what may never be corrected silently, and the two clauses are deliberately identical.

5.4 Where materiality is arguable, the correction SHALL be treated as material. The cost of an unnecessary correction note is a line of text; the cost of a suppressed one is that the reader learns of the error from someone else.

5.5 Materiality is assessed on the position as published, not as intended. A figure that was meant as a placeholder, a sample, an illustration or a demonstration is assessed as a reader would read it, unless the published statement itself said so at the point of reading.

5.6 The absence of a known relying reader is not a finding of immateriality. The Programme has published to an audience it does not enumerate, and it operates a public API.

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6. The correction ladder

6.1 There are five rungs, plus a separate registry track under Section 10. They are ordered by visibility, and the ladder is climbed, never descended, once a rung has been chosen and published.

Rung	Remedy	What it is	When it is the right rung
R0	Silent fix	The statement is changed in place with no note, recorded internally only	Only where the change cannot mislead: class C1, and nothing else (clause 6.2)
R1	Published correction note	The statement is changed and carries a dated note saying what was wrong, what it now says, and on whose authority	Any material correction to a page, register surface, notice or non-normative document
R2	Erratum instrument	A separate published instrument that lists each corrected line as current text → corrected text with its basis, adopted on the Tier 5 path	Corrections to a normative instrument or its annexes that change no rule
R3	Amendment	The ordinary change procedure for the instrument's tier	Where the correction changes a threshold, a quantity, an obligation or a status the instrument sets
R4	Withdrawal	The statement is taken out of service, with a note that says why and what replaces it, if anything	Where the statement should not have been published at all, or cannot be corrected into truth
RC	Registry correction	Cancellation and reissue, or a compensating entry — never an edit	Class C6 only. Section 10 governs it in full and this ladder does not apply

6.2 R0 is available only where the change cannot mislead. A silent fix MAY be made where, and only where, the corrected statement and the superseded statement would lead every reader to the same understanding of every quantity, date, obligation, status, authority and claim. Correcting a misspelling, a broken link, a renumbered cross-reference that resolves to the same target, or a rendering defect meets that test. Nothing in clause 7.2 meets it. (Consultation question 2.)

6.3 The presumption is upward. Where the correct rung is arguable — including any case where two people who have read the statement disagree about which rung applies — the more visible rung SHALL be taken. A correction note published where none was needed costs a reader nothing; a correction note withheld where one was needed is a second error on top of the first, and the reader has no way to detect it.

6.4 R1 does not require the statement to be preserved in place. Where a page or a figure is removed rather than corrected — because the honest position is that the Programme has nothing to put there — the removal SHALL still carry a correction note. Removing a false statement without saying it was removed leaves a reader who saw it with no way to learn it was wrong.

6.5 R2 follows the errata form the Programme already uses. An erratum instrument SHALL follow the form of Guidance Errata No. 1 (F01, F02, F05): the corrections common to several documents stated once, then applied line by line, each as v1.0 text → v1.1 text with the basis for the change, followed by an adoption, consolidation and publication section. Under the Rule Change and Public Consultation Procedure v1.0 §7 — not yet adopted: its notice period ended on 8 September 2026, and its closing protocol of 24 September 2026 recommends adoption on FD-2026-09-04 (MCC-CLS-2026-001 §B.1) — an erratum "corrects a calculation, a cross-reference or a factual statement without changing what the rule requires", follows "the Tier 5 path — 14 days' notice on /consultations, administration adoption, version bump to the next minor — whatever the tier of the corrected document". This Policy adopts that boundary and does not restate it.

6.6 R2 becomes R3 at the same boundary the change procedure already draws. Where the correction "changes a threshold, a quantity or an obligation" (Rule Change and Public Consultation Procedure v1.0 §7) it is an amendment, decided by the body the tier table assigns, and this Policy hands over to that procedure. Where a correction is on the R2/R3 boundary, clause 6.3 applies and it is an amendment.

6.7 R4 is not a last resort; it is sometimes the only true answer. Where a published statement rests on an authority that does not exist, or asserts a fact for which no evidence can be produced, correcting the wording leaves the assertion standing. In that case the statement is withdrawn and the withdrawal note says what was claimed, what the position actually is, and what the Programme will do to be able to say something at all.

6.8 A withdrawal SHALL NOT be effected by deletion alone. A statement that vanishes without a note is indistinguishable, to a reader who saw it, from a statement the Programme still stands behind and has merely moved.

6.9 Choosing a rung is a decision, and it is recorded in the correction record with the reason (clause 9.2). A rung chosen without a recorded reason SHALL be treated as R1 for the purposes of Section 12 reporting.

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7. Never silently

7.1 This Section is the operative core of the Policy. It is short on purpose.

7.2 No change to a published statement SHALL be made without a published correction note where the change alters any of the following:

(a) a number — a quantity, a count, a rate, a percentage, a threshold, a fee, a price, a serial, a balance, an aggregate or a statistic;

(b) a date — an effective date, an entry-into-force date, a closing date, a deadline, a vintage, a publication date, or a "last updated" marker;

(c) an obligation — anything a person must, must not, may or need not do, including the addition or removal of a condition, a gate or an exemption;

(d) a status — of an instrument (in force, stayed, superseded, withdrawn, draft, never made), a project, a unit, an account, a consultation, an accreditation, a decision or a governance body;

(e) an authority — the clause, decision, instrument or body cited as the basis for the statement; or

(f) anything the Programme has claimed about itself — its capabilities, its systems, its certifications, its operational status, its history, its counterparties, its assurances or its record.

7.3 The list in clause 7.2 is a floor, not a ceiling. Clause 5.1 continues to apply to changes the list does not name.

7.4 Where a change of the kind in clause 7.2 has already been made silently — whether before or after this Policy takes effect — it SHALL be regularised by a published note as soon as it is discovered, on the model of the MCC-800 Re-issue Note for v1.1, which exists because art. 27 of that Standard was silently edited after adoption and the Programme chose to say so rather than let the edited text stand as though it had always read that way. The note SHALL state what the text said before, what it says now, when it changed, and that the change was made without notice.

7.5 A version number is not a correction note. A change log entry is a correction note only if it states what was wrong, not merely what is now different. "Updated" is not a correction note.

7.6 A correction note SHALL NOT be worded so as to suggest that the superseded statement was correct at the time it was published, unless it was.

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8. Timeliness

8.1 A correction is published as soon as it is known, not when it is comfortable. The trigger is knowledge that the published statement is or may be wrong, not completion of the investigation into how it came to be wrong, not the drafting of the successor text, and not the availability of the person who authorised the original.

8.2 Where the Programme knows a published statement is wrong but does not yet know what the correct statement is, it SHALL publish that fact within the period fixed in clause 8.3, and SHALL NOT wait for the corrected text. An interim note stating "this figure is under correction and should not be relied on" is a correction note within the meaning of this Policy.

8.3 Correction notes SHALL be published within the following periods from the moment the error is known:

What	Period
A statement that could cause a person to act to their detriment before the next period elapses	Immediately, and in any event within 2 business hours (Consultation question 3.)
A material correction (clause 5.1 or 5.3) to a register surface, a served page, a notice or a figure	1 business day
A material correction to a normative instrument, an annex or a register of record	5 business days for the correction note; the erratum or amendment then follows its own procedure
An immaterial correction (C1 only)	No period; recorded in the change log at the next publication

8.4 The periods in clause 8.3 are aligned with the publication timing already committed in the Transparency Policy Article 4, which fixes 2 business hours for real-time publication, 1 business day for event-driven publication, and 5 business days for governance decisions and policy amendments. A correction is not entitled to a slower cadence than the statement it corrects.

8.5 The period is not extended because the corrected position is unwelcome, because a governance body has not yet met, because a body competent to decide has not yet been constituted, or because a related matter is on a future agenda. Where the correction requires a decision by a body that cannot yet take it, the Programme SHALL publish the correction note stating the position and identifying what remains undecided, and SHALL place the decision before the body when it can be taken. Withholding the note until the body can meet leaves the untruth in service in the meantime, which is the choice the note exists to prevent.

8.6 Where an error is drawn to the Programme's attention by a person outside it, the periods in clause 8.3 run from receipt, and the Transparency Policy Article 8.1 commitment of a "Response provided to requester (within 30 days)" applies to the substantive answer, not to the correction note.

8.7 A stay, suspension or withdrawal that is published as a notice — as the five rule-change consultations were, by consultation stay notice CSN-2026-001 on 3 September 2026 — satisfies clause 8.3 for the statement it addresses, and does not need a second note.

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9. The correction record, and the superseded text

9.1 The Programme SHALL maintain a Correction Register, publicly accessible, in which every correction at rung R1 or above is recorded. It is the register the Transparency Policy §6.1 step 5 assumes when it requires that "Original data archived (for audit trail; not deleted)", and it is the register MCC-100 cl. 0256 requires when it provides that programme documentation shall be maintained "in a publicly accessible archive".

9.2 Each entry SHALL record, at minimum:

(a) a correction reference and the date the error became known; (b) the published statement affected, identified precisely enough for a reader to find it; (c) the class under Section 4 and the rung under Section 6, with the reason the rung was chosen; (d) what the statement said, and what it says now; (e) the materiality determination under Section 5, with its reason; (f) who decided, under which head of Section 11; (g) the date the correction was published, and the elapsed time from clause 9.2(a); (h) whether any person was notified individually, and if not, why not; and (i) the reference of the superseded text under clause 9.4.

9.3 An entry SHALL NOT be edited to change what it records. A correction to a correction record is made by a further entry that references the first — the same discipline Section 10 applies to the audit trail, for the same reason.

9.4 The superseded text SHALL remain available with its hash. For every correction at rung R1 or above, the exact bytes of the statement as served immediately before the correction SHALL be retained and made publicly retrievable, together with their SHA-256 digest and the period during which they were served.

9.5 Clause 9.4 uses the mechanism the Programme already operates and invents nothing. Since 25 August 2026 the corpus has been served from files committed to the repository with the SHA-256 of each file published alongside it, on the reasoning recorded in the document manifest that "a public document that cannot be checked against a hash is weaker than one that can" and that "the hash on this page is the statement". The superseded text is published on the same footing: same store, same digest, same page. A superseded text that is retained but cannot be checked against a hash is a claim about history rather than a record of it.

9.6 The Rule Change and Public Consultation Procedure v1.0 §6 — not yet adopted: its notice period ended on 8 September 2026, and its closing protocol of 24 September 2026 recommends adoption on FD-2026-09-04 (MCC-CLS-2026-001 §B.1) — provides that, on adoption, the administration "publishes the file on /transparency/documents with its SHA-256 in the manifest (the platform refuses a listing without a hash); archives the superseded version in 99_Arkiv/ with a cover sheet naming the successor". Clause 9.4 extends the same requirement to corrections that are not adoptions — to pages, notices, register surfaces and figures — because those are where most of the Programme's errors have actually been.

9.7 Where a correction is made to a served page rather than to a file, the retained superseded text is the rendered content as served, not the source that produced it.

9.8 Retention of the superseded text is permanent. It is not a working copy and it is not subject to tidying. (Consultation question 4.)

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10. The registry ledger and the audit trail are corrected differently, or not at all

10.1 A published figure and an issued unit are not the same kind of thing, and this Policy does not treat them as one. A register page is a statement about the ledger; the ledger is the thing itself. Correcting a page changes what the Programme says. Correcting a unit changes what a person holds. The ladder in Section 6 applies to the first and never to the second.

10.2 No ledger entry SHALL be edited or deleted to correct an error. Where units were issued that should not have been, the remedy is cancellation on a defect finding, recorded with its ground and decision reference, and — where the correct quantity is greater than nil — a fresh issuance. This is the mechanism MCC-800 v1.0 art. 51 already provides: cancellation "may be initiated by the Programme Administrator in the following circumstances: (a) discovery of material error in the underlying verification". Cancelled units go to the Cancellation Account "with status CANCELLED and a recorded cancellation reason", and "the cancellation shall be publicly visible on the Public Ledger" (art. 52).

10.3 A serial is never edited. MCC-800 v1.0 art. 30: a serial number, once assigned, "shall never be reused, reassigned, or modified, even if the credit is subsequently cancelled or the batch is voided". The consultation draft MCC-800 v2.0 states the same rule for migration at S1.15 — "A serial is never edited: migration SHALL retire the old serial ... and issue a successor serial ... with a bidirectional cross-reference recorded immutably in the audit trail" — and that is the shape every registry correction takes: a new record that points at the old one, never an overwrite.

10.4 Retirement is not correctable. MCC-800 v1.0 art. 48: "Retirement is irreversible. Once a credit unit has been retired, it may not be reactivated, transferred, or re-retired under any circumstances." An error discovered after retirement is corrected by a published statement about the retirement — a correction note under Section 6 — and by whatever remedy is owed outside the ledger. It is not corrected in the ledger. Cancellation is likewise terminal: the consultation draft MCC-800 v2.0 cl. 5.4 records that "RETIRED and CANCELLED are terminal, and no transition SHALL exist out of them".

10.5 The audit trail is never rewritten. MCC-800 v1.0 art. 65: "Audit records shall be immutable. No audit record may be modified, deleted, or overwritten after creation. The system shall enforce this through database-level constraints and application-level controls." That enforcement exists: the audit_log_entries table carries triggers prevent_audit_update and prevent_audit_delete, both calling a function whose entire body raises 'Audit log entries are immutable and cannot be modified.' A correction policy that implied the history could be tidied would contradict a rule in force and a control that is deployed.

10.6 Where the audit trail itself records something incorrectly, the correction is a compensating entry that references the entry it corrects, never an amendment of that entry. The consultation draft MCC-800 v2.0 cl. 14.3 states the same rule: "corrections SHALL be made only by compensating entries that reference the record they correct."

10.7 A registry correction SHALL be executed under the separation-of-duties control the Registry Operations Standard requires for manual correction of registry data, SHALL be notified to affected holders before it takes effect save where the decision record states why delay would defeat the measure, and SHALL carry the appeal route. Those requirements are the Registry Operations Standard's, not this Policy's, and this Policy does not restate them.

10.8 Nothing in this Section has yet been used. The registry holds zero credit units. No unit has been issued, retired or cancelled, and no defect finding has been made. Section 10 is written before the first issuance deliberately: the rule for correcting a unit is worth nothing if it is written after the first unit needs correcting.

10.9 The removal of the demonstration cohort on 31 August 2026 — 17 projects and 28,769 credit units — was not a registry correction within this Section, because nothing in it was ever an issued unit of the Programme. It was the removal of demonstration data from public surfaces, archived row-level into the schema demo_archive_20260831, which holds those 17 project rows and those 28,769 unit rows today. It is recorded here so that the distinction is on the record: the audit log was deliberately left untouched, and the archive is the superseded text for the purposes of clause 9.4.

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11. Who decides

11.1 Authority to correct is bounded by what is reserved. The rule is: the Programme Administrator may correct a manifest error; anything that changes a rule, a status or a figure the Board set is the Board's.

11.2 The Programme Administrator MAY decide and execute, without further authority:

(a) every R0 correction; (b) every R1 correction, including the removal of a statement under clause 6.4 and 6.7, where the corrected position is a matter of fact that the Administrator can evidence — including the removal of a figure that no record supports, the removal of a claim for which no evidence exists, the correction of a citation to a provision that is not in force, and the addition of a missing register row for an instrument that exists; (c) the preparation of an R2 erratum for adoption on the Tier 5 path; and (d) an interim note under clause 8.2.

11.3 The Governing Board decides, and the Programme Administrator SHALL NOT:

(a) any R3 amendment, and any correction that changes a threshold, a quantity or an obligation an instrument sets; (b) any correction to a figure, amount or status that the Board itself set, or that a decision instrument records as set; (c) any R4 withdrawal of a normative instrument or of an adopted policy; (d) any material restatement within the meaning of Transparency Policy §6.2; and (e) the disposition of any correction where the Programme Administrator has a conflict, including any correction to a statement about the Administrator's own conduct or performance.

11.4 The division in clauses 11.2 and 11.3 implements Transparency Policy §6.1 step 3 — "Correction approved (MCC Board or technical staff, per significance)" — by fixing where significance falls. It follows the line drawn by §11.1 of MCC-700 v3.0 and of MCC-700 v3.1, which the document register records as in force (FD-2026-08-24 item D11): governance procedure amendments require the Governing Board at a 75 % threshold and constitutional amendments require unanimity.

11.5 A correction proposed by a person outside the Programme enters through the Transparency Policy Article 8.1 feedback mechanism and is answered on that route, within its 30 days. A correction request SHALL NOT be declined on the ground that the person making it is not affected by the error.

11.6 Duties attaching on constitution. The Governing Board was constituted on 26 August 2026 (GB-2026-001), with two members; GB-2026-001 is recorded in the decision register as attested by the founder, with no executed copy filed, and the copy on file is marked DRAFT; FD-2026-08-24 records that the board composition "fastsettes ved konstituering og protokolleres da" — is fixed at constitution and minuted then. Accordingly:

(a) every duty this Section places on the Governing Board attaches on its constitution and is exercisable by it from that date; (b) until then, a matter reserved to the Board under clause 11.3 SHALL be prepared by the Programme Administrator, published as a correction note stating the position and identifying what remains undecided (clause 8.5), and placed before the Board at its first meeting competent to take it; and (c) the Programme Administrator SHALL NOT take a reserved decision in the interim, and SHALL NOT record a correction as decided when what has happened is that it was prepared. (Consultation question 5.)

11.7 This Policy assigns no duty to any body that is not constituted other than as clause 11.6 provides. Where an instrument names a body that does not exist, a statement resting on that body's authority is a class C4 error and is corrected as such.

11.8 Whether a standing correction authority should also sit with the Registry Oversight function for class C6, or whether every registry correction should reach the Board, is not decided. MCC-800 v2.0-draft routes defect findings and cancellations through the governance decision matrix; this Policy does not duplicate that routing and takes no position on it. (Consultation question 6.)

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12. Reporting, and publishing the count

12.1 Every correction at rung R1 or above SHALL be reported to the Governing Board. Corrections within the Programme Administrator's own authority under clause 11.2 are reported as executed, not for approval; corrections reserved under clause 11.3 are reported for decision.

12.2 The report SHALL be made at the Board's next scheduled meeting, and immediately where the correction concerns a matter already before the Board, a statement the Board itself approved, or a figure the Board set. A correction that changes a premise of a paper the Board is due to consider SHALL be reported before that paper is taken.

12.3 The Programme SHALL publish, quarterly, a correction summary stating, for the period:

(a) the number of corrections by class (C1–C7) and by rung (R0–R4, RC); (b) the number determined material and the number determined immaterial; (c) the median and longest elapsed time from knowledge to publication, against the periods in clause 8.3, and the number of corrections published outside those periods; (d) the number of corrections that were themselves corrected; and (e) the number of instruments, pages and register rows affected.

12.4 The summary SHALL be published on the same cadence and page as the quarterly transparency reporting MCC-700 §14.4 requires (v3.1, the version the document register records as in force, FD-2026-08-24 item D11), which includes "audit findings and corrective actions". It is a count, not a narrative, and it SHALL NOT be presented in a way that treats a low count as a measure of quality: a programme that corrects a great deal and says so is more transparent than one that corrects a great deal and does not.

12.5 A correction is not withheld, delayed, downgraded a rung, or classified as immaterial in order to keep the count down. Where the count is high, the count is the finding.

12.6 The correction summary SHALL state the number of corrections outstanding — errors known and not yet corrected — and how long the oldest has stood.

12.7 The Correction Register under clause 9.1 carries the detail and the quarterly summary carries the count. (Consultation question 7.)

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13. Corrections to this Policy

13.1 This Policy is amended by the procedure for a Tier 5 instrument.

13.2 A correction to this Policy is subject to this Policy. A silent fix to Section 7 would be the clearest possible breach of it.

13.3 This Policy SHALL be reviewed at the same cadence as the Transparency Policy, which MCC-700 v3.0 §14 and Transparency Policy §9.1 place semi-annually in March and September, and in any event after any quarter in which the correction summary records a correction that was itself corrected more than once.

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Schedule 1 — The ladder applied to the corrections of 31 August to 4 September 2026

Non-normative. Every correction below was made before this Policy existed, and each was made on judgement alone. The schedule states what rung this Policy would have required, so that the Policy can be judged against real cases rather than invented ones. Where the rung taken was right, that is said. Where it was not, that is said too, and clause 7.4 applies.

#	Date	What was wrong	Class	Rung this Policy requires	What was done	Assessment
1	31 Aug	The public register page displayed 605,000 tCO₂e of hard-coded sample credits, which appeared precisely when the database was emptied — a fallback that spoke loudest when it had least to say	C5	R1 — and immediately, under clause 8.3 row 1: a stated credit volume is the single figure a reader of the registry acts on	Removed	Right remedy, no correction note. A reader who saw 605,000 tCO₂e has never been told it was never real. Clause 7.4 regularisation outstanding.
2	31 Aug	A demonstration cohort of 17 projects and 28,769 credit units, plus 9 organisations, 3 VVBs and associated history, was displayed on public surfaces	C5	R1	Deleted from the public schema, archived row-level into demo_archive_20260831; audit log deliberately left untouched	Right remedy and right archive; the archive is the superseded text under cl. 9.4. Note published on the site; no hash published against the archive (cl. 9.5)
3	31 Aug	A fabricated news item was served as a news item	C3	R1, and R4 in substance — the item could not be corrected into truth, only withdrawn	Removed	Right rung. A withdrawal note naming what was claimed (cl. 6.8) is outstanding
4	31 Aug	A mis-cited claims authority — a claims restriction attributed to a provision that did not establish it	C4	R1 at least; R3 if any restriction as applied rested on the mis-cited provision	Corrected; the prohibition's authority is Claims Policy v1.1 Article 4	Right rung, on the basis that nothing had been applied under the wrong citation
5	3 Sep	Five rule-change consultations were open on clause numbers that the successor texts would not contain — the public was being asked to comment on text about to be replaced	C4 (the consultation's own premise)	R1, published notice	Stayed by notice CSN-2026-001, with stayedAt, stayReason and stayDecisionRef all required by database constraint; a separate public "Stayed" section; the comments API answering 409 with the stay reason	The model case. A stay is neither a closure nor a pretence of consultation; the reason travels with the status; zero comments were lost
6	4 Sep	The served privacy notice contained six statements that could not be verified, including analytics cookies where no analytics library is loaded and standard contractual clauses none of which is recorded	C3	R1, within 1 business day	Corrected in place; marked "Interim notice — corrected 4 September 2026. Not an adopted instrument"; each correction described in the MCC-PRIV draft	Right rung, correctly executed. The page was not deleted — cl. 6.4 reasoning: a site with no privacy notice is worse
7	4 Sep	/transparency/system-status was published "under MCC-400 art. 95.1", a provision that arrives with Addendum 1, whose entry into force is stayed by FD-2026-09-03 item D8, and which has never been in force	C4	R4 for the authority, R1 for the page — the citation is withdrawn; the disclosure survives as voluntary	Exactly that: the page now records that it "IS NOT PUBLISHED UNDER MCC-400 ART. 95.1, THOUGH IT ONCE SAID SO", and the substance is kept voluntarily	The model case for C4. Withdrawing an authority without withdrawing a useful disclosure is the distinction Section 6 exists to make
8	4 Sep	The instrument register omitted every annex, so an annex in force and publicly served since 31 August was recorded by two successive reviews as never having existed	C7	R1, plus the structural fix	A parent_code column added, so the register can carry an annexed instrument; register grown from 15 rows to 35	Right remedy. The register now "prints [absence] as a finding rather than an empty cell" — cl. 4.4 is drafted from this case
9	4 Sep	MIR-2026-001 was reissued twice in one day, as revisions 2 and 3, each correcting a finding of the last	C3, twice	R1 each time — and cl. 12.3(d) counts them: a correction that is itself corrected is the metric worth watching	Both reissued	Right rung. Two reissues in a day is not a failure of the register; it is what an honest register looks like while facts are still arriving. It is a failure only if unrecorded
10	4 Sep	The board pack GB-2026-002 v1.0 rested on nine premises that were wrong, including that the Definitions Register was missing (it is in force as an MCC-100 annex), an insurance figure of EUR 1M/2M where the adopted figure is USD 2m/5m, and an evidence-marker count of 52 where the true figure is 42	C3 and C5	R2 in form — one instrument listing each correction as v1.0 → v2.0 with its basis — and R1 timing, immediately, under cl. 12.2: these were premises of a paper then due before the Board	Consolidated into v2.0 with the nine corrections tabulated, superseding v1.0 and four addenda, v1.0 remaining published	Right rung and right form. The consolidation is an erratum in all but name, and it keeps the superseded pack published (cl. 9.4)

What the schedule shows. Ten corrections in five days. Eight took the right rung. Every one of the eight took it by judgement, and two of those judgements — items 5 and 7 — are better than anything a policy would have compelled. The two failures are the same failure in two places: the remedy was right and the note was missing (items 1 and 3). Both concern a figure or a claim that a reader saw and now has no way of knowing was false. That is precisely the case clause 7.2 covers, and it is the reason clause 7.4 exists.

One correction was outstanding when this draft was prepared, and its R1 note has since been published. The consolidated MCC-400 v1.1 text — the text served as the standard in force — states in its own document control that "Section 18 enters into force 17 September 2026", and instructs the reader that Articles 95.1, 99.1 and 103.1 "are operative provisions, not notes". FD-2026-09-03 item D8 stays that entry into force. At the date of this draft the document manifest recorded the stay against the separate "MCC-400 Add.1" row but not against the MCC-400 v1.1 row, so a reader who opened the served standard was told that a section would take effect on a date on which it would not. That was a class C4 error in an instrument in force, material under clause 5.3 (a date and a status), requiring R1 immediately and R2 or R3 to follow. Since 8 September 2026 the MCC-400 v1.1 entry in the document manifest has carried a correction notice stating that Section 18 does not enter into force on 17 September 2026 (PR #300).

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Annex — What consultation is asked to settle

#	Question	This draft's position
1	Is the silent-fix rung (R0) available at all, or should every change to a published statement carry a note?	R0 retained, confined to class C1 by cl. 6.2. A note on every typo would train readers to ignore notes (Consultation question 2.)
2	Is the materiality test right — "what a reader would have done differently"?	Yes, and cl. 5.2 expressly excludes embarrassment. This is the clause most likely to be argued in practice (Consultation question 1.)
3	Should the correction summary name each material correction, or only count them?	Count in the summary, detail in the public Correction Register (cl. 12.7) (Consultation question 7.)
4	Should the 2-business-hour tier in cl. 8.3 apply to any statement, or only to register figures?	Any statement on which a person could act to their detriment within the day (Consultation question 3.)
5	Permanent retention of superseded published text, or a period?	Permanent (cl. 9.8) (Consultation question 4.)
6	Does a correction authority sit with the Registry Oversight function for class C6?	Not taken (cl. 11.8) (Consultation question 6.)
7	Where should this Policy sit in the hierarchy — as a standalone Tier 5 policy, or as an annex to the Transparency Policy whose Article 6 it implements?	A standalone Tier 5 policy, as its document control states; the tier is entered in the Document Register on adoption. The code MCC-REST is assigned by the programme administration for this consultation and entered in the Document Register on adoption. (Consultation question 8.)
8	Should the Transparency Policy Article 6 be amended to cite this Policy, or left as the promise this Policy keeps?	This draft proposes the citation but does not draft it; amending an adopted policy is the Governing Board's (Transparency Policy v1.1 §9.1). (Consultation question 9.)

Eight questions. The first two decide whether the Policy has teeth; the rest decide where it lives.

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Prepared 4 September 2026 for public consultation. Not adopted, not in force, and it corrects nothing by itself.

Evidence — what was checked, 4 September 2026. (1) The 34 in-force texts in the review corpus, searched for "correct", "restate", "erratum", "errata", "amend", "withdraw", "republish", "material change" and "notice"; MCC-800 v1.0 art. 16, 26, 30, 48, 50–52, 63, 65, 66 and art. 111–113 read in full; MCC-700 v3.0 §11.1, §12.2, §13, §14.1–14.5 read in full; MCC-400 v1.1 consolidated document control, "How to read this text", art. 95, 95.1, 109 and 114, and MCC-400 Addendum 1; MCC-100 v2.1 cl. 0040, 0205, 0249, 0256 and the Appendix note on the Amendment 1 cross-reference. (2) apps/web/content/adopted/: transparency-policy.md in full (Articles 4, 6, 7, 8, 9 and the v1.1 change log), definitions-register.md §4, claims-policy.md Article 4, fd-2026-08-24.md items D1–D16, and mcc-800-reissue-note.md in full; apps/web/src/lib/documents/manifest.ts (the SHA-256 mechanism and its rationale, and the revision state of every published standard). (3) apps/web/content/proposals/: guidance-errata-1-f01-f02-f05.md in full as the errata reference form, rule-change-consultation-procedure-v1-0.md in full (§§1–9), mcc-800-registry-operations-v2-0-draft.md (cl. 4.2, 5.4, 6.1–6.3, 10.6, 11.1–11.5, 14.3, 15.1, 15.3, 17.2, S1.15), and mcc-fees-fee-schedule-v1-0-draft.md for the house document-control form. (4) The served application: src/app/privacy/page.tsx, src/app/transparency/system-status/page.tsx, src/app/governance/instruments/page.tsx and src/lib/registers.ts (the parent_code field and the MIR-2026-001 rev 2 §7 finding it records). (5) Supabase project ifflkkpowmzjoochwavf, read-only: audit_log_entries carries triggers prevent_audit_update and prevent_audit_delete on function audit_immutable, and holds 240 rows; credit_units holds 0 rows; projects 2; document_register 35; stakeholder_consultations 5 STAYED and 8 OPEN; decision_register 6; and schema demo_archive_20260831 holds 17 archived project rows and 28,769 archived credit-unit rows. No clause number, figure, date or body in this draft is stated without one of those sources behind it. Nothing in the database was written.