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Counterparty policies

Claims Policy

Version 1.1Adopted 2026-08-24 · FD-2026-08-24English (Norwegian adoption banner)MCC_Claims_Policy_v1.1.md

Adopted by founder decision FD-2026-08-24. The Board’s first meeting (GB-2026-001, 26 August 2026) took up ratification of FD-2026-08-24 as item 2 and recorded it as ratified as to substance; the resolution itself remains attested, not signed. Published verbatim from the maintained corpus — changes occur only by amendment with a version bump.

Correction notice

Correction notice, 4 September 2026 (revised the same day). The Programme publishes contact details at two domains that do not exist: mcc-credits.org and mcc-registry.org. Both return NXDOMAIN, neither has a mail exchanger, and neither has ever been reachable. Affected here: claims@mcc-credits.org (complaints), claims-appeal@mcc-credits.org (appeals to the Board), policy@mcc-credits.org (feedback), and the URL mcc-credits.org/claims-audit — which is also the Claims Audit Tool this policy requires and which has never been built. The instrument text is unchanged, because amending an adopted instrument is not an administrative act. Until the Board disposes of the point, the working channel for every purpose in this instrument is contact@marineconservationcredits.com or the contact page. The claims prohibition in section 4 is unaffected and remains in force: it is enforced in the registry by a database trigger and depends on no address. This notice was first served naming only mcc-credits.org; mcc-registry.org was found an hour later by searching the whole corpus rather than one folder, which is the same incomplete-search failure the Programme has now recorded seven times. The earlier notice was not wrong in what it said, and it was not complete. Further correction, same date. Two statements in this Policy are not ones the Programme is entitled to make. Section 3.3 sets out VCMI Silver, Gold and Platinum tier claims as permitted, under criteria the Programme wrote itself: VCMI confers no tier on a crediting programme and none has been conferred here, so no buyer may make a VCMI tier claim on the strength of this Policy. Section 2 asserts compliance with the EU Green Claims Directive, a proposal the European Commission withdrew; the Policy's own change log flagged this on 24 August 2026 and it was not corrected. Both are recorded as PAR-2026-001 findings F8 and F9 and go to the Governing Board on 23 September 2026. Separately, the retirement claim control in the registry was rewritten on 4 September: it previously missed eight ways of writing a prohibited claim, including in Norwegian, and rejected this Policy's own model certificate wording at section 6.2. Further correction, 6 September 2026. A full-corpus audit (PAR-2026-002) found two more statements in this Policy that the Programme is not entitled to make, both going to what a buyer thinks they are buying. First, article 2.1 defines the Marine Conservation Unit as "1 credit represents 1 tCO₂e carbon + quantified SDG benefits". That is a tonne-denominated claim. It contradicts the contribution-first principle in article 1.3(1), it contradicts the Programme's public description of the unit, and no methodology in force quantifies a removal to a tonne with the uncertainty deduction ICVCM criterion 8 requires. The tilde makes it worse rather than better: no tolerance is stated, so a buyer cannot know what a unit contains. Until the Board disposes of the point, the MCC-MCU is not to be described, sold, invoiced or retired as a tonne of CO₂e, and no tonne-denominated figure may appear on a retirement certificate. Second, article 4.2 prohibits the carbon-neutrality claim only conditionally — its heading is "Carbon Neutrality Without Evidence" and its prohibition is qualified "(without documenting ≥50% own reduction + MCC credits for residual 50%)". Read plainly, that permits a buyer to say "carbon neutral" on a 50/50 split, which article 4.1 prohibits unconditionally in almost the same words, and which the Programme has said publicly it does not permit at all. The unconditional prohibition governs: no buyer may make a carbon-neutrality or net-zero claim on the strength of MCC credits, on any evidence. The registry's retirement claim control enforces the unconditional rule and will reject the article 4.2 formulation. Both findings go to the Governing Board on 23 September 2026 with the rest of PAR-2026-002. Further correction, 10 September 2026. Three further things on the face of this Policy are wrong. It still describes "MCC-HYB (Hybrid)" as a credit type carrying "0.8 tCO₂e carbon + 0.2 fisheries impact weighting"; founder decision FD-2026-09-03 item D1 abolished MCC-HYB with no successor unit. It lists "9/9 Safeguards Principles Satisfied," naming nine; the Environmental and Social Safeguards Policy v1.0 cl. 0011 fixes eight core principles, not nine. And it cross-references "MCC AI & Human Oversight Policy (Art. 4: AI flags non-compliant language)"; Article 4 of that Policy is "AI Prohibitions (Hard Boundaries)" and has nothing to do with flagging language — the function described sits at Article 3.6, "Compliance Checking (Claims, Statements, Public Messaging)." The text is unchanged, because amending an adopted instrument is not an administrative act. Until the Board disposes of these points: MCC-HYB no longer exists as a credit type; every safeguards figure is eight, not nine; and the AI cross-reference for flagging non-compliant language is Art. 3.6, not Art. 4. Recorded with the served-page factual sweep (10 September 2026). Further correction, 14 September 2026. Two further things on the face of this Policy are wrong. Art. 6.1's certificate template forces a tonnes-CO2e quantity onto every retirement certificate (6.1.A) with no branch for MCC-MCU, whose non-carbon status and bar on tCO2e conversion are set by the Definitions Register and MCC-M008, and gives the Corresponding Adjustment field (6.1.C) only a binary [YES/NO], which cannot record the NOT_APPLICABLE value the programme uses elsewhere for a non-climate-claim unit. Separately, the header, art. 11.2 and the footer state three mutually inconsistent review dates for the same document (23 September 2026; annually in March; 23 March 2027), and §2.2 lists a "Regulatory Compliance Claim" as NOT PERMITTED while §3.4, under "Permitted Claims," describes a substantiable National NDC Contribution Claim of the same kind. The text is unchanged, because amending an adopted instrument is not an administrative act. Until the Board disposes of these points: no MCU retirement can lawfully complete this certificate template, and the review cycle and the NDC-claim permission remain unsettled. Recorded with the A5 served-instrument cross-reference (14 September 2026) for the Governing Board of 23 September 2026.

MCC CLAIMS AND USE OF CREDITS POLICY

Version 1.1 | 24 August 2026

v1.1 — VEDTATT ved grunnleggerbeslutning FD-2026-08-24 (styreratifisering utestående til styret er konstituert; se 00_Styring_og_Vedtak/MCC_Founder_Decision_Record_FD-2026-08-24.md). Korrigert etter regelverksrevisjonen 24.08.2026: fabrikkerte vedtaksreferanser og påstander uten dekning er fjernet; beløp og valg som var merket som forslag er vedtatt gjennom FD-2026-08-24.

Document Owner: MCC Board Last Updated: 24 August 2026 Next Review: September 23, 2026 Status: ADOPTED v1.1 — FD-2026-08-24 (board ratification pending)

ARTICLE 1: PURPOSE AND SCOPE

1.1 Purpose

This Claims Policy establishes standards for environmental and climate claims made by buyers who retire Marine Conservation Credits (MCC). The policy ensures that claims are accurate, substantiated, compliant with international standards (VCMI Claims Code, EU Green Claims Directive, ISO 14068, SBTi BVCM), and aligned with MCC's contribution-first framework.

1.2 Applicability

This policy applies to:

  • All buyers retiring MCC credits
  • All organizations using retired MCC credits to substantiate climate or environmental claims
  • Marketing and public communications referencing MCC credits
  • Certificate language and retirement notifications

1.3 Guiding Principles

MCC adopts the following principles:

  1. Contribution-First Framing: Credits represent contributions to marine conservation, not offsets of buyer's own emissions
  2. Substantiation Required: All claims must be supported by documented evidence
  3. Regulatory Alignment: Claims comply with evolving regulatory frameworks (VCMI, EU GCD, ISO 14068, SBTi BVCM)
  4. Transparency: Buyers disclose claim basis and CA status to stakeholders
  5. Integrity Over Marketing: Conservative claim standards prioritized over aggressive marketing

ARTICLE 2: DEFINITIONS

2.1 Credit Types

MCC-CC (Carbon Credit): Standalone blue carbon removal credit; 1 credit = 1 tCO₂e sequestered in marine ecosystem over permanence period.

MCC-HYB (Hybrid): Carbon removal + weighted fisheries benefit co-benefit; 1 credit represents ~0.8 tCO₂e carbon + 0.2 fisheries impact weighting.

MCC-MCU (Marine Conservation Unit): Integrated carbon removal + biodiversity + coastal resilience co-benefits; 1 credit represents ~1 tCO₂e carbon + quantified SDG benefits.

2.2 Claim Types

Climate Contribution Claim: Buyer contributes to global climate action by retiring MCC credits to support marine conservation (not to reduce buyer's own emissions).

Conservation Contribution Claim: Buyer contributes to marine ecosystem restoration, fisheries enhancement, biodiversity protection, or coastal resilience beyond buyer's climate obligations.

VCMI-Aligned Claim: Buyer structures claim per VCMI Claims Code (Silver, Gold, or Platinum tier); demonstrates credible emission reductions AND responsible credit use.

Regulatory Compliance Claim (NOT PERMITTED): the use of MCC credits to meet mandatory climate obligations. Defined here only so that Section 3.4 can prohibit it unambiguously; MCC credits are not eligible for the EU ETS.

2.3 Retirement

Retirement: Irrevocable withdrawal of credit from circulation, marking buyer's environmental contribution. Status locked as RETIRED; credit cannot be transferred.

Retirement Certificate: Official MCC document issued upon retirement, listing credit serial numbers, quantity, vintage, project metadata, permanence information, and CA status.

2.4 Contribution

Contribution: MCC credits represent contributions to marine carbon removal and coastal ecosystem benefits. Contributions support buyer's voluntary climate ambition and/or regulatory compliance, but do not directly reduce buyer's own emissions (unless buyer has achieved 50%+ own emissions reduction through operational changes).

2.5 Double-Counting

Double-Counting (Claiming): Same emission reduction claimed in two different GHG inventories (e.g., host country NDC + buyer's national inventory). Prevented by Letter of Authorization (LoA) and Corresponding Adjustment (CA) mechanism.

ARTICLE 3: PERMITTED CLAIMS

3.1 Climate Contribution Claim (Primary)

Definition: Buyer publicly states that retiring MCC credits supports marine conservation and global climate action.

Example Language:

"Organization retires 10,000 MCC credits to contribute to marine conservation and global climate action. This contribution supports F01 blue carbon (seagrass) restoration in Indonesia, with 100-year permanence horizon, and enhances fisheries resilience."

Substantiation Requirements:

  • Buyer retirement authorization (signed)
  • MCC retirement certificate (showing serial numbers, project details, CA status)
  • Documented communication explaining project benefits (project name, location, permanence, co-benefits)

Frequency: No restrictions. Buyer may claim annual retirement amounts.

Disclosure Requirements:

  • Permanence horizon disclosed per family (F01: 100 years; F02/F05: 30 years; F03/F04: avoided-emission flow measure, no permanence horizon)
  • Co-benefits (e.g., "fisheries enhancement, coastal protection")
  • CA status (e.g., "Indonesia NDC → Organization international contribution")

3.2 Conservation Contribution Claim

Definition: Buyer emphasizes marine ecosystem and community benefits beyond carbon.

Example Language:

"Organization supports coastal resilience through 10,000 MCC credits, protecting 5,000 community members from storm surge, restoring fish nursery habitat, and creating 50 jobs in marine restoration."

Substantiation Requirements:

  • Retirement certificate
  • Project fact sheet (ecosystem impacts quantified)
  • Community benefit documentation (employment, livelihood support, fisheries data)
  • Permanence and permanence management summary

Claim Restrictions:

  • Cannot claim sole conservation responsibility (credit is contributor, not primary conservation mechanism)
  • Co-benefits quantified per certificate (no inflation)
  • Must acknowledge permanence risks disclosed on certificate

Disclosure Requirements:

  • Project methodology (F01-F05 family)
  • Geographic location and scale (hectares, number of beneficiaries)
  • Permanence mechanisms (legal protection, monitoring)
  • Buffer pool size (permanence risk allocation)

3.3 VCMI-Aligned Claim (Silver, Gold, or Platinum)

Definition: Buyer structures claim per VCMI Claims Code tier, demonstrating credible own-emissions reduction + responsible credit use.

VCMI Silver Tier (Minimum Standard):

Criteria:

  • Buyer has publicly announced climate target (net-zero by 2050 or interim target)
  • Buyer has credible transition plan (science-based targets, capital investment, operational roadmap)
  • Credits used for residual emissions only (after 20-50% own reduction)

Claim Example:

"Organization has reduced Scope 1+2+3 emissions 30% below 2020 baseline. To address remaining 70%, Organization is transitioning with renewable energy investment (target 50% reduction by 2030) and using 5,000 MCC credits annually to support marine conservation toward net-zero 2050."

Substantiation:

  • Emission baseline + reduction progress report (third-party verified)
  • Climate target announcement
  • Transition roadmap (CAPEX, timeline, interim targets)
  • MCC retirement documentation (annual quantity, project details)

VCMI Gold Tier (Preferred):

Criteria:

  • All Silver criteria PLUS
  • Buyer has achieved measurable progress toward interim target (e.g., 25% reduction by 2025 on track)
  • Credits limited to <10% of claimed reduction (heavy operational emphasis, credit supplement only)

Claim Example:

"Organization has achieved 35% emissions reduction by 2025 (vs. interim target 25%), ahead of schedule. Organization uses 1,000 MCC credits annually (~2% of target reductions) to support marine conservation beyond core climate strategy, with focus on fisheries co-benefits in developing coastal nations."

Substantiation:

  • Verified emissions report (2020-2025, showing progress trajectory)
  • CAPEX documentation (renewable energy, efficiency investments)
  • MCC retirement (limited quantity, benefit quantification)

VCMI Platinum Tier (Premium):

Criteria:

  • All Gold criteria PLUS
  • Buyer has exceeded interim target (e.g., 40% vs. 25% planned by 2025)
  • Credits retired at scale (1,000s+ annually) with documented impact
  • Annual climate report published (transparent progress, independent audit)

Claim Example:

"Organization has exceeded 2025 interim targets (40% reduction vs. 30% planned), driven by renewable energy scale-up and supply chain transition. Organization retires 50,000 MCC credits annually to support marine conservation and coastal community resilience, representing a 5+ year commitment to blue carbon restoration."

Substantiation:

  • Independent emissions audit (verified progress)
  • Multi-year retirement commitment (contractual document)
  • Annual impact report (credits, projects, community benefits)
  • Verified supply chain emission progress

3.4 Regulatory Compliance Claim (EU ETS, National NDC)

Definition: Buyer uses MCC credits to meet mandatory climate obligations.

EU ETS Compliance Claim:

"NOT PERMITTED. MCC credits are ineligible for EU Emissions Trading System (ETS) compliance. MCC is voluntary programme, not regulated allowances supplier. Buyer cannot claim ETS compliance using MCC."

National NDC Contribution Claim:

"Organization supporting host country NDC achievement through MCC credits. Example: Indonesian company retires 1,000 MCC credits from Indonesian mangrove project, contributing to Indonesia's NDC reduction target."

Substantiation:

  • National climate policy documentation (NDC targets, eligibility for credits)
  • Project documentation (host country authorization, LoA)
  • Retirement certificate showing CA status

ARTICLE 4: PROHIBITED CLAIMS

The following claims are expressly prohibited and subject to enforcement action (Article 8):

4.1 Offset-Only Claims

Prohibited:

"Organization offset X% of its emissions using MCC credits" (implies company continuing to emit unabated; credits as 'license to pollute')

"Organization is carbon neutral because MCC credits neutralize our emissions" (implies no own reduction required)

"MCC credits allow us to remain carbon-intensive and offset the difference" (explicit anti-reduction framing)

Rationale: Offset language implies credits are primary climate strategy, not residual contribution. VCMI, EU GCD, SBTi BVCM all prohibit offset-only claims.

4.2 Carbon Neutrality Without Evidence

Prohibited:

"Organization is carbon neutral" (without documenting ≥50% own reduction + MCC credits for residual 50%)

"We are net-zero through MCC credits" (without science-based reduction plan and measured progress)

Rationale: ISO 14068 requires demonstrated reductions first; credits only address residual. MCC certificates clarify residual-only use.

4.3 Misleading Co-Benefit Claims

Prohibited:

"MCC credits generate 100,000 tonnes of new fish catch annually" (inflating fisheries benefits beyond certificate quantification)

"MCC credits protect endangered species from extinction" (overstating conservation causality)

"Our purchase created 10,000 jobs" (claiming full employment credit, not project attribution)

Rationale: Co-benefits quantified on certificate. Buyer cannot claim larger benefits than documented.

4.4 Comparative Claims

Prohibited:

"MCC credits are 50% more effective than terrestrial offsets" (making unsupported comparative claims)

"MCC is the only real carbon solution" (disparaging competitor programmes)

Rationale: MCC does not make comparative claims. Buyers free to emphasize blue carbon benefits; cannot disparage alternatives.

4.5 Misuse of Permanence

Prohibited:

"MCC credits are permanent; sequestration lasts forever" (ignoring buffer pool risks and permanence mechanisms)

"Our company is climate-positive forever because of MCC" (permanence is storage, not company liability)

Rationale: Permanence disclosed on certificate with risk assessment. Buyer must accurately represent durability.

4.6 Claim Stacking

Prohibited:

"Organization reduced emissions 50% AND achieved carbon neutrality through MCC" (double-counting same reduction)

"We claim EU ETS compliance AND corporate net-zero AND NDC contribution for same credits" (claiming triple value)

Rationale: Single credit supports one claim. Registry prevents double-transfer; claims substantiation prevents double-counting.

ARTICLE 5: CLAIMS SUBSTANTIATION REQUIREMENTS

5.1 Documentation Requirements by Claim Type

For Climate Contribution Claims:

  • Signed retirement authorization
  • MCC retirement certificate (serial numbers, project, vintage, CA status)
  • Public announcement or report (if disclosed)

For Conservation Contribution Claims:

  • Retirement certificate
  • Project fact sheet (ecosystem type, permanence, co-benefits quantified)
  • Community impact documentation (employment, livelihood data, if claimed)

For VCMI-Aligned Claims:

  • Emission baseline + reduction progress (third-party verified for Gold/Platinum)
  • Climate target and transition roadmap (published)
  • MCC retirement documentation (quantity, annual commitment if Platinum)
  • For Platinum: annual climate report + independent audit

5.2 Audit Rights

MCC reserves the right to audit claims substantiation:

  • Random audits: 5-10% of retiring organizations annually
  • Complaint-triggered audits: Within 30 days of public challenge
  • Regulatory audits: If authorities request verification

Audit Process:

  1. MCC requests documentation (14 days to respond)
  2. Independent reviewer assesses claim compliance
  3. Finding: Compliant, Conditional, or Non-Compliant
  4. If Non-Compliant: Corrective action plan required within 30 days
  5. If no response: Public notice of non-compliance; potential enforcement

5.3 Third-Party Verification

For claims involving:

  • Science-based reduction targets (VCMI Gold/Platinum) → SBTi-verified emission reduction required
  • Corporate net-zero 2050 → Third-party target verification required

MCC does not perform third-party verification; buyers responsible for obtaining certification.

ARTICLE 6: CERTIFICATE LANGUAGE REQUIREMENTS

6.1 Mandatory Certificate Components

All MCC retirement certificates must include:

A. Contribution Statement (Required)

This retirement represents [Buyer]'s contribution of [Quantity] tonnes CO₂
equivalent to marine conservation and global climate action.

B. Project Description (Required)

Project Name: [Name]
Location: [Country, Region]
Ecosystem: [F01-F05 Type]
Permanence: [X-year storage estimate]
Co-Benefits: [Fisheries, Biodiversity, Resilience impacts]

C. Corresponding Adjustment Disclosure (Required)

Corresponding Adjustment: [YES/NO]
Host Country: [Country]
Impact: [Host NDC adjustment details, if applicable]

D. Permanence Risk Assessment (Required)

Buffer Pool: [X%]
Risk Factors: [Coastal erosion, storm frequency, disease history, climate change, human pressure]
Permanence Mechanisms: [Legal protection, monitoring, endowment]

E. Safeguards Compliance (Required)

9/9 Safeguards Principles Satisfied:
✓ Human Rights | ✓ Gender | ✓ Health | ✓ Cultural | ✓ Corruption
✓ Economic Fairness | ✓ Climate Resilience | ✓ Water | ✓ Biodiversity

6.2 Appropriate Claim Language

Recommended Framing on Certificates:

"This retirement represents [Buyer]'s contribution to marine conservation
and coastal ecosystem restoration. MCC credits support global climate action
and complement [Buyer]'s own emissions reduction efforts."

6.3 Prohibited Certificate Language

Certificates shall NOT state:

  • "MCC credits offset [Buyer]'s emissions" (use "contribute to marine conservation")
  • "This makes [Buyer] carbon neutral" (use "supports [Buyer]'s climate commitment")
  • "Permanence guaranteed forever" (use "estimated X-year storage; buffer pool insurance")
  • "[Project] will single-handedly save fisheries" (use "contributes to fisheries enhancement; 50-hectare habitat restoration supporting 200+ fish species")

ARTICLE 7: CLAIMS MONITORING AND ENFORCEMENT

7.1 Claims Monitoring System

MCC establishes AI-assisted claims monitoring:

Intake Phase:

  • Buyer submits retirement claim (optional; many retirements not accompanied by claims)
  • Claim language analyzed for compliance with Policy (Article 3-4)
  • AI flags non-compliant language (e.g., "offset," "carbon neutral without reduction," "comparative")
  • MCC sends feedback (24-hour turnaround)

Publication Phase:

  • Buyer publishes claim in annual report, website, press release, etc.
  • MCC web monitoring (Google Alerts, press tracking) identifies public claims
  • Automated comparison to retirement certificate documentation
  • Discrepancies flagged for investigation

Audit Phase:

  • Annual random audits (5-10% of retiring organizations)
  • Complaint-triggered investigation (if stakeholder challenges claim)
  • Regulatory investigation (if authorities request verification)

7.2 Complaint Process

Stakeholder Complaint:

  1. Stakeholder submits complaint to MCC (email: claims@mcc-credits.org)
  2. Complaint must include: organization name, claim text, concern, source
  3. MCC acknowledges within 5 business days

Investigation (30 days):

  1. MCC reviews claim against Policy (Article 3-4)
  2. MCC requests documentation from buyer (if needed)
  3. MCC consults expert reviewers (if technical question)
  4. MCC makes determination: Compliant, Conditional, or Non-Compliant

Outcome:

  • Compliant: Complaint dismissed; buyer notified
  • Conditional: Buyer given 14 days to revise claim language
  • Non-Compliant: Enforcement action initiated (Article 8)

7.3 Monitoring Metrics (Publicly Reported Quarterly)

MCC publishes quarterly claims monitoring report:

  • Total retiring organizations (by quarter)
  • % of claims submitted for review (opt-in currently; may become mandatory)
  • % of claims flagged by AI (non-compliant language)
  • % of flagged claims corrected by buyers (compliance rate)
  • Complaints received (by category)
  • Enforcement actions initiated

ARTICLE 8: SANCTIONS FOR CLAIMS VIOLATIONS

Violations of this Policy trigger escalating enforcement:

8.1 Warning (First Offense)

Trigger: Non-compliant claim discovered; first incident for organization

Action:

  • Written warning (email)
  • 14-day corrective action period
  • Request revised claim language
  • Public notice withheld (private correction)

Requirements:

  • Buyer posts corrected claim language
  • MCC verifies compliance
  • Case closed

8.2 Suspension (Second Offense or Severe Violation)

Trigger:

  • Organization fails to correct within 14 days
  • Organization repeats violation after warning
  • Organization makes egregious claim (e.g., "MCC is only solution"; comparative disparagement)

Action:

  • 90-day suspension of credit retirement service for organization
  • Organization cannot retire additional MCC credits during suspension
  • Public notice issued (organization name, violation type, suspension period)
  • Stakeholder communication (investors, customers notified if applicable)

Reinstatement:

  • After 90 days, organization may request reinstatement
  • Requires written commitment to Policy compliance
  • One-time reinstatement; subsequent violations = deaccreditation (Article 8.3)

8.3 Public Notice and Deaccreditation (Third Offense or Fraud)

Trigger:

  • Organization suspended twice + refuses compliance
  • Organization commits fraud (e.g., falsifies retirement certificate, fabricates co-benefits)
  • Organization makes systematically misleading claims (pattern of violations)

Action:

  • Deaccreditation from MCC programme
  • All future credits transfers/retirements rejected
  • Public notice with full violation details
  • List published on MCC website ("Deaccredited Buyers")
  • Potential referral to authorities (for fraud cases)

Remedy for Stakeholders:

  • MCC may revoke retirement certificates if fraudulently obtained
  • Buyers harmed by fraud claims (reputational damage) may seek damages
  • MCC does not guarantee damages recovery; refers to legal counsel

8.4 Dispute Resolution Process

Organizations may dispute enforcement findings:

Appeal Period: 30 days from enforcement notice

Appeal Process:

  1. Organization submits appeal to MCC Board (claims-appeal@mcc-credits.org)
  2. Appeal must include: organization response, evidence, legal/factual argument
  3. Board appoints independent reviewer (external to MCC)
  4. Reviewer issues non-binding recommendation (30 days)
  5. Board makes final decision (14 days post-recommendation)

Appeal Grounds:

  • Factual error (claim was compliant; MCC misread)
  • Policy ambiguity (claim language in gray zone; Policy requires clarification)
  • Procedural error (MCC violated investigation timeline or due process)

Outcome:

  • Decision published (anonymized if upheld)
  • If overturned: enforcement action reversed; correction/reputational damage noted in MCC records

ARTICLE 9: BUYER GUIDANCE

9.1 How to Make Credible Claims with MCC Credits

Step 1: Know Your Emission Profile

  • Calculate Scope 1, 2, 3 baseline
  • Set science-based reduction target (SBTi-aligned recommended)
  • Plan reduction roadmap (CAPEX, timeline, interim targets)

Step 2: Reduce First

  • Implement operational changes (efficiency, renewable energy, supply chain transition)
  • Measure progress (third-party verified)
  • Set interim targets (e.g., 25% reduction by 2025)

Step 3: Use MCC for Residual

  • Once ≥50% reduction achieved, MCC credits address remaining emissions
  • Keep credit quantity <10% of total reduction (credits supplement, not primary strategy)
  • Document annual retirement amounts

Step 4: Substantiate Claims

  • Obtain MCC retirement certificate (serial numbers, project details, CA status)
  • Gather emission reduction documentation (verified baseline + progress report)
  • Prepare fact sheet (co-benefits quantification from certificate)

Step 5: Disclose Accurately

  • State emission reductions achieved (absolute %)
  • State MCC contribution (# credits, # projects)
  • Disclose CA status (host country → buyer country implication)
  • Emphasize permanence mechanisms (buffer pool, conservation easement)

Step 6: Publish Transparently

  • Annual climate report (ISO 14068 alignment recommended)
  • Third-party assurance (audit, SBTi verification, B Corp certified)
  • Stakeholder communication (investor, customer, employee audience)

9.2 VCMI Tier Self-Assessment

Tier 1 (Silver): Entry-level climate action

  • Emission reduction: 20-50%
  • Credit use: 5-15% of reduction
  • Target: Net-zero 2050 or interim 2030 target
  • Use case: Early-stage sustainability commitments

Tier 2 (Gold): Advanced climate action

  • Emission reduction: 50%+ achieved + on-track to interim target
  • Credit use: <10% of reduction (strict)
  • Target: Net-zero 2040-2050 with measurable progress
  • Use case: ESG-focused mid-cap and large corporates

Tier 3 (Platinum): Climate leadership

  • Emission reduction: 50%+ + interim target EXCEEDED
  • Credit use: Annual 1,000s+ credits over 5+ years
  • Target: Net-zero 2030-2040 (aggressive)
  • Use case: Shipping, airlines, luxury brands with extreme climate ambition

9.3 MCC Claims Audit Tool (Online)

MCC provides free online claims self-assessment:

Tool URL: mcc-credits.org/claims-audit

Input Fields:

  1. Organization name, sector
  2. Emission baseline (tCO₂e)
  3. Reduction achieved (%)
  4. MCC credits retired (#)
  5. Claim language (text)

Output:

  • Tier classification (Silver/Gold/Platinum or Non-Compliant)
  • Compliance assessment (Compliant, Conditional, or Non-Compliant)
  • Guidance (if non-compliant, suggested revisions)
  • Certificate link (downloadable)

Confidentiality: Tool is private; results not shared with MCC unless organization requests formal audit

ARTICLE 10: RELATED POLICIES AND CROSS-REFERENCES

This Policy interacts with:

  • MCC Registry Terms (Art. 5: Retirement mechanics)
  • MCC AI & Human Oversight Policy (Art. 4: AI flags non-compliant language)
  • MCC Transparency Policy (Art. 2: Claims data published quarterly)

ARTICLE 11: POLICY EFFECTIVENESS AND EVOLUTION

11.1 Effective Date

This Policy is effective upon MCC launch (mid-2026).

11.2 Review Cycle

Policy reviewed annually (March). Amendments proposed quarterly. Board approval required for material changes.

11.3 Stakeholder Feedback

MCC welcomes feedback on Policy clarity and effectiveness. Stakeholders may submit feedback to policy@mcc-credits.org.

11.4 Regulatory Tracking

MCC monitors evolution of VCMI Claims Code, EU Green Claims Directive (finalized 2026), ISO 14068, and SBTi BVCM. Policy updated to maintain regulatory alignment.

ARTICLE 12: REFERENCES

  • VCMI Claims Code of Practice (v1.0, 2023): vcmintegrity.org/claims-code
  • EU Green Claims Directive (Final, 2026): ec.europa.eu
  • ISO 14068: Carbon Neutrality (2023): iso.org
  • SBTi Beyond Value Chain Mitigation Guidance (2023): sciencebasedtargets.org
  • ICVCM Core Carbon Principles (v1.0, 2023): icvcm.org

Document Date: March 23, 2026 Next Review: March 23, 2027 Board Approval Required: YES

ENDRINGSLOGG v1.1 (24.08.2026)

Definisjonskatalogen i art. 2.2 etablerte en claimtype (EU ETS/regulatorisk) som art. 3.4 selv forbyr — definisjonen er nå eksplisitt merket NOT PERMITTED. Referansen «EU Green Claims Directive (Final, 2026)» i art. 12 skal verifiseres mot direktivets faktiske status før godkjenning. Grunnlag: regelverksrevisjonen 24.08.2026 (vedlegg 6).

Vedtatt 24.08.2026 ved FD-2026-08-24. Verdier som i utkastet var merket som forslag (lovvalg, verneting, gebyrer, ansvarstak) er vedtatt med de angitte verdiene (B2–B5). Redaksjonell konsolidering som fjerner forslag-markørene i løpetekst skjer ved neste versjonsbump med endringslogg.