MCC-BPM — Buffer Pool Management Policy

Document control

Field	Value
Document code	MCC-BPM
Title	Buffer Pool Management Policy
Version	2.0-draft
Status	DRAFT — FOR CONSULTATION
Date of this draft	3 September 2026
Tier	Tier 3 (Document Hierarchy & Precedence Register, per FD-2026-09-03 item D5)
Effective date	None. This document is not in force. It takes effect only on approval under clause 17.1.
Document owner	Programme Administrator (transitional, until a Secretariat is staffed — FD-2026-10-01 Schedule 1, C3)
Approved by	Not approved. Prepared for public consultation.
Decision basis	Founder Decisions FD-2026-09-03, items D1–D8 (adopted 3 September 2026 in the programme working channel; tabled for ratification by the Governing Board). FD-2026-09-03 is recorded in the decision register as attested by the founder on 7 September 2026; no executed copy has been filed (the register at /governance/decisions shows its status).
Supersedes	MCC Buffer Pool Management Policy v1.0 (document reference MCC-BPM-v1.0, March 2026, printed status APPROVED) — reclassified by FD-2026-09-03 item D5; the document register records it as in force until this version is adopted, when its withdrawal as a controlled copy is executed (FD-2026-09-07 item A8: scheduled, not executed). See the baseline declaration below.
Normative schedule	Schedule 1 — Durability Classification, version 1.0-draft, published for consultation together with this draft as a normative part of this Policy
Companion instrument	Non-Permanence Risk Tool, document code MCC-NPRT, version 1.0-draft (Tier 4), published for consultation together with this draft
Language convention	British English; RFC-style normative verbs (SHALL/MUST = mandatory; SHOULD = recommended, deviation to be documented; MAY = optional). Canonical registry enumeration values and status labels are quoted verbatim from the adopted control tables and retain their spelling.
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)

Baseline declaration and version-identity resolution

The controlled identity of the predecessor text is defective and is resolved here by declaring a new baseline:

1. The circulated MCC Buffer Pool Management Policy v1.0 PDF displays "Status: APPROVED" but contains no document-control table at all — no version history, owner, approval body, decision-record reference or effective date (Phase 0 source inventory: one of seven corpus documents printing APPROVED with no document-control apparatus). Its table of contents page is blank, and several of its risk and release tables split across pages with isolated rows (audit §6.4).
2. No signed approval instrument for the predecessor exists in the programme record (SYS-14). The programme's document corpus was searched for one on 3 September 2026 (Evidence Register ER-2026-001 §B3).
3. The predecessor expands "MCC" as "Methodological Carbon Credits" (clause 0001) and defines MCC-CC as "Carbon Capture & Storage Credits" (clause 0002), against the canonical expansion Marine Conservation Credits and the canonical Unit/Product Dictionary (BUF-01 CRITICAL; SYS-01).
4. The predecessor's release architecture is internally contradictory: release after a 10-year guarantee (clause 0122), family-differentiated schedules (clauses 0122.1–0122.2), 25% release at year 0 (clause 0124), a uniform schedule "regardless of credit type or risk level" (clause 0137), and no release before guarantee completion (clause 0138) coexist (BUF-07 CRITICAL).
5. The predecessor assigns family F05 two different credit types and buffer treatments in the same document — MCC-MCU with a 0% rate in the Buffer Rate table against MCC-HYB with a +10-percentage-point uplift in clauses 0069.2–0069.3 (Phase 0 finding; under-stated by the audit). Both treatments are extinguished by Founder Decisions D1 (MCC-HYB abolished; MCC-MCU renamed and re-scoped) and D2 (canonical family map: F05 is MCC-MOU only).
6. The predecessor buffers risks that are not stored-carbon reversal exposure — avoided emissions, baseline uncertainty and leakage (clauses 0011–0016, 0069.3, 0122.2) (BUF-02 CRITICAL; SYS-13).

Resolution. This version 2.0-draft is declared the new baseline of MCC-BPM. It is rebuilt from the canonical control tables adopted under FD-2026-09-03 and confines the buffer pool to the quantified reversal/non-permanence exposure of stored carbon, the single-source rule for which is MCC-700 clause 16.3. The predecessor is reclassified by FD-2026-09-03 item D5; the document register records it as in force until this version is adopted, when the withdrawal of its PDF as a controlled copy, and its archiving as a superseded record, are executed (FD-2026-09-07 item A8: scheduled, not executed). Version 1.x is not re-used for any consolidation.

Change history

Version	Date	Change	Instrument
1.0	March 2026 (printed)	Initial policy; printed status APPROVED; no document-control table	No such instrument is in the programme record (Evidence Register ER-2026-001 §B3).
2.0-draft	3 September 2026	Full rewrite against the independent audit of 3 September 2026 (findings SYS-01, SYS-02, SYS-09, SYS-13, SYS-14 and BUF-01 to BUF-11) and Founder Decisions FD-2026-09-03 D1–D8: buffer scope confined to stored-carbon reversal exposure; instrument and family applicability generated from the canonical control tables (MCC-HYB and MCC-MCU treatments removed; F05 double treatment extinguished); flat and default contribution rates abolished in favour of per-project risk assessment under the Non-Permanence Risk Tool within consultation-proposed bands; the contradictory release architecture replaced by one adequacy-gated release regime with no date-based release; reversal compensation single-sourced on MCC-700 clause 16.7 (tonne-for-tonne, regardless of cause; cash never discharges); pooled contributions made non-refundable by default; portfolio adequacy, stress testing, concentration limits, insolvency and wind-down protection added; the Durability Classification created as Schedule 1; technology clauses removed in favour of references to the Information Security Standard and MCC-800	FD-2026-09-03 items D1–D8

NOTE (non-normative). This document is issued for public consultation. Nothing in it asserts that any approval, accreditation, eligibility, registration, issuance or operational history exists unless a linked record is identified in the MCC Evidence Register. Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions below and marked in the text.

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 6.8 — Validity of a non-permanence risk assessment. Proposed: an assessment remains valid for the shorter of five years and the period to the next verification, and is reassessed on every trigger in MCC-NPRT §8. Basis: the five-year ceiling is carried from MCC-BPM v1.0 clause 0061 as the consultation proposal; open decisions go to public consultation (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether five years is the right ceiling.

2. Clause 7.4 — Buffer contribution band. Proposed: a minimum of 10% and a maximum of 40% of the post-deduction verified quantity for every stored-carbon issuance, not narrowed for any family. Basis: the band is carried from MCC-BPM v1.0 clause 0013 as the consultation proposal (FDP-2026-001 Part 3); no evidence base for narrowing it by family exists in the programme record (FD-2026-10-01 Schedule 1, Q15). Decided by: the Governing Board on adoption of the suite. Comments are invited on the calibration of the band, which no MCC operational data yet evidences, and on whether any family — for example F02 protected-stock projects — should carry a different floor.

3. Clause 7.9 — Justification of a contribution rate below 15%. Proposed: a rate below 15% is supported by an explicit justification in the assessment record addressing why every risk category scores low over the full enforceable commitment period. Basis: carried from MCC-BPM v1.0 clause 0026 as the consultation proposal (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether 15% is the right threshold for this requirement.

4. Clause 9.4 — Reversal investigation timeline. Proposed: an investigation should conclude within forty-five calendar days of opening; where it cannot, the reasons and a revised timetable are recorded and published. Basis: carried from MCC-BPM v1.0 clauses 0098–0099 as the consultation proposal (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether forty-five days is realistic for marine reversal events.

5. Clause 9.13 — Accountable owner of reversal determinations (MCC-700 Annex A row 27). Proposed: the Registry Oversight Committee, as drafted in row 27; the Delegated Authority Matrix is put to consultation as drafted, as one proposal. No such Committee is constituted; under the transitional appointments schedule also proposed (MCC-700 v4.0-draft cl. 4.5.5), its functions would be exercised by the Governing Board until it is, whereas clause 16.3 of this Policy, read with cl. 23.2 of that draft as it stands, places the functions of a body not yet constituted with the founder. Basis: FD-2026-10-01 Schedule 1 (C2, C5). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether reversal determinations, including any proponent replenishment liability, should rest with that Committee.

6. Clause 10.6 — Funding of replenishment steps (c) and (d). Proposed: no proposal is made — any programme guarantee depends on the Programme's operating entity, which has not yet been incorporated, and the wind-down reserve on which step (d) draws has no figure; an actuarially derived proposal is to be commissioned. Basis: FD-2026-10-01 item 3 and Schedule 1 (C6). Decided by: the Governing Board on adoption of the suite. Comments are invited on how steps (c) and (d) should be funded, and on whether a programme guarantee should back them.

7. Clause 11.6 — Destination of released buffer units. Proposed: two options, without a preference between them: (a) released units are cancelled for net atmospheric benefit; (b) released units are returned pro rata to contributing projects whose enforceable commitment periods have concluded without any uncompensated reversal, becoming tradeable with full provenance metadata (the model of MCC-BPM v1.0 clauses 0125 and 0142–0143, in gated form). Until one is chosen on approval of this Policy, no release is made. Basis: open decision put to public consultation (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on which option better protects the integrity of outstanding units.

8. Clause 12.4 — Minimum adequacy ratio. Proposed: no proposal is made — no figure exists in the predecessor or the programme record, and an actuarially derived proposal is to be commissioned. Basis: FD-2026-10-01 Schedule 1 (C6). Decided by: the Governing Board on adoption of the suite. Comments are invited on the method by which the minimum ratio should be derived.

9. Clause 12.6 — Reversal reserve margin. Proposed: a margin of buffer units above the modelled expected exposure equal to 10% of total outstanding buffer units. Basis: carried from MCC-BPM v1.0 clause 0119 as the consultation proposal, pending the first independent adequacy assessment (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether 10% is an adequate margin before any adequacy assessment exists.

10. Clause 12.7 — Initial concentration limits. Proposed: no proposal is made — no figure exists in the programme record, and an actuarially derived proposal is to be commissioned. Basis: FD-2026-10-01 Schedule 1 (C6). Decided by: the Governing Board on adoption of the suite; the initial limits are then set by the body MCC-700 Annex A row 37 designates (the Independent Governing Board, as drafted), on the first adequacy assessment's recommendation (clause 12.7). Comments are invited on the dimensions and form the limits should take.

11. Clause 13.1 — Legal mechanism segregating the buffer pool. Proposed: a separate foundation, or a ring-fenced account with a declaration of trust. The choice depends on the incorporation of the Programme's operating entity, which has not yet taken place, and counsel is to be instructed once the entity exists. Basis: FD-2026-10-01 item 3 and Schedule 1 (Q16). Decided by: the Governing Board on adoption of the suite. Comments are invited on which mechanism better secures the pool against the insolvency of the entity and of the registry operator.

12. Clause 13.3 — Wind-down reserve. Proposed: no proposal is made — no figure for the reserve exists in the programme record, its funding source is not decided, and an actuarially derived proposal is to be commissioned. Basis: FD-2026-10-01 Schedule 1 (C6). Decided by: the Governing Board on adoption of the suite. Comments are invited on how the reserve should be sized and funded.

Table of contents

1. Purpose, scope and application
2. Normative references, definitions and interpretation
3. Buffer pool scope and excluded risks
4. Instruments and families in scope
5. Durability classes and the enforceable commitment period
6. Non-permanence risk assessment
7. Buffer contributions
8. Buffer pool account and operations
9. Reversal response and buffer draw
10. Replenishment
11. Buffer release
12. Portfolio adequacy, stress testing and the reversal reserve
13. Insolvency and wind-down protection
14. Reporting and transparency
15. Platform, records and information security
16. Amendments and transitional provisions
17. Entry into force Schedule 1 — Durability Classification (normative; published as a separate consultation file)

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1. Purpose, scope and application

1.1 This Buffer Pool Management Policy (MCC-BPM) SHALL govern the establishment, funding, operation, drawdown, replenishment, release, adequacy assessment and wind-down protection of the pooled buffer of the Marine Conservation Credits (MCC) Programme.

1.2 The buffer pool exists for exactly one purpose: to compensate verified reversals of stored carbon credited as MCC-CC, so that every issued and outstanding MCC-CC continues to represent one tonne of CO2e reduced or removed (MCC-700 clause 16.3; MCC-100 clause 11.8).

1.3 This Policy SHALL apply to every project crediting stored carbon under any MCC methodology, to the Programme Secretariat, to the Registry Oversight Committee, to the registry operator, and to every assessor and VVB performing work under it.

1.4 This Policy is a Tier 3 instrument under the Document Hierarchy & Precedence Register; precedence is governed by MCC-001 Section 2, and nothing in this Policy weakens MCC-100 or MCC-700. Where this Policy sets a stricter requirement than a higher-tier ceiling permits it to tighten, the stricter rule applies and the tightening is identified in a NOTE.

1.5 Where this Policy refers to another MCC document, form, tool or register, the reference SHALL be read against the Document Hierarchy & Precedence Register; a requirement of this Policy that depends on a referenced instrument is ineffective until MCC-001 clause 2.5 is satisfied for that instrument.

NOTE. The following instruments referenced in this Policy are, at the date of this draft, not yet published under document control: the Record Retention Schedule; the Information Security Standard; the MCC-600 Claims Code; the rewritten Environmental & Social Safeguards Policy (MCC-ESS v2.0-draft); the reissued MCC-400 and MCC-800 (v2.0-drafts); the versioned serial specification; the Non-Permanence Risk Tool (MCC-NPRT), which is published as a companion consultation draft with this Policy and is not yet adopted; and Schedule 1 (Durability Classification), which is published with this Policy as a normative part of it and takes effect with it. The Definitions Register v1.0 is in force as an annex to MCC-100 (FD-2026-08-24 item D12, recorded in the decision register as attested by the founder, with no executed copy filed); its Amendment 1 is put to consultation with this suite. Each dependent requirement is deferred under clause 1.5, never silently effective.

1.6 No buffer contribution, cancellation or release SHALL occur while the issuance and serialisation freeze of MCC-100 clause 19.9 and MCC-001 clause 14.7 is in effect.

2. Normative references, definitions and interpretation

2.1 The terms MCC-CC, MCC-MOU, MCC-CB label, reversal, cancellation, retirement, validation and verification SHALL bear the meanings of the canonical Unit/Product Dictionary (control table 1) and the Definitions Register; where the Definitions Register does not define the term, the Audit Appendix A canonical meanings apply, mirroring MCC-001 clause 3.3.

2.2 In this Policy, "MCC" expands as Marine Conservation Credits; the predecessor's expansion "Methodological Carbon Credits" (clause 0001) was wrong and is not carried (BUF-01).

2.3 Normative verbs follow MCC-001 clause 3.1: SHALL/MUST mandatory; SHOULD recommended with documented deviation; MAY optional.

2.4 The following terms are defined locally under MCC-001 clause 3.4 because they are unique to this Policy:

2.4.1 Buffer pool — the single programme-level pool of MCC-CC units held in the segregated buffer account to compensate verified reversals of stored carbon.

2.4.2 Buffer contribution — the quantity of MCC-CC units deducted from a project's verified issuance quantity and issued into the buffer pool under Section 7.

2.4.3 Buffer draw — a cancellation of buffer pool units to compensate a verified reversal under Section 9.

2.4.4 Buffer release — a transfer of buffer pool units out of the pool other than a buffer draw, permitted only under Section 11.

2.4.5 Enforceable commitment period (ECP) — the period defined by MCC-100 clause 11.2, as operationalised in Schedule 1.

2.4.6 Adequacy ratio — the ratio of the buffer pool balance to the modelled stressed reversal exposure of the outstanding stored-carbon portfolio, computed under Section 12.

2.5 Precedence is governed by MCC-001 Section 2; identified tightenings under clause 1.4 operate within the ceilings the higher-tier documents permit this Policy to tighten.

3. Buffer pool scope and excluded risks

3.1 The buffer pool SHALL cover only the quantified reversal / non-permanence exposure of stored carbon; the single source of this scope rule is MCC-700 clause 16.3, and this Policy implements it without variation (SYS-13; BUF-02).

3.2 No risk listed in the table in clause 3.3 SHALL be covered by, transferred to, netted against or compensated from the buffer pool, in any quantity, by any document, methodology, tool or decision.

3.3 Each excluded risk is handled where the following table states, and nowhere else:

Excluded risk	Where and how it is handled	Citation
Baseline and quantification uncertainty	Uncertainty is estimated, propagated and discounted before issuance; the discount reduces the credited quantity and is never buffered	MCC-100 clauses 9.3–9.4; MCC-200 clause 8.6 and Annex B-4
Missing or invalid monitoring data	Conservative substitution or no crediting; missing data never increase issuance	MCC-100 clause 9.5; MCC-200 clause 8.7
Leakage, and leakage uncertainty	Identified, quantified, monitored and deducted in full before issuance	MCC-100 Section 10, in particular clauses 10.3 and 10.5
Avoided-emission (flow) outcomes	Flow outcomes carry no permanence horizon and are excluded from buffer participation entirely	MCC-100 clause 11.9; MCC-200 clauses 9.6–9.7
Environmental and social safeguards risk	Safeguards screening, clearance, suspension, remedy and grievance mechanisms	MCC-100 Section 14; Environmental & Social Safeguards Policy (MCC-ESS v2.0-draft); MCC-700 Annex A rows 8, 12a, 12b
Compliance, fraud, error and misrepresentation risk	Enforcement measures and defect-finding cancellation of the specifically affected units, with due process	MCC-100 Section 23, in particular clause 23.5; MCC-700 Annex A rows 20–26
Non-permanence of MCC-MOU outcomes	Methodology-specific evidence rules: duration is expressed inside the outcome metric and its monitoring requirements; no buffer participation	MCC-200 clause 9.8; the applicable Tier 4 methodology
Proponent or programme financial default (other than a reversal)	Contractual and enforcement mechanisms; insolvency and wind-down protections of Section 13	MCC-100 Section 23; this Policy Section 13

3.4 A verified reversal SHALL be compensated from the buffer pool under Section 9 whatever its cause — including natural disaster, disease, thermal stress, subsidence, project abandonment, land- or sea-use change, technical failure, regulatory action and force majeure — and no cause-based waiver, deferral or reduction of compensation is permitted (MCC-700 clause 16.7; BUF-06).

3.5 The buffer pool SHALL be distinct and separate from retirement accounts, from any voluntary reserve a participant maintains, and from any regulatory compliance mechanism; buffer units SHALL NOT be used to satisfy any obligation other than reversal compensation under this Policy.

4. Instruments and families in scope

4.1 Buffer contributions SHALL be made only in MCC-CC units, and only from issuances of stored carbon; no MCC-MOU unit, and no MCC-CB label, SHALL contribute to, be held in, or be drawn from the buffer pool.

4.2 The instrument type MCC-HYB does not exist (FD-2026-09-03 item D1); every predecessor rule assigning buffer treatment to MCC-HYB — including the F05 uplift of clauses 0069.2–0069.3 and the F02/F03 rows of the predecessor's Buffer Rate table — is void and is not carried in any form.

4.3 Buffer applicability per family SHALL be as follows, generated from the canonical Family–Methodology–Instrument Matrix (control table 2) and the permanence-class applicability adopted in MCC-200 clause 9.6:

Family	Buffer applicability
F01 Coastal blue-carbon removals/restoration	In scope — stored carbon; durability class required (Schedule 1); buffer participation required
F02 Coastal blue-carbon avoided loss/protection	In scope for the protected stored stock — durability class required; buffer participation required
F03 Sustainable fisheries and fishing-gear interventions	Flow-based by default (no buffer); any stored-carbon component a methodology defines is in scope with durability class and buffer participation
F04 Marine pollution prevention/removal	Not in scope — MCC-MOU outcomes; any separately approved GHG module is flow-based unless it credits storage
F05 Marine habitat and biodiversity conservation	Not in scope — MCC-MOU outcomes

NOTE — GENERATED CONTENT. The table in clause 4.3 is generated from control table 2 (FD-2026-09-03 item D2) and the permanence-class applicability proposed in MCC-200 v3.0-draft clause 9.6, which Schedule 1 §6 adopts and refines with minimum durability classes per family. It is not independently editable; any change is made in the control table and flows into every document generated from it. The predecessor's family table (clause 0014 and the Buffer Rate by Credit Type table) — which buffered "avoided-emission components", assigned F04 a stored-carbon rate for "avoided decomposition", and gave F05 both MCC-MCU/0% and MCC-HYB/+10 percentage points — is extinguished (BUF-01; BUF-02; SYS-02; Phase 0 F05 finding).

4.4 Non-permanence of MCC-MOU outcomes SHALL be addressed exclusively through the methodology-specific evidence rules of MCC-200 clause 9.8 — duration expressed inside the outcome metric and its monitoring requirements — and the detail of those rules is a Tier 4 matter for each methodology, not this Policy.

4.5 An avoided-emission quantity SHALL NOT be described as sequestration, and a stored-carbon quantity SHALL NOT be re-characterised as a flow to escape buffer participation; the characterisation fixed in the approved methodology governs.

5. Durability classes and the enforceable commitment period

5.1 Schedule 1 (Durability Classification) is a normative part of this Policy; it defines the durability classes consumed by MCC-100 clause 11.1 and MCC-200 clause 9.1, and no other document SHALL define a durability class.

5.2 Every project crediting stored carbon SHALL be assigned a durability class under Schedule 1 before validation is completed, and the assignment SHALL be verified by the VVB.

5.3 No permanence or durability claim, label, registry field or communication for any project or unit SHALL exceed the project's evidenced enforceable commitment period (MCC-100 clause 11.3; SYS-09); the predecessor's 100-year F01 permanence horizon and its calibration clauses 0069.2–0069.3 are deleted and not carried in any form.

5.4 The enforceable commitment period SHALL be evidenced element-by-element as Schedule 1 §3 requires; the shortest-evidenced element governs the period.

5.5 The durability class fixes the risk horizon of the non-permanence risk assessment (Section 6) and the minimum duration of post-crediting monitoring (MCC-100 clause 11.4); it does not of itself add or subtract any buffer percentage points.

NOTE. The predecessor added family-calibrated percentage-point uplifts for shorter permanence horizons (clause 0069.3: F02 +5pp, F05 +10pp). That mechanism is not carried: durability now operates through the enforceable commitment period (which caps claims and crediting under MCC-200 Annex B-6) and through the risk horizon of the assessment, not through flat uplifts attached to family labels that no longer exist in that form (SYS-09; FD items D1–D2).

6. Non-permanence risk assessment

6.1 Every project crediting stored carbon SHALL undergo a non-permanence risk assessment under the Non-Permanence Risk Tool (MCC-NPRT) before first issuance, and the assessment SHALL be complete and verified before any issuance (MCC-100 clause 11.10).

6.2 No default buffer rate SHALL exist, and no issuance SHALL proceed on an incomplete, expired or unverified risk assessment; the predecessor's 20% default-on-incomplete-assessment rule (clause 0025) is abolished (BUF-03).

6.3 The assessment SHALL consume exactly the methodology-defined inputs of MCC-200 clause 9.4 — the activity-specific risk factors, the evidence required for each, and the treatment of unassessable factors as maximum-risk — together with the project's durability class and enforceable commitment period under Schedule 1.

6.4 The assessment SHALL be performed by an independent, qualified assessor meeting the competence, conflict-of-interest and disclosure requirements of MCC-NPRT §10, and SHALL NOT be performed by the project proponent, its adviser on the project, or any person with a financial interest in the project outcome.

6.5 Risk SHALL be assessed over the full enforceable commitment period, not only the crediting period.

6.6 The completed assessment, including every category score, the composite risk score, the stress-test result and the derived buffer contribution rate, SHALL be recorded in the project's validation report and published on the registry, with only the redactions permitted by MCC-100 clause 20.7.

6.7 The project proponent SHALL have thirty calendar days from receipt of a draft assessment to submit additional risk-mitigation evidence, which the assessor SHALL evaluate under MCC-NPRT §5.4 before finalising.

6.8 A risk assessment SHALL remain valid for the shorter of five years and the period to the next verification, and SHALL be reassessed on every trigger in MCC-NPRT §8. (Consultation question 1.)

6.9 A project whose assessment yields an ineligibility outcome under MCC-NPRT §6 SHALL NOT be issued MCC-CC units, and the outcome SHALL be recorded in the registry with the decision and appeal rights of MCC-700.

7. Buffer contributions

7.1 Every issuance of MCC-CC units for stored carbon SHALL carry a mandatory buffer contribution, applied as step (d) of the ordered deduction sequence of MCC-100 clause 9.9 — after conservative quantification, leakage deduction and uncertainty discount, never in substitution for any of them.

7.2 The buffer contribution rate SHALL be the rate derived for the project by the Non-Permanence Risk Tool, within the applicable band of clause 7.4; no flat, default, negotiated or unexplained rate SHALL be applied.

7.3 The contribution quantity SHALL equal the contribution rate multiplied by the verified quantity after steps (a)–(c) of MCC-100 clause 9.9, rounded up to the next whole unit; the net quantity issued to the project SHALL be rounded down to the whole unit (MCC-100 clauses 9.8 and 19.4), and the sum of net issuance and buffer contribution SHALL NOT exceed the verified quantity (BUF-04).

7.4 The buffer contribution band for every stored-carbon issuance SHALL be a minimum of 10% and a maximum of 40% of the post-deduction verified quantity.

NOTE. The 10–40% band is carried from predecessor clause 0013 as the consultation proposal — it is the only element of the predecessor's rate architecture that survives the audit, and it is retained so that consultation respondents assess a concrete band. Its calibration is not evidenced by MCC operational data (none exists) and is confirmed or varied on approval. The band is not narrowed per family (for example by a higher floor for F02 protected-stock projects), because no evidence base for narrowing it exists in the programme record (FD-2026-10-01 Schedule 1, Q15). (Consultation question 2.)

7.5 The rate mapping from composite risk score to contribution rate within the band SHALL be that of MCC-NPRT §7, including its stress-test floor; where the stress-test floor would exceed the band maximum, the project SHALL be referred for ineligibility review under MCC-NPRT §6.3, not issued at the band maximum.

7.6 The applicable rate SHALL be fixed per issuance batch at the rate current under the most recent valid assessment at the time of issuance; a reassessment SHALL apply to subsequent batches only and SHALL NOT retroactively alter issued batches.

7.7 An upward rate adjustment following reassessment SHALL apply automatically to every subsequent batch of the project.

7.8 A downward rate adjustment SHALL apply only after an independent reassessment under MCC-NPRT, verification of the reassessment by a VVB, and confirmation by the Registry Oversight Committee, and SHALL apply prospectively only.

7.9 A rate below 15% SHALL be supported by an explicit justification in the assessment record addressing why every risk category scores low over the full enforceable commitment period. (Consultation question 3.)

7.10 Buffer contributions SHALL be issued directly into the buffer account at issuance, as MCC-100 clause 19.6 requires, in the same transaction as the project issuance, carrying the same vintage, methodology and attribute set as the batch from which they derive.

7.11 The predecessor's blunt-proxy minimum rates — 30% for historical reversals (clause 0033), 25% for developers younger than two years (clause 0034) and 25% by country classification (clause 0035) — are not carried as flat minimums; reversal history, operating track record and jurisdictional governance are scored as evidence-based factors with floors inside MCC-NPRT §§4–6 (BUF-05).

7.12 Buffer contribution rates and their derivation SHALL be communicated in writing to the project proponent and recorded in the registry before the affected issuance is executed.

8. Buffer pool account and operations

8.1 The buffer pool SHALL be held as a single programme-level segregated account in the MCC registry, operated on a continuous basis and administered by the registry operator under the oversight of the Registry Oversight Committee (MCC-700 clauses 16.1–16.2).

8.2 Buffer units SHALL carry a distinct registry status (buffer) and SHALL retain their serial identification to the originating project batch under the versioned serial specification, for auditability and traceability.

8.3 Buffer units SHALL be non-tradeable: they SHALL NOT be listed, sold, transferred to any external account, pledged, lent or encumbered.

8.4 Contributions to the buffer pool are mutualised: from the moment of contribution they are pool assets held for the benefit of the integrity of all outstanding MCC-CC units, and no project, proponent or unit holder has any entitlement to their return except through a release lawfully made under Section 11 (BUF-08).

8.5 The pool SHALL maintain a perpetual ledger recording every contribution, draw, cancellation and release, each with project identifier, date, quantity, serial range and the approving decision reference.

8.6 The pool balance SHALL be updated in the registry as transactions occur, and the current balance SHALL be published at least quarterly.

8.7 Buffer units SHALL accrue no interest and SHALL maintain constant one-tonne CO2e equivalence to their vintage.

8.8 The buffer pool SHALL NOT be commingled with MCC operating funds, fee income or any other account, and no fee, levy or charge SHALL be paid out of buffer units.

8.9 A transfer of buffer-pool administration to another operator SHALL require approval under MCC-700 Annex A row 35 and a transition plan preserving ledger continuity; the predecessor's fixed 120-day transition period is replaced by a plan-based requirement.

8.10 Buffer pool operations SHALL be reconciled quarterly against independent records and audited annually by a third party independent of the registry operator; the audit report SHALL be provided to the Registry Oversight Committee and published in summary.

9. Reversal response and buffer draw

9.1 A reversal is defined by MCC-100 clause 11.5: any loss or release that negates previously credited stored-carbon benefit, in any quantity; no de minimis exemption exists and the predecessor's threshold-based treatments are not carried.

9.2 The project proponent SHALL notify the Programme Secretariat of any suspected reversal within ten business days of discovery.

NOTE. Clause 9.2 tightens the thirty-calendar-day ceiling of MCC-100 clause 11.7, carrying the predecessor's stricter ten-business-day rule (clause 0097); the stricter rule prevails and the tightening is disclosed here per clause 1.4.

9.3 On notification or other credible indication of a reversal, the Programme Secretariat SHALL open a reversal investigation within fifteen business days and SHALL withhold any pending issuance for the affected project (MCC-100 clause 11.7).

9.4 The investigation SHOULD conclude within forty-five calendar days of opening; where it cannot, the reasons and a revised timetable SHALL be recorded and published. (Consultation question 4.)

9.5 The reversal quantity SHALL be quantified in tonnes CO2e under the methodology's reversal-quantification method (MCC-200 clause 9.5) and verified by a VVB before compensation is quantified (MCC-100 clause 11.7); where the loss estimate carries uncertainty, the verified quantity SHALL be the conservative (upper-bound) estimate of the loss, replacing the predecessor's 15% margin-of-error allowance (clause 0101).

9.6 Every verified reversal SHALL be compensated as MCC-700 clause 16.7 requires — cancellation or replenishment of an equivalent quantity of units, tonne-for-tonne, regardless of cause, with pursuit of a responsible party a separate action that never defers compensation; that clause is the single source of the compensation rule and is not restated or varied here.

9.7 Compensation SHALL be executed as a buffer draw: the Registry Oversight Committee SHALL cancel buffer pool units equal to the verified reversal quantity under maker-checker control within ten business days of verification, and SHALL publish the cancellation (MCC-700 clause 16.6; Annex A row 11).

9.8 A buffer draw SHALL NOT be waived, deferred, reduced or made conditional on any liability determination, insurance recovery, force-majeure finding or appeal; a successful appeal against the reversal determination SHALL be remedied by restoring units to the pool, not by delaying the draw (BUF-06).

9.9 Cancelled buffer units SHALL be permanently removed, marked non-recoverable, and recorded against the reversal event.

9.10 A partial reversal SHALL trigger a draw proportional to the verified loss.

9.11 Where the buffer pool balance is insufficient to cover a verified reversal in full, the shortfall SHALL be met through the replenishment hierarchy of clause 10.6, and every outstanding affected obligation SHALL be tracked in the registry until discharged; cumulative obligations from multiple reversals accrue without limitation.

9.12 A Reversal Event Report SHALL be issued within sixty calendar days of the investigation's conclusion and published, identifying the project, cause, verified quantity, buffer draw, any proponent replenishment liability and the evidence relied on.

9.13 The reversal determination, including any proponent replenishment liability under clause 10.2, SHALL be taken by the body designated for that decision type in MCC-700 Annex A, and SHALL carry appeal to the Independent Appeals Panel de novo. The designated row is MCC-700 Annex A row 27, added by the bundled conforming instrument of 3 September 2026. The row's accountable owner is proposed to be the Registry Oversight Committee, as drafted there, the Delegated Authority Matrix being put to consultation as drafted, as one proposal (FD-2026-10-01 Schedule 1, C2). (Consultation question 5.)

9.14 Every verified reversal SHALL trigger a mandatory reassessment of the project's risk assessment under MCC-NPRT §8 before any further issuance for that project.

9.15 A reversal SHALL NOT release the proponent from its continuing monitoring, maintenance and safeguard obligations for the remainder of the enforceable commitment period.

10. Replenishment

10.1 The atmosphere is made whole by the buffer draw; replenishment then restores the pool.

10.2 Where the verified cause of a reversal is attributable to the proponent's act, omission or breach of programme requirements, the proponent SHALL replenish the pool with an equivalent quantity of MCC-CC units (or other units accepted as equivalent in integrity under MCC-700 Annex A row 38, cancelled for the purpose) within ninety calendar days of the liability determination.

10.3 A cash payment SHALL NOT itself discharge any reversal or replenishment obligation; cash MAY be applied only to procure units that are then cancelled, and the obligation is discharged only on cancellation (BUF-06).

10.4 Insurance proceeds, guarantees or security MAY fund the procurement of replenishment units but SHALL NOT substitute for cancellation.

10.5 Where no responsible party exists or recovery fails, the draw stands and the pool SHALL be restored through the programme-level mechanisms of clause 10.6; recovery efforts SHALL continue and be reported.

10.6 The replenishment hierarchy, applied in order until the adequacy ratio is restored, SHALL be: (a) proponent replenishment under clause 10.2; (b) the reversal reserve margin of clause 12.6; (c) a programme-wide prospective increase in buffer contribution rates decided under MCC-700 Annex A row 36; (d) procurement and cancellation of equivalent units funded by the wind-down reserve or insurance under Section 13. The funding sources and any programme guarantee backing steps (c) and (d) are not decided, and no proposal is made: the Programme's operating entity has not yet been incorporated (FD-2026-10-01 item 3), and the wind-down reserve has no figure; an actuarially derived proposal is to be commissioned (FD-2026-10-01 Schedule 1, C6). (Consultation question 6.)

10.7 Replenishment obligations SHALL survive project completion, crediting-period end, buffer release, participant suspension or exclusion, and the transfer or sale of the project (BUF-09).

11. Buffer release

11.1 There is one release regime: this Section. The predecessor's contradictory release rules — the 10-year guarantee (clauses 0122–0124), family schedules (clauses 0122.1–0122.2), phased 25/25/50 milestones (clauses 0124, 0137), early- and accelerated-release prohibitions (clauses 0138–0139) and full-return rule (clause 0142) — are all replaced (BUF-07).

11.2 Buffer pool contributions are non-refundable by default; no project, proponent or holder acquires any right to a release by contribution, by the passage of time, by the completion of a crediting period, or by the reaching of any date or milestone.

11.3 No buffer release SHALL be made solely because a project or vintage reaches a date (MCC-700 clause 16.5; MCC-100 clause 11.11).

11.4 A buffer release SHALL require every one of the following, evidenced:

11.4.1 a recommendation of the Registry Oversight Committee (MCC-700 clause 16.5(a));

11.4.2 an independent actuarial or adequacy assessment of the portfolio, current within twelve months, including the stress tests of Section 12 (MCC-700 clause 16.5(b));

11.4.3 approval by the Governing Board under MCC-700 Annex A row 10 (MCC-700 clause 16.5(c));

11.4.4 demonstration that the post-release adequacy ratio remains at or above the minimum of clause 12.4 under every stress scenario;

11.4.5 sustained monitoring performance: every contributing project counted in the adequacy basis is current on its monitoring and reporting obligations, and no suspected reversal is unresolved anywhere in the stored-carbon portfolio; and

11.4.6 no uncompensated verified reversal and no outstanding replenishment obligation.

11.5 The quantity approved for release SHALL NOT exceed the surplus demonstrated by the adequacy assessment after applying every stress scenario, and the approval SHALL state the computed surplus and the quantity released against it.

11.6 Destination of released units. Two options are put to consultation: (a) released units are cancelled for net atmospheric benefit; (b) released units are returned pro rata to contributing projects whose enforceable commitment periods have concluded without any uncompensated reversal, becoming tradeable with full provenance metadata (the predecessor's model, clauses 0125 and 0142–0143, retained in gated form). Until this decision is taken on approval of this Policy, no release SHALL be made. (Consultation question 7.)

11.7 Every release decision SHALL be published with the project-level and portfolio-level basis, the adequacy assessment relied on, and the destination of the released units.

11.8 A release SHALL NOT extinguish any replenishment liability, and a reversal verified after a release SHALL be compensated in full under Section 9; released units are not recalled, but the assumptions of the release decision SHALL be re-examined in the next adequacy assessment and any deficit restored under clause 10.6 (BUF-09).

11.9 The end of a project's enforceable commitment period SHALL end its contribution and monitoring obligations prospectively but SHALL NOT of itself trigger any release.

12. Portfolio adequacy, stress testing and the reversal reserve

12.1 Portfolio reversal-risk adequacy SHALL be assessed at least annually by an independent assessor and published (MCC-100 clause 11.12).

12.2 The adequacy assessment SHALL model, at minimum: the expected reversal exposure of every outstanding stored-carbon vintage over the applicable enforceable commitment periods; concentration by geography, family, methodology and proponent; and correlated-event stress scenarios, including at minimum a single severe storm season affecting multiple projects in one region, a basin-scale marine heatwave, a disease outbreak affecting one habitat type, and a systemic tenure or governance failure in one jurisdiction.

12.3 The assessment SHALL compute the adequacy ratio: the buffer pool balance divided by the modelled stressed reversal exposure.

12.4 The minimum adequacy ratio is not decided: no figure exists in the predecessor or the programme record, none is proposed, and an actuarially derived proposal is to be commissioned (FD-2026-10-01 Schedule 1, C6). (Consultation question 8.)

12.5 Where the adequacy ratio falls below the clause 12.4 minimum, the Registry Oversight Committee SHALL report to the Governing Board within twenty business days with a restoration plan under the clause 10.6 hierarchy, and no release SHALL be considered while the ratio is below the minimum.

12.6 The pool SHALL maintain a reversal reserve margin — buffer units above the modelled expected exposure — of 10% of total outstanding buffer units. (Consultation question 9.)

12.7 Concentration limits per geography, family and proponent SHALL be set under MCC-700 Annex A row 37, on the first adequacy assessment's recommendation, and reviewed annually. No initial limit is decided or proposed: no figure exists in the programme record, and an actuarially derived proposal is to be commissioned (FD-2026-10-01 Schedule 1, C6). (Consultation question 10.)

12.8 Historical reversal-rate data by family and cause SHALL be maintained and published annually to inform rate calibration and adequacy modelling; no operational history is claimed at the date of this draft, and this record starts empty.

12.9 The adequacy assessor SHOULD benchmark pool design and rates against published buffer and non-permanence approaches of other crediting programmes as design references; no such comparison is an alignment or equivalence claim (MCC-001 clause 8.8).

13. Insolvency and wind-down protection

13.1 Buffer pool units SHALL be held under a legal arrangement that segregates them from the insolvency estate of the legal entity and of the registry operator, so that they remain available exclusively for reversal compensation. The legal mechanism depends on incorporation; the proposal is a separate foundation, or a ring-fenced account with a declaration of trust, with counsel to be instructed once the entity exists (FD-2026-10-01 Schedule 1, Q16). (Consultation question 11.) No segregation instrument has been executed and no insolvency-remoteness opinion has been obtained: the entity that would grant the arrangement has not yet been incorporated (FD-2026-10-01 item 3), and the buffer pool holds no units (Evidence Register ER-2026-001 §A1; registry measurement of 1 October 2026). This clause binds before the first buffer contribution.

13.2 The Programme SHALL maintain a wind-down plan under which, on any decision to terminate the Programme, the buffer pool and its ledger transfer to a successor administrator bound by rules no weaker than this Policy or, absent a successor, all buffer units are cancelled for net atmospheric benefit; in no circumstance SHALL buffer units be distributed to the Programme, its members, its creditors or any commercial party.

13.3 A wind-down reserve SHALL be maintained to fund continued monitoring, adequacy assessment and pool administration for outstanding enforceable commitment periods after any cessation of new issuance. Its funding source and sizing basis are not decided, and no figure is proposed: an actuarially derived proposal is to be commissioned (FD-2026-10-01 Schedule 1, C6). (Consultation question 12.)

13.4 No durability class above D-30 SHALL be assigned to any project until the clause 13.1 arrangement and clause 13.3 reserve are evidenced, per Schedule 1 §4.5.

13.5 The buffer pool SHALL operate for as long as any credited stored-carbon exposure remains outstanding; it SHALL NOT be dissolved while any enforceable commitment period is running, and dissolution thereafter SHALL follow the wind-down plan.

14. Reporting and transparency

14.1 An annual Buffer Pool Management Report SHALL be produced and published within 120 calendar days of each financial year end, covering: contributions by family and risk level; pool balance and adequacy ratio; draws and their causes; replenishments; releases; reversal-trend analysis; and any policy recommendations.

14.2 The registry SHALL display publicly: the current pool balance; contributions, draws and releases year-to-date; each project's contribution history, current rate, durability class, risk-assessment summary and reversal history; and every Reversal Event Report and release decision.

14.3 Every non-permanence risk assessment SHALL be published within thirty calendar days of finalisation, with only the redactions permitted by MCC-100 clause 20.7.

14.4 Every decision of any body under this Policy SHALL be recorded and published within thirty calendar days, with the decision reference linked in the Evidence Register.

15. Platform, records and information security

15.1 The registry platform SHALL record, for the buffer pool: the pool account and balance; each contribution (project, date, quantity, serial range, rate, assessment reference); each draw and cancellation (reversal reference, cause code, quantity, liability status); each release (decision reference, quantity, destination); and each risk assessment (assessor, category scores, composite score, rate, validity) — implemented under MCC-800 as reissued (MCC-800 v2.0-draft).

15.2 Buffer transactions SHALL be logged immutably with timestamp and user identity, under the access-control, security and audit-trail requirements of MCC-800 and the Information Security Standard; this Policy fixes no technology stack, encryption protocol, database design, performance benchmark or log-retention period, and the predecessor's clauses 0146–0170 hard-coding them are not carried (BUF-11; SYS-11).

15.3 Records under this Policy SHALL be retained per the Record Retention Schedule; pending its entry into force, no record created under this Policy SHALL be destroyed, mirroring MCC-700 clause 21.2.

16. Amendments and transitional provisions

16.1 Amendments to this Policy follow the decision type of MCC-700 Annex A row 2, with the Tier 3 minimum consultation period of MCC-001 clause 12.3.

16.2 No rate, schedule, release rule or family mapping stated in the predecessor SHALL be applied to any assessment, issuance or decision (MCC-700 clause 16.4); there is no grandfathering, because no issuance, buffer contribution or release has occurred in the programme record. The registry holds no buffer pool entry; the archived demonstration cohort held 4 buffer pool entries and 6,739 units in BUFFER status, all demonstration entries on MCC-DEMO- serials (Evidence Register ER-2026-001 §A1, §A3; registry measurement of 1 October 2026).

16.3 During the transitional period, powers of bodies named in this Policy are exercised as MCC-700 Section 23 provides, logged and tabled for ratification.

16.4 The predecessor's 24-month transition window for rate reform (clause 0029) is not carried; rate rules take effect for all projects on entry into force, there being no issued portfolio to transition.

17. Entry into force

17.1 This Policy (MCC-BPM version 2.0), together with Schedule 1, SHALL enter into force upon approval under the decision type in MCC-700 Annex A row 2 — during the transitional period, upon a Founder Decision recorded and tabled for ratification under MCC-700 Section 23 — on a stated date, following the public consultation on this draft and completion of the acceptance tests in Section 9 of the independent audit dated 3 September 2026.

17.2 The Non-Permanence Risk Tool (MCC-NPRT) is adopted separately as a Tier 4 instrument; no issuance of stored-carbon MCC-CC units SHALL occur before both this Policy and MCC-NPRT are in force (MCC-001 clause 2.5).

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End of MCC-BPM version 2.0-draft. Status: DRAFT — FOR CONSULTATION. Not in force. Schedule 1 (Durability Classification) and the companion Non-Permanence Risk Tool (MCC-NPRT) are published with this draft. Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions above and marked in the text.