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Governance decisions

Founder Decision FD-2026-09-04

Version 2026-09-04Decided 2026-09-04 · FD-2026-09-04EnglishMCC_Founder_Decision_FD-2026-09-04_UTKAST_for_signatur.md

A decision record, served as the programme record holds it. Whether it is signed is carried by the decision book, not by this page. A decision record is not amended after the fact: anything on its face that has since been overtaken is stated in the notice above the text.

Correction notice

Notice, 1 October 2026. Served as archived in 00_Styring_og_Vedtak: the draft prepared for signature, which the register records as ATTESTED by the founder on 4 September 2026 with the executed copy not received. Four things on its face are overtaken or unmet, and the text is unchanged. (1) Item 2 says twenty-three texts are loaded; the opening script lists twenty-eight (MCC-ROI, MCC-REST, MCC-IRC, MCC-APP and MCC-M008 Am. 1 were loaded later on 4 September, after this draft was written — PRs #240, #241 and #248), and the notice periods by tier are unchanged. (2) Item 5 resolved that the database plan with daily backups and point-in-time recovery be procured "immediately": on 1 October 2026 the organisation that holds the registry database is still on the free plan, and the platform's health and component registers record no backup and no off-site export. The gate in the same item — no credit issued before a tested backup exists — stands, and no credit has been issued. (3) Item 3 resolved that the peer-review invitation issue within seven days. MCC-RAT-2026-001, a draft of 10 September, describes the invitation as already issued, but no copy of a sent invitation has been found in the programme record. (4) Item 1 has not been carried out in full. The six consultations closed on 24 September 2026 with published protocols, five recommending adoption and the errata not, each of the five stating that adoption rests on this decision as attested, not signed (MCC-CLS-2026-001 §B.1). None of the five has been entered in the document register with this decision as its adopting instrument, so none is yet adopted.

Founder Decision FD-2026-09-04

Marine Conservation Credits Programme — decision of the founder

Field Value
Reference FD-2026-09-04
Date of decision 4 September 2026
Made by Leif Martin Klakken, founder
Basis MCC-001 cl. 0083 (Tier 5 amendment by the operational team with Board oversight); FD-2026-08-24 item 3 (programme administration); FDP-2026-001 C4 (the consultation calendar is the founder's); MCC-200 cl. 0040 (in force)
Status DRAFT — FOR SIGNATURE. Nothing in it takes effect until it is signed and the executed copy is in the programme record.
Ratification To be sought at the Governing Board meeting of 23 September 2026, as FD-2026-08-24 was ratified in GB-2026-001 item 2

NOTE. This decision carries only matters within the founder's or programme administration's own competence. Every matter an instrument reserves to the Governing Board by name is listed at item 6 and is not decided here. Programme administration will execute items 1 to 5 on receipt of the signed copy, and not before.

Item 1 — Adoption of six texts at the close of their consultations

Six consultations opened on 25 and 26 August 2026 with fourteen days' notice. Each received no comments. Each names, as its decision body, "Programme administration under FD-2026-08-24 item 3, with Board oversight (MCC-001 cl. 0083)" — the KYC procedure with Registry Oversight Authority oversight. Adoption is therefore within programme administration's competence, exercised here by the founder.

RESOLVED that each of the following texts is adopted, unamended, at the close of its consultation, in the version whose SHA-256 is recorded against it:

Text Closes SHA-256 (first 16)
Applicant Guidance — Errata and Clarifications No. 1 (F01, F02, F05) 8 September 2026 cd5618a98354b6ed
Validation Report Template v1.0 8 September 2026 436c06cb1b578980
Verification Report Template v1.0 8 September 2026 a044bf7bbb3572f3
Registry KYC and Account Opening Procedure v1.0 8 September 2026 1a26e33bc0759d95
Rule Change and Public Consultation Procedure v1.0 8 September 2026 96c40593b9fd4ffd
VVB Accreditation — Assessment Report Templates v1.0 9 September 2026 9c2ca6edf58f38db

RESOLVED that each adopted text is entered in the document register with FD-2026-09-04 as its adopting instrument, so that none of the six joins the twelve instruments in force that have none.

RESOLVED that the consultation register records for each: the notice period given, the closing date, and that no comment was received — which is a fact about the consultation and is published as one, not treated as endorsement.

Item 1.1 — What the Errata does not carry

NOTED that Part E5 of the Errata requests a determination reserved to the Standards Committee (Tier 4, MCC-700 §11): which reef carbon pools are eligible for the CO₂e component in F02 and F05, the instrument's working assumption being organic carbon in biomass and sediment only, with carbonate excluded.

RESOLVED that the Standards Committee is not constituted and the determination is not made by this decision; that the corrected F02 and F05 worked examples take effect as arithmetic corrections of the v1.0 text and not as endorsement of the underlying stock figures, as the instrument itself states; and that no MCC-HYB unit shall be issued for a reef site under F02 or F05 until the determination is made.

Item 2 — The consultation calendar for the rewritten suite

NOTED that twenty-three texts are loaded in the platform with their hashes and none is open; that the loader refuses to run without an explicit opening date, so that no notice period can begin by accident; and that draft resolution 4.4 of the board pack proposes 1 October 2026.

RESOLVED that the rewritten suite opens for public consultation on 1 October 2026, with notice periods by tier — 90 days for Tier 1 (1 text), 60 for Tier 2 (1), and 30 for the remaining 21 — so that the Charter consultation closes on or about 30 December 2026 and no text is adopted before that date.

RESOLVED that DPIA-2026-001 is excluded from that opening: it is an assessment and not a rule change, and a consultation on it would invite comment on a document that proposes no rule.

Item 3 — External peer review of M001–M003

NOTED that MCC-200 clause 0040 is in force and requires methodology approval to be preceded by at least one round of external peer review by qualified independent scientists; that clause 0042 requires the public consultation to follow that review; that no review has been commissioned; and that the single invitation prepared on 31 August 2026 has never been sent.

RESOLVED that adoption of M001–M003 on 30 September 2026 is not available, on any majority and by any body, and that the date is abandoned.

RESOLVED that the invitation shall issue within seven days, seeking comments by 30 November 2026, to at least one reviewer in addition to the Sfax team, so that no methodology rests on a single review; and that the affiliations of the named reviewers are confirmed before it is sent.

RESOLVED that the F01 consultation opened on 31 August 2026 runs to its close on 30 September 2026, that every comment received is published, and that it is recorded on the consultation register as a pre-consultation on CONCEPT texts which does not discharge clause 0042, with the reason published alongside.

Item 4 — The published fee example

NOTED that Transparency Policy §2.9 publishes a worked example totalling €9,500 in the first year, and that no instrument in force sets those amounts.

RESOLVED that the worked example is marked as an illustration, as §§2.5, 2.6 and 2.7 of the same Policy already mark theirs, pending the Board's adoption of the Fee Schedule; and that no fee figure is quoted to any applicant or published as a price until the Board has set it.

Item 5 — Recovery of the registry database

NOTED that MCC-800 article 21 publishes a recovery point objective of one hour and a recovery time objective of four hours; that the deployed database runs on a plan that includes neither daily backups nor point-in-time recovery; that no export of the registry database has ever been taken; that object storage lies outside database backups at every plan level; and that the real recovery point and recovery time are therefore unbounded and untested.

RESOLVED that the database plan including daily backups and point-in-time recovery is procured immediately, and that an off-site export of the database and of object storage is established, the date each is first achieved being recorded and reported to the Board.

RESOLVED that no credit shall be issued before a tested backup exists, an independent penetration test has been completed and its findings addressed, and DPIA-2026-001 has been reviewed by a qualified data protection adviser.

Item 6 — What this decision does not do

NOTED that the following are reserved by an instrument in force to the Governing Board, by name, and are not decided here. They go to the meeting of 23 September 2026:

Reserved matter The clause that reserves it
Transmission of applicant documentation to an external model provider MCC-850 art. 9, 39–40 — "authorized by Board decision". Until authorised, the alternative in force is Degraded Mode
Every fee amount MCC-800 art. 99; MCC-400 art. 84
The status of MCC-SDCF following conformity review CR-2026-001 A review records findings; status is the Board's
Completing or setting aside MCC-BDR-2026-002 The Board's own record
Resuming or withdrawing the five stayed consultations Reserved when the stay was made (CSN-2026-001)
The programme's legal entity — name and jurisdiction Two documents in force give it differently
Constituting the Standards Committee; appointing at least one external member of the appeals panel The Board is first instance and cannot hear an appeal from itself

NOTED further that four matters are work rather than decisions and cannot be resolved by any approval: the independent penetration test, the review of DPIA-2026-001 by a qualified adviser, a tested backup, and the external peer review at item 3.

Execution

Programme administration shall, on receipt of the signed copy: adopt the six texts at their closing dates and enter each with this decision as its adopting instrument; open the suite on 1 October 2026; issue the peer review invitation; mark the §2.9 example; and report the backup position. Nothing at items 1 to 5 is executed before then.

Signature

Founder: ................................................ Leif Martin Klakken

Date: ................................

Prepared 4 September 2026 by programme administration as a draft for signature. Sources: the consultation register as at 4 September 2026 (six open consultations closing 8 and 9 September, no comments received, hashes as recorded); MCC-001 cl. 0083; FD-2026-08-24 item 3; FDP-2026-001 C4; MCC-200 cll. 0040, 0042; MCC-700 §11; MCC-800 arts. 21, 99 and v2.0-draft cll. 18.5, 19.4; MCC-400 art. 84; MCC-850 arts. 9, 39–40; Errata No. 1 Part E5; board pack GB-2026-002 draft resolutions 4.4 and 7.2 and Addenda 3 and 4; execution note EN-2026-001.