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RULE CHANGE · Tier 5 — Operational policies, procedures, templates, guidanceOPEN FOR COMMENT

MCC-FEES Fee Schedule v1.0 — new instrument

New schedule required by MCC-800 art. 99 (a "Registry Fee Schedule") and MCC-400 art. 84 ("the MCC Fee Schedule") (code MCC-FEES proposed)

Opened 22 October 2026Closes 21 November 2026 · 30-day notice (floor 14)18 days left

What is being consulted on

The schedule two standards require and the programme has never had in force. It sets no fee. Reading the public register is free under an instrument in force (MCC-100 cl. 0205). Retirement free of charge, and the transfer and VVB figures, are read two ways in the record — adopted under FD-2026-08-24 item D9 and ratified by GB-2026-001, or reserved to the Governing Board under FD-2026-09-04 item 6 — and the Board is asked which reading stands; FD-2026-10-01 Schedule 1 (C6) proposes the figures to it: retirement and the public API free of charge, a transfer fee of 0.25 % with a minimum of EUR 25, and VVB fees of EUR 2,500 on application, EUR 1,500 a year and EUR 500 per engagement. Every other line is RESERVED, or UNPRICED where an instrument requires a fee that no one has ever proposed. It records that the applicant tariff is published as settled in Applicant Terms art. 5 and Transparency Policy §2.9; that the issuance-fee bands are keyed to a superseded taxonomy, so that F04 — the family of both project submissions in the register — is priced as "Peatland"; and that the transfer and VVB figures enter the record through MCC-BDR-2026-002, recorded as unsigned. The registry database holds no fee, invoice, payment or billing table.

Decision by
Governing Board, on adoption of the suite (FD-2026-10-01 Schedule 1, C4; FD-2026-08-24 item D11); fee amounts under MCC-800 art. 99 and MCC-400 art. 84
After closing
Every material comment receives a written response; the closing protocol is published here; the decision cites the proposal by its hash; on adoption the text is published at /transparency/documents with a version bump and this consultation is linked from it.
Proposal SHA-256
ed3da2895301e9375251990603e4079b5577b7d2c57731e95cf77405b782372f
Source file
MCC-800 art. 99–102; MCC-400 art. 84–86; MCC-100 cl. 0052(d), 0205, 0294(c); Applicant/Registry/VVB Terms and Transparency Policy §2.9 as served; MIR-2026-001 rev 3 §3.3

Proposal text hash ed3da289…b782372f

MCC-FEES — Fee Schedule v1.0-draft

Document control

Field Value
Document code MCC-FEES (code assigned by the programme administration for this consultation; entered in the Document Register on adoption)
Title Fee Schedule
Version 1.0-draft
Status DRAFT — FOR CONSULTATION
Date of this draft 4 September 2026
Tier Tier 5 (operational schedule). The amounts are the Board's; the schedule is the instrument that carries them.
Effective date None. This schedule is not in force, and it sets no fee.
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-800 art. 99–102 (Registry Fees and Charges); MCC-400 art. 84–86 (Accreditation Fees); MCC-100 cl. 0052(d), 0144(e), 0205 and 0294(c); Applicant Terms art. 5; Registry Terms art. 11; VVB Terms art. 10; Transparency Policy §2.9; FD-2026-08-24 item D9 (the amounts B2–B5, among them retirement free of charge), GB-2026-001 resolution 2.1 (ratification of FD-2026-08-24 in its entirety) and FD-2026-09-04 items 4 and 6, each recorded in the decision register as attested by the founder, with no executed copy filed; MIR-2026-001 rev 2 §3.3; board pack GB-2026-002 draft resolution 2.3 and action A5, prepared for a Governing Board meeting on 23 September 2026 of which no record has been filed.
Supersedes None (new document). On entry into force it becomes the only place an MCC fee amount is stated.
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). This schedule sets no fee. Every line is marked DECIDED (an amount fixed by an instrument in force), RESERVED (to the Board, with any figure that has been proposed to it) or UNPRICED (required by an instrument and never proposed by anyone); retirement is marked DECIDED or RESERVED, because the record supports both readings (2.1); and some reserved amounts are already published today although no instrument in force sets them (3.1; FD-2026-09-04 item 4). Fees are the Governing Board's under MCC-800 art. 99 and MCC-400 art. 84, and nothing here anticipates that decision.

It was drafted because board pack action A5 would forbid communicating any fee figure until it was reconciled against the Fee Schedule — and no Fee Schedule existed. That pack (GB-2026-002, with its draft resolution 2.3) was prepared for a Governing Board meeting on 23 September 2026, of which no record has been filed. FD-2026-09-04 item 4 has since resolved to the same effect that no fee figure is quoted to any applicant or published as a price until the Board has set it; FD-2026-09-04 is recorded in the decision register as attested by the founder, with no executed copy filed. A prohibition measured against a document that does not exist cannot be discharged. This is the document to reconcile against.

Nothing has been charged. The registry platform has no fee, invoice, payment or billing table, and the registry records no fee invoiced to or collected from any party, the two project submissions it holds included (Evidence Register ER-2026-001 §A3; FD-2026-10-01 Schedule 1, Q14; registry database measured on 5 October 2026).

Consultation questions

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

1. Clause 2.1 and line R5 — retirement, and the public API, free of charge. Proposed: retirement is free of charge, as a deliberate integrity signal, and the public API is free of charge; whether access above the API's standard rate limit is chargeable is put separately (question 7). Basis: FD-2026-10-01 Schedule 1 (C6); FD-2026-08-24 item D9 (B4), which adopted retirement at €0, and GB-2026-001 resolution 2.1, which ratified FD-2026-08-24 in its entirety, each recorded in the decision register as attested by the founder, with no executed copy filed; the MCC-100 Annex — Definitions Register v1.0 §4, which the document register records as in force and which states the retirement fee as €0; MCC-100 cl. 0205; Registry Terms art. 9.1 and 11.1. The record supports two readings — that retirement free of charge is already decided by those instruments, or that it is reserved to the Board with every other fee amount (MCC-800 art. 99; FD-2026-09-04 item 6) — and this Schedule does not choose between them (cl. 2.1). Decided by: the Governing Board on adoption of the suite (MCC-800 art. 99). Comments are invited on whether retirement and the public API should remain free of charge, and on which reading of the record should stand.

2. Lines A1 to A3 and clause 3.1 — the applicant tariff. Proposed: no proposal is made — FD-2026-10-01 Schedule 1 (C6) proposes no registration, annual monitoring or issuance fee. The figures in lines A1 to A3 are those Applicant Terms art. 5 prints — €500 (SIDS/LDCs) or €1,000 on registration, €1,000 or €2,000 a year for monitoring, and €0.15 to €0.25 per credit issued — which its change log says are to be read as proposed until the Board has set the fee schedule, and which Transparency Policy §2.9 republishes with a worked example. Basis: Applicant Terms art. 5 and its change log; Transparency Policy §2.9; FD-2026-09-04 item 4, which notes that no instrument in force sets those amounts (recorded in the decision register as attested by the founder, with no executed copy filed). Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-800 art. 99; FD-2026-09-04 item 6). Comments are invited on the amounts, and on whether the figures already published to applicants should stand, be changed or be withdrawn.

3. Line A3 and clause 3.2 — whether the issuance fee varies by family, and on which keys. Proposed: no proposal is made on whether the issuance fee should vary by family; no figure is published against a family key until the keys are the families of the Definitions Register v1.0 §2 (cl. 3.2). Basis: cl. 3.2 as drafted; Applicant Terms art. 5.3; the Definitions Register v1.0 §2 (FD-2026-08-24 item D5). The family boundaries are themselves open: FD-2026-09-03 item D2 sets out a different family map, on which MCC-200 v3.0-draft §4.2, put to consultation with this suite, is drafted, and which places ghost-gear recovery in F03 where the Definitions Register places it in F04; FD-2026-08-24 and FD-2026-09-03 are each recorded in the decision register as attested by the founder, with no executed copy filed. Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-800 art. 99; FD-2026-09-04 item 6). Comments are invited on whether the issuance fee should vary by family at all, and if so on which family keys.

4. Lines A4 and A5, and clauses 1.2 and 7.3 — the listing fee and the reinstatement fee. Proposed: no proposal is made — neither fee has been priced anywhere in the programme record, and until an amount is set the precondition that cites it is satisfied without payment (cl. 1.2). Basis: MCC-100 cll. 0052(d) and 0294(c); cll. 1.2 and 7.3 as drafted. Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (FD-2026-09-04 item 6). Comments are invited on whether each fee should be priced or the precondition that cites it deleted, and on whether the listing fee is the registration fee under another name.

5. Lines R1 and R2 — account registration and annual account maintenance. Proposed: no proposal is made for account registration, or for the maintenance of any account type other than Buyer/Holder accounts, which Registry Terms art. 11.2 proposes be free; until the Board determines a maintenance fee none is charged (Registry Terms art. 11.2). Basis: MCC-800 art. 99(a) and (b); Registry Terms art. 11.2. Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-800 art. 99; FD-2026-09-04 item 6). Comments are invited on whether either fee should be charged, and for which account types.

6. Line R4 and clause 3.3 — the credit transfer fee, and how a transfer with no stated price is valued. Proposed: a transfer fee of 0.25 % with a minimum of EUR 25; no rule is proposed for valuing a transfer that has no stated price. Basis: FD-2026-10-01 Schedule 1 (C6); Registry Terms art. 11.1, which states the fee as 0.25 % of transaction value, minimum EUR 25 per transfer, under its proposed fee structure; FD-2026-08-24 item D9 (B4), which adopted the same figures and which GB-2026-001 ratified, each recorded in the decision register as attested by the founder, with no executed copy filed; MCC-BDR-2026-002 decision D-2026-08-06, recorded in the decision register as unsigned (provenance at 3.3). Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-800 art. 99; FD-2026-09-04 item 6). Comments are invited on the rate and the minimum, and on how a transfer with no stated price should be valued.

7. Line R6 — data export and API access above the standard rate limit. Proposed: no proposal is made — access within the standard rate limit is free (MCC-100 cl. 0205), and the instruments in force publish that limit two ways: 100 requests a minute per IP address (MCC-800 art. 78) and 1,000 requests a day per IP address (Registry Terms art. 9.1; Transparency Policy art. 5.2). Basis: MCC-800 art. 78 and art. 99(f); Registry Terms art. 9.1; Transparency Policy art. 5.2. Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-800 art. 99; FD-2026-09-04 item 6). Comments are invited on whether access above the standard limit should be chargeable at all, and on which limit should be the standard.

8. Lines V1 to V6 and clause 4.3.1 — VVB fees payable to the Programme. Proposed: EUR 2,500 on application, EUR 1,500 a year and EUR 500 per engagement; no figure is proposed for accreditation renewal, scope extension or witness audits. Basis: FD-2026-10-01 Schedule 1 (C6); VVB Terms art. 10.1 to 10.3; FD-2026-08-24 item D9 (B5), which adopted the same figures and which GB-2026-001 ratified, each recorded in the decision register as attested by the founder, with no executed copy filed; MCC-BDR-2026-002 decision D-2026-08-07, recorded in the decision register as unsigned (provenance at 3.3). The per-engagement fee is not one of the five categories of MCC-400 art. 84 (line V6). Decided by: the Governing Board on adoption of the suite; every fee amount is reserved to it (MCC-400 art. 84; FD-2026-09-04 item 6). Comments are invited on the amounts, on whether a per-engagement fee should be a fee category at all, and on how renewal, scope extension and witness audits should be priced.


1. Purpose, scope and application

1.1 This Schedule states every fee the Programme charges or proposes to charge, in one place. On entry into force no other Programme document SHALL state a fee amount; the amounts in Applicant Terms art. 5, Registry Terms art. 11, VVB Terms art. 10 and Transparency Policy §2.9 are replaced by a citation to this Schedule, and any amount surviving elsewhere is void to the extent of the divergence.

1.2 A fee exists only when this Schedule states it. Where a Programme document makes payment of a fee a precondition to a step — MCC-100 cl. 0052(d) makes payment of a listing fee a completeness-check requirement, cl. 0144(e) makes payment of accreditation fees an accreditation requirement, and cl. 0294(c) makes payment of a reinstatement fee a reinstatement requirement — and this Schedule states no amount for it, that precondition is satisfied without payment until an amount is set. A gate keyed to a price that does not exist is not a gate.

1.3 This Schedule does not create a power to charge. That power is in MCC-800 art. 99 (registry fees, Board-approved) and MCC-400 art. 84 (VVB accreditation fees, Board-set, "published in the MCC Fee Schedule" — this one).

1.4 A fee, once set, is charged to fund the Programme's own operation. The Programme's revenue model is to rest on programme fees and not on margins on credits — the position the Foundational Decisions paper recorded in March 2026, a document since retired by FD-2026-08-24 item D15 (recorded in the decision register as attested by the founder, with no executed copy filed) — and MCC-800 art. 100 requires fees to cover operational cost "without generating excessive surplus".


2. What is actually decided

2.1 One fee position rests on an instrument in force and is not in question: reading the public register is free (MCC-100 cl. 0205). A second, retirement free of charge, is read two ways in the record. On one reading it is decided: FD-2026-08-24 adopted "the amounts B2–B5", retirement at €0 among them (item D9, B4); GB-2026-001 ratified FD-2026-08-24 in its entirety (resolution 2.1); and the Definitions Register v1.0, which the document register records as in force, states the retirement fee as €0 (§4). On the other it is reserved: the retirement fee is one the Governing Board approves (MCC-800 art. 99(e)); FD-2026-09-04 item 6 lists every fee amount among the matters an instrument in force reserves to the Board, and does not decide them; and FD-2026-10-01 sets no fee and puts retirement free of charge to the Board as a proposal (item 6; Schedule 1, C6). FD-2026-08-24, GB-2026-001 and FD-2026-09-04 are each recorded in the decision register as attested by the founder, with no executed copy filed. This Schedule does not choose between the two readings: it proposes the €0 to the Board on either, and asks the Board to say which reading stands. (Consultation question 1.) Every other amount is treated in this Schedule as reserved to the Board or as unpriced; the transfer and VVB figures, which FD-2026-08-24 item D9 also adopted, are read two ways in the same manner (3.3).

Fee Amount Authority Status
Retirement of a credit €0 FD-2026-08-24 item D9 (the amounts B2–B5; retirement at B4), carried in the MCC-100 Annex — Definitions Register v1.0 §4 DECIDED or RESERVED — the record supports both readings (2.1). FD-2026-08-24 item D9 adopted the amount and GB-2026-001 ratified that decision; the Definitions Register, which the document register records as in force, states the fee as €0; FD-2026-09-04 item 6 treats every fee amount as reserved to the Board (MCC-800 art. 99(e)). Retirement free of charge is proposed to the Board on either reading (FD-2026-10-01 Schedule 1, C6), as a deliberate integrity signal. A programme that charges to retire is paid to discourage retirement. (Consultation question 1.)
Reading the public register €0 MCC-100 cl. 0205 — registry data "publicly accessible without requiring login or fee payment" DECIDED. MCC-100 is recorded in the document register as in force (v2.2). Extends to the public API within its standard rate limit (Registry Terms art. 9.1; see R6); FD-2026-10-01 Schedule 1 (C6) proposes that this Schedule state the public API free of charge. (Consultation question 1.)

2.2 No other fee position rests on an instrument in force.


3. Three defects this Schedule exists to close

3.1 The applicant tariff is published as settled; nothing settles it. Applicant Terms art. 5 states registration, annual monitoring and issuance fees as firm amounts, with no reservation in the article itself — its change log says both that the rates are to be read as proposed until the Board has set the fee schedule and that the fees were adopted with the stated values (B2–B5), items that set no applicant fee — and Transparency Policy §2.9 republishes them as "Fee Schedule (Public)" with a worked example totalling €9,500 in year one. Registry Terms art. 11 and VVB Terms art. 10 mark their own figures "subject to Board decision". Two treatments of the same question in the same corpus: on 24 August 2026 the fee articles of the Registry and VVB Terms were rewritten as proposals, while Applicant Terms art. 5 received only the change-log note and Transparency Policy §2.9 still prints the figures without any reservation. An applicant reading the published documents today is told a price the Programme has not decided.

3.2 The issuance-fee bands are keyed to a taxonomy that no longer exists. Applicant Terms art. 5.3 prices "Mangrove (F01), Seagrass (F02): €0.15" and "Kelp (F03), Peatland (F04), Tidal Flat (F05): €0.20". The canonical families, registered in the Definitions Register v1.0 §2 under FD-2026-08-24 item D5, are F01 Blue Carbon · F02 Restoration (kelp classified here) · F03 Fisheries · F04 Pollution Prevention · F05 MPA Management. Seagrass is F01, not F02; kelp is F02, not F03; and F04 — the family of both project submissions the register holds — is priced as "Peatland", which is not what F04 is. A developer cannot read their own price off the tariff. No figure may be published against a family key until the keys are the canonical ones.

3.3 The figures trace to a defective record. The transfer fee (0.25 % of value, minimum EUR 25) and the VVB fees (EUR 2,500 / 1,500 / 500) enter the corpus through MCC-BDR-2026-002 items B4 and B5 (decisions D-2026-08-06 and D-2026-08-07, 17 August 2026); item B4 also resolves that retirement is free of charge and the public API free. That record is an unsigned reconstruction of a meeting of a board not then constituted, and the decision register records it as unsigned; its disposal is reserved to the Governing Board (FD-2026-09-04 item 6) and was to be taken at a Governing Board meeting on 23 September 2026, of which no record has been filed. FD-2026-08-24 treats the matters of that draft as decided (item D3) and adopts "the amounts B2–B5" (item D9); it is recorded in the decision register as attested by the founder, with no executed copy filed, and GB-2026-001, recorded in the same way, ratified FD-2026-08-24 in its entirety (resolution 2.1), which the decision register describes as ratification as to substance. Registry Terms art. 11.1 and VVB Terms art. 10 nonetheless print these figures as proposed and "subject to Board decision", although the change log of each records that the values the draft had marked as proposals, fees among them, were adopted with the stated values (B2–B5); and FD-2026-09-04 item 6 lists every fee amount among the matters reserved to the Board. The record therefore supports two readings of these figures, as it does of retirement (2.1). They are recorded here as proposals, with their provenance, because FD-2026-10-01 Schedule 1 (C6) puts them to the Board, which is asked to say which reading stands.


4. The Schedule

Every row states: the fee, the amount, and its status — DECIDED (instrument in force), RESERVED (the Board's, with any proposal on the table), or UNPRICED (required by an instrument, never proposed by anyone).

4.1 Applicant and project fees

# Fee Amount Status
A1 Registration fee, on application Proposed €500 (SIDS/LDC) / €1,000 (other) RESERVED. Published as settled in Applicant Terms 5.1 and Transparency Policy §2.9 — see 3.1. (Consultation question 2.)
A2 Annual monitoring fee Proposed €1,000 (project < 50,000 credits) / €2,000 (≥ 50,000) RESERVED. Same defect as A1. The threshold is expressed in credits a project has not yet been issued.
A3 Issuance fee, per credit Proposed €0.15–€0.25, by family and, at €0.25, for complex projects RESERVED, and not publishable until the family keys are corrected (3.2). (Consultation question 3.)
A4 Listing fee (MCC-100 cl. 0052(d)) — UNPRICED. A completeness-check precondition with no amount anywhere. Either it is the registration fee under another name, in which case cl. 0052(d) should say so, or it is a second fee nobody has proposed. (Consultation question 4.)
A5 Reinstatement fee (MCC-100 cl. 0294(c)) — UNPRICED. A precondition to reinstatement after non-compliance, never priced. (Consultation question 4.)

4.2 Registry fees — the six categories of MCC-800 art. 99

# Category (MCC-800 art. 99) Amount Status
R1 (a) Account registration — UNPRICED. No figure has been proposed for any account type. (Consultation question 5.)
R2 (b) Annual account maintenance — RESERVED. Registry Terms art. 11.2 records the question as open and states that no account maintenance fee is charged until it is determined; that interim position is carried here unchanged. Of the four account types it lists, it proposes that Buyer/Holder accounts be free and states no figure for the others. (Consultation question 5.)
R3 (c) Credit issuance, per credit See A3 RESERVED. MCC-800 art. 99(c) and Applicant Terms 5.3 describe one charge, not two. It is stated once, at A3.
R4 (d) Credit transfer, per transaction Proposed 0.25 % of transaction value, minimum EUR 25 RESERVED — provenance at 3.3. A percentage-of-value fee also requires a rule for valuing a transfer that has no stated price; none exists. (Consultation question 6.)
R5 (e) Credit retirement, per credit €0 DECIDED or RESERVED — the record supports both readings; see 2.1. (Consultation question 1.)
R6 (f) Data export and API access above standard rate limits — UNPRICED. Standard-rate access is free (MCC-100 cl. 0205). The instruments in force publish the standard limit two ways — 100 requests a minute per IP address (MCC-800 art. 78) and 1,000 requests a day per IP address (Registry Terms art. 9.1; Transparency Policy art. 5.2) — so what lies "above standard" is unsettled, and no charge for it has been proposed. (Consultation question 7.)

4.3 VVB fees payable to MCC — the five categories of MCC-400 art. 84

# Category (MCC-400 art. 84) Amount Status
V1 (a) Initial accreditation application and assessment Proposed EUR 2,500 RESERVED — provenance at 3.3.
V2 (b) Annual accreditation maintenance Proposed EUR 1,500 a year, per accreditation RESERVED — provenance at 3.3.
V3 (c) Accreditation renewal — UNPRICED.
V4 (d) Scope extension — UNPRICED.
V5 (e) Witness audits — UNPRICED. A witness audit is a real cost borne by the Programme and priced by nobody.
V6 Per-engagement oversight fee Proposed EUR 500 per engagement RESERVED. Note that this is not one of the five categories MCC-400 art. 84 lists: VVB Terms art. 10.3 creates a sixth. Either art. 84 is extended or the fee goes.

4.3.1 VVB Terms art. 10 proposes figures for two of the five categories MCC-400 requires, and adds one the Standard does not have. Renewal, scope extension and witness audits — V3, V4, V5 — have never been priced or proposed by anyone. No VVB is accredited today, so nothing is prejudiced; the gap is recorded rather than closed by invention. (Consultation question 8.)

4.3.2 Fees a VVB charges a developer are not MCC's. MCC-400 art. 85–86 make them a commercial matter, and art. 86 forbids the Programme Administrator to set or cap them while permitting investigation where a fee arrangement appears to compromise independence. Applicant Terms 5.4 says the same. The market ranges quoted there (€5,000–€20,000 per validation; €5,000–€15,000 per verification) are not Programme fees and are not part of this Schedule.

4.3.3 No AI-discounted fee range will be published. The stayed MCC-400 Addendum 1 §18.7 required the Programme Administrator to publish an indicative fee range for AI-augmented engagements, priced on "the reduced primary measurement effort enabled by the AI Analysis Layer". MCC-400 v2.0-draft cl. 18.3 forbids the Programme or any VVB to publish, promise or price any fee or effort reduction premised on AI outputs, because under that Standard no such reduction exists. This Schedule follows the successor: there is no AI tariff, and there will not be one.

4.4 Waivers and reductions

W1 MCC-800 art. 102 permits fee waivers or reductions for least-developed-country project developers and academic institutions, at the discretion of the Programme Administrator and subject to Governing Board approval. That power is carried unchanged.

W2 Every waiver granted SHALL be recorded with its reason, and the number and total value of waivers SHALL be published annually. A discretionary discount that is not counted in public is a discount whose fairness cannot be checked.

W3 No waiver may be granted for a fee this Schedule has not set. There is nothing to waive.


5. Rules that bind this Schedule

5.1 Who decides. Registry fees are approved by the Governing Board (MCC-800 art. 99); VVB accreditation fees are set by the Governing Board (MCC-400 art. 84). The Programme Administrator prepares and publishes; it does not set.

5.2 Level. Fees SHALL be set to cover the operational cost of the function they pay for, without generating excessive surplus (MCC-800 art. 100). Each amount adopted SHALL be published with the cost it is intended to cover (Transparency Policy §2.9 "Cost Justification").

5.3 Notice. The Schedule SHALL be reviewed annually, and a change SHALL take effect no earlier than 90 days after publication of the revised Schedule (MCC-800 art. 101). A fee increase that takes effect on announcement is a fee increase nobody could plan for.

5.4 A fee already invoiced. Where a fee is reduced or removed, the change applies from its effective date only; where a fee is introduced, it does not apply to a step already completed.

5.5 Publication. This Schedule is published in full, with the worked examples §2.9 requires, and the examples SHALL be regenerated from it whenever an amount changes. Until amounts are adopted, the worked example in Transparency Policy §2.9 SHALL be marked as an illustration — as §2.6, §2.7 and §2.5 of that Policy already mark theirs — because it presently reads as a quotation of real prices. FD-2026-09-04 item 4 resolved the same marking; it has not yet been made.

5.6 No fee may rest on a component that is not operating. No requirement, timeline, sampling reduction or fee expectation may rest on an AI Analysis Layer component recorded as not operational. That rule is MCC-400 art. 95.1, in Addendum 1, whose entry into force is stayed by FD-2026-09-03 item D8, and MCC-850 v1.2 records it (Appendix B.4); MCC-400 v2.0 cl. 10.3, on that Standard's entry into force, removes the question by allowing no AI-premised reduction in any state.


6. Until this Schedule is in force

6.1 The Programme charges nothing it cannot cite. No amount in §4 marked RESERVED or UNPRICED is invoiced, quoted as a price, or represented to any party as the price. As to invoicing, this is the position today in fact as well as in principle: the platform has no billing capability at all. As to quotation it is not yet the position in fact: Applicant Terms art. 5 and Transparency Policy §2.9 still state the applicant tariff as prices (3.1).

6.2 No fee figure is communicated externally until the Board has decided it. FD-2026-09-04 item 4 states that rule, and board pack action A5, with draft resolution 2.3, proposed it (NOTE above). §4 is the reconciliation the pack called for: a figure may be communicated when, and only when, it appears in §2 or §4 marked DECIDED and not also marked RESERVED.

6.3 A party who asks what a step costs SHALL be told, in terms: that the Programme has not set the fee, that no fee is payable for that step today, and when the Board is expected to decide.


7. Maintenance

7.1 This Schedule is amended by the procedure for a Tier 5 instrument. A change to an amount requires the Board decision that MCC-800 art. 99 and MCC-400 art. 84 reserve to it; a change to the drafting does not.

7.2 When an amount is adopted, the row moves from RESERVED or UNPRICED to DECIDED, cites the adopting instrument, and the 90-day notice of cl. 5.3 begins.

7.3 Where an instrument creates a fee precondition without an amount — as MCC-100 cl. 0052(d) and cl. 0294(c) do — the Programme Administrator SHALL either propose an amount or propose the deletion of the precondition, and SHALL not leave it standing unpriced through a second annual review.


Annex — What the Board must decide

# Question Proposal on the table
1 The applicant tariff: registration, annual monitoring and issuance fees — and whether the figures already published to applicants stand, are changed, or are withdrawn €500/€1,000 · €1,000/€2,000 · €0.15–€0.25 per credit, as printed in Applicant Terms art. 5; none of them is proposed under FD-2026-10-01 Schedule 1 (C6) (Consultation question 2.)
2 Whether the issuance fee varies by family at all, and on what canonical keys Bands exist but are keyed to a superseded taxonomy (3.2) (Consultation question 3.)
3 The credit transfer fee, and how a transfer with no stated price is valued 0.25 %, minimum EUR 25 (FD-2026-10-01 Schedule 1, C6), of transaction value (Registry Terms art. 11.1) (Consultation question 6.)
4 Account registration and annual account maintenance None proposed, except that Registry Terms art. 11.2 proposes that Buyer/Holder accounts be free; no maintenance fee charged today (Consultation question 5.)
5 The five VVB categories of MCC-400 art. 84, and whether the per-engagement oversight fee is a sixth EUR 2,500 · EUR 1,500 · EUR 500 (FD-2026-10-01 Schedule 1, C6); renewal, scope extension and witness audits unpriced (Consultation question 8.)
6 The listing fee and the reinstatement fee: price them, or delete the preconditions that cite them None proposed (Consultation question 4.)
7 Whether data export and API access above the standard rate limit is chargeable, given that the instruments in force publish that limit two ways None proposed (Consultation question 7.)
8 Whether retirement free of charge, which the Definitions Register v1.0 §4 states, is already decided or remains reserved (2.1); whether it remains free of charge; and whether this Schedule states the public API free of charge Both free of charge (FD-2026-10-01 Schedule 1, C6) (Consultation question 1.)

Eight decisions. Until they are taken, the honest answer to "what does this cost?" is the one at cl. 6.3.


Prepared 4 September 2026 for public consultation. Evidence: MCC-800 art. 99–102; MCC-400 art. 84–86; MCC-100 cl. 0052(d), 0144(e), 0205, 0294(c); Applicant Terms art. 5, Registry Terms art. 11 and VVB Terms art. 10 as served; Transparency Policy §2.9; FD-2026-08-24 item D9; MCC-BDR-2026-002 items B4 and B5; MCC-400 v2.0-draft cl. 18.3; and a check of the registry database on 4 September 2026, repeated on 5 October 2026, which holds no fee, invoice, payment or billing table. Read again on 5 October 2026 against the decision, document and consultation registers and FD-2026-10-01 Schedule 1. No decision in this draft has been taken, and no fee in it is set.

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