How Carbon Markets Function Under the Paris Agreement Framework

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Alexander Ferrigno
Edit: Shortly after the creation of this article developments at COP29 were made that change the landscape of this topic massively. There is now a consensus among States regarding emissions trading under Article 6. I will explore that in a new article once details regarding this consensus are revealed.

As countries moved away from the Kyoto Protocol, which eventually led to its collapse, the Paris Agreement emerged with a similar aspiration but different strategies. While the Kyoto Protocol focused on setting a baseline for reducing greenhouse gas (GHG) emissions, the Paris Agreement sets a more specific target: to limit global temperature rise to well below 2°C above pre-industrial levels, with the goal of pursuing efforts to limit the increase to 1.5°C.1

A significant shift under the Paris Agreement is the move away from the “common but differentiated responsibilities” principle of the Kyoto Protocol. Instead of assigning different responsibilities based on countries’ economic status, the Paris Agreement places the burden of combating climate change on all countries, allowing each to determine its own commitments to the common goals through Nationally Determined Contributions (NDCs). This marks a transition from a top-down approach with mandatory commitments to a bottom-up approach based on voluntary contributions.2

The Paris Agreement includes both legally binding and non-binding elements, carefully distinguished by its language. For instance, obligations that are legally binding often use the word “shall,” particularly concerning the requirements for reporting and transparency on how each country plans to achieve its NDC.3 Article 13 outlines the transparency framework, requiring countries to submit GHG inventories and report on the progress of their NDC implementation, ensuring accountability and fostering trust among nations.

Focus on Article 6 and the Evolution of Carbon Markets

One of the critical components of the Paris Agreement is Article 6, which addresses cooperative approaches and mechanisms that allow countries to meet part of their NDCs through international market mechanisms. After the Kyoto Protocol, there was much uncertainty about the future of carbon markets. Discussions on new market mechanisms began in 2007,4 then continuing on until COP21, which resulted in the cooperative approaches established under Article 6.

Article 6.2 provides for the use of cooperative approaches that involve the transfer of Internationally Transferred Mitigation Outcomes (ITMOs).5 An ITMO can represent various forms of emission reductions and allows countries to trade GHG reductions, similar to the Joint Implementation (JI) mechanism under the Kyoto Protocol.6 However, unlike the Kyoto Protocol, Article 6.2 of the Paris Agreement does not restrict ITMOs from being used to achieve NDCs,7 offering flexibility in how countries can meet their climate commitments.8 Some countries support this flexible approach, seeing it as a way to enhance cooperation and cost-effectiveness in achieving climate goals.

This flexibility facilitates trading on the carbon market; however, Joint Implementation (JI) and the Clean Development Mechanism (CDM) were not included in the Paris Agreement, which initially meant there were no mechanisms for generating credits. Article 6.4 addresses this issue by establishing the Sustainable Development Mechanism,9 which provides a framework for credit generation. As a result, states are fully empowered to create Emissions Trading Systems (ETS), engage in carbon trading, and use these systems to meet their Nationally Determined Contributions (NDCs).

Despite these benefits, the lack of strict regulations on ITMO use raises concerns about “double counting”—where the same emission reduction is claimed by both the buyer and the seller.10 The Paris Agreement has attempted to address this issue through its rulebook,11 which requires countries to report adjustments to their emissions inventories to reflect the use of ITMOs. These adjustments ensure that emissions reductions are counted only once, either by the country that generates the reductions or the one that uses them.12 In contrast, deductions are made to account for the acquisition or use of mitigation outcomes that have been internationally transferred.13 However, these rules are yet to be expressed in Article 6, leaving room for potential gaps in enforcement and accountability.

Challenges in Defining the Scope of NDCs and Mitigation Efforts

A significant challenge in implementing Article 6 is determining how mitigation efforts not covered by a country’s NDC should be treated. Different countries have adopted various scopes for their NDCs: some target all GHG emissions, while others focus on specific gases or sectors. For example, China has committed to reducing carbon dioxide emissions but not other greenhouse gases.14 This raises questions about how to account for mitigation outcomes that fall outside the scope of a country’s NDC, especially if these outcomes are traded internationally.15

The complexity of defining an NDC’s scope stems from the diverse approaches countries have taken. Some countries provide quantifiable emission reduction targets, while others neglected to do so,16 possibly opting for different metrics, such as global warming potential.17 Additionally, some NDCs lack specificity regarding which sectors or emissions are covered, making it challenging to determine whether certain mitigation activities fall within the scope of an NDC. As Schneider explains, if a country implements a technology like biogas digesters that reduces emissions across multiple sectors, it may be unclear whether all these reductions count towards the country’s NDC.18

Estimates suggest that 12-14% of global emissions are currently outside the scope of NDCs,19 with a significant portion of these emissions originating from countries with less comprehensive targets, such as China. Allowing mitigation outcomes outside the NDC scope to count towards another country’s NDC could undermine the Paris Agreement’s goals by enabling countries to meet their targets through external efforts rather than enhancing their domestic mitigation actions. While there are potential benefits to this approach, such as improved emissions data and reduced mitigation costs, it could also discourage countries from expanding the scope of their NDCs and lead to double counting, which would weaken the overall effectiveness of global climate efforts.20

On the other hand, allowing outside-scope mitigation transfers on the carbon market could dissuade States from increasing their ambition through expanded scope, as they would no longer need to expand what sectors and emissions their NDC would cover if a State can use another States outcomes instead. Furthermore, allowing it would go against other articles of the Paris Agreement, specifically that “Developed country Parties should continue taking the lead by undertaking economy-wide absolute emission reduction targets.”21 It would disincentivise States from moving towards “economy-side” targets. More importantly, double counting would also likely occur, as mentioned prior, assuming only that GHG-emissions are only defined by the targets and sectors communicated within an NDC.22

Also, and importantly, as mentioned above some States opted for different metrics of their targets, meaning that a transfer of a carbon unit outside the scope of an NDC could also lead to an increase of global GHG emissions, if the unit is not converted properly.23 Finally, a transfer could lead to only temporary reductions, but will be counted the same, such instances would typically occur only within certain sectors, such as the storage of carbon dioxide or in forestry sectors.24 Although there may be more disadvantages to advantages, whether the advantages outweigh the higher number of disadvantages is a matter of perspective. On the one hand, States will have a better understanding of emissions globally, which can influence their next NDC, as well as making it easier to achieve their NDCs, at least on paper. On the other hand, you would be undermining the spirit of the Paris Agreement, while also running the risk of double counting.

Ensuring the Quality of Carbon Credits in the Evolving Market

Regardless of whether mitigation outcomes fall inside or outside an NDC’s scope, the quality of carbon credits generated through these activities is critical. High-quality carbon credits depend on “additionality,” meaning the emission reductions must be additional to what would have happened in the absence of the market mechanism. Overestimating reductions can lead to the issuance of credits that do not represent genuine climate benefits, especially if the market is oversaturated with more credits than demand. In a way it is paradoxical, these estimations become murky when crediting through additionality. Assuming the market is oversaturated with a higher supply than demand, future projects would quite possibly just stop genuine reduction of global GHG entirely.25

The ambition level of a country’s NDC also influences the quality of the carbon credits it can offer. Countries with more ambitious targets are more likely to undertake robust mitigation efforts, ensuring that the credits generated are of high quality. Conversely, countries with less ambitious targets may have weaker incentives to ensure the quality of the credits they generate, potentially compromising the integrity of the carbon market. This was evidenced well in Kyoto’s Joint Implementation.26

Voluntary Carbon Markets (VCM) Under the Paris Agreement

Since the emergence of carbon markets, we have seen a surge in non-international, or voluntary, markets across all types of economies—both developed and developing. In the early days, most national carbon markets were connected to the international credit market, such as the EU’s system. However, as the EU’s international credit market faced challenges and eventually shut down, other states followed suit, aiming to protect their markets from being overwhelmed by low-cost credits from less stringent regions.27 This shift created significant uncertainty in carbon markets over the past two decades. Despite these challenges, there is currently a high volume of credit transactions in voluntary carbon markets under the Paris Agreement’s Article 6 mechanisms.28 The financial services sector, in particular, is among the largest users of carbon credits, indicating a strong and continuing demand for these credits.29

The demand for carbon credits in voluntary markets is closely tied to the governance structures overseeing these markets, especially regarding the institutions responsible for issuing the credits.30 The current structure of the VCM involves four key types of institutions:

  1. Voluntary Standards Organizations: These entities develop criteria for project development, ensuring that projects generating carbon credits meet certain baseline requirements.31
  2. Standard-Setting Organizations: Groups like the Gold Standard expand upon and evolve the guidelines set by voluntary standards. They also monitor the issuance of credits to ensure consistency and quality.32
  3. Third-Party Verification Bodies: These organizations verify compliance with the standards set by the first two types of institutions, ensuring that credits are genuine and that emissions reductions are real and measurable.33
  4. Independent Credit Registries: These registries help prevent double counting by maintaining records of issued credits and their transfer between parties.34

During the era of the Clean Development Mechanism (CDM), voluntary carbon markets were seen as a cost-effective solution to supplement the CDM, which was criticized for not achieving sufficient global GHG reductions.35 These voluntary institutions were tasked with developing baseline-and-credit systems to maintain the environmental integrity of carbon credits.36 However, the definition of “environmental integrity” remains somewhat ambiguous, as it is not explicitly defined in either the United Nations Framework Convention on Climate Change (UNFCCC) documents or the Paris Agreement. Article 6 frequently references the concept, especially in the context of the mechanisms under Article 6.4, which aim to ensure that carbon credits reflect real, measurable mitigation benefits.

In the context of Article 6, environmental integrity can be understood as ensuring that international transfers of carbon credits result only in genuine reductions in GHG emissions or, at the very least, do not lead to an increase in global emissions had the transfer not occurred.37 Maintaining environmental integrity leads to common principles and practices across different carbon markets, although significant differences in governance remain.38 These governance structures can be either public, where governments set regulations and policies, or private, where resistance from stakeholders—often due to the economic implications of emission reductions—leads to different standards and practices.39

Sometimes, public and private governance structures overlap. For instance, under the Kyoto Protocol’s Joint Implementation (JI) and CDM, some private governance frameworks, like those developed by the Gold Standard, merged with public frameworks to enhance the robustness and credibility of carbon markets.40 Conversely, public regimes may shift toward private governance, as seen when some states, like India, chose to use the Gold Standard guidelines over the CDM’s minimum sustainable development criteria to maintain sovereignty over their carbon markets.41 In this case India preferred not to adhere strictly to the CDM’s requirements.

As carbon markets have evolved, fragmentation remains a significant issue, though it is less pronounced now compared to the Kyoto Protocol era. This is partly due to the mechanisms designed to limit fragmentation and partly due to the Paris Agreement’s paradigm shift toward a bottom-up approach.42 Under this new framework, countries set their own long-term objectives, which, while aimed at the same overall goal, can vary significantly in scope and ambition. This flexibility has created a “grey zone” between compliance-based and voluntary-driven targets, further complicating the landscape of carbon markets.43

The Role of Offsetting in Voluntary Markets

Offsetting in voluntary carbon markets involves actions to reduce emissions in one area to compensate for emissions elsewhere. For example, a company or state might purchase carbon offsets, such as carbon credits, to counterbalance its emissions, effectively achieving a net zero balance. This concept is closely linked to “additionality,” which requires that emissions reductions be beyond what would have occurred without the project. Ensuring additionality is critical to the credibility of carbon credits, as it addresses the challenge of accurately counting emissions reductions—a challenge highlighted by researchers Lang, Blum, and Leipold, who noted that accurate emissions accounting is vital to avoid double counting and ensure reliable data on emissions reductions.44

Double counting, particularly in the form of “double claiming,” where a single reduction unit is accounted for by multiple entities, poses a significant threat to the integrity of carbon markets.45 To mitigate this risk, there is a need for a uniform set of criteria across carbon markets, similar to how the Gold Standard filled gaps in the previous regime by emphasizing the importance of avoiding double counting, which it described as a “life-threatening challenge” to market credibility.46

Interestingly, the Gold Standard has proposed developing certified statements of emissions reductions that could facilitate emissions accounting without relying on offsets. This approach, often referred to as “financing emission reductions,” does not replace carbon credits but provides an additional mechanism to support climate action while allowing for corresponding adjustments.47

Corresponding Adjustments (CA) Under the Paris Agreement

Article 6 of the Paris Agreement introduces mechanisms for corresponding adjustments (CAs), which are essential to prevent double counting in the transfer of Internationally Transferred Mitigation Outcomes (ITMOs). Corresponding adjustments ensure that when one country transfers an ITMO to another, both countries adjust their greenhouse gas (GHG) accounting accordingly. The transferring country deducts the reduction from its own GHG inventory, while the receiving country adds it to its emissions accounting. This system applies to ITMOs that are transferred to help another country meet its Nationally Determined Contribution (NDC), ensuring that both parties accurately reflect this transaction in their emissions records.48

However, challenges arise when the ITMO involves mitigation actions outside the scope of a country’s NDC. Questions persist about whether the original host country’s role in oversight and accounting remains when these out-of-scope mitigation efforts are transferred. There is also the issue of whether emission reductions not covered under Article 6.4, such as those generated in voluntary carbon markets (VCMs), require corresponding adjustments.49 Since these are not classified as ITMOs, they traditionally do not need CAs. The debate on whether corresponding adjustments should apply to voluntary markets intersects with broader discussions on the role of VCMs in non-state financing,50 which is beyond the scope of this paper. However, aligning VCMs with CA requirements could help prevent double counting and ensure that states genuinely meet their NDC goals.51

Linking Voluntary Carbon Markets and Corresponding Adjustments

Integrating VCMs with the Article 6 framework of the Paris Agreement could close the “ambition gap” by bringing activities previously outside governmental climate governance under stricter oversight. This link would expand climate governance to include voluntary actions, enhancing clarity and reducing the risk of double counting.52 However, this integration has not been solidified, partly because many VCMs were established before the Paris Agreement was enforced. As a result, emission reductions from these markets often did not contribute directly to achieving NDC goals. To address this, a proposed cut-off date for the registration of credits earned through mechanisms like the Joint Implementation (JI) or Clean Development Mechanism (CDM) was suggested.53 This uncertainty contributed to the decline of these earlier mechanisms, as the potential expiration of credits diminished interest and investment.

The collapse of the CDM also raises questions about how ITMOs under Article 6 should handle the Share of Proceeds—a portion of carbon offset proceeds allocated to local communities where projects are located. During the CDM era, a percentage of the credits issued was withheld and later sold on the international market,54 but it is unclear how this practice applies to ITMOs under Article 6. Some argue that incorporating a Share of Proceeds into Article 6 transactions would ensure that Article 6.4 mechanisms are not disadvantaged compared to other carbon market approaches.55 Others believe that a 2% share in a centrally governed account might not be effective, particularly if the transactions are government-to-government, which could limit their value in the market.56

Adjusting NDC Targets with Corresponding Adjustments

When ITMO transfers occur, corresponding adjustments could be made by increasing the NDC target of the buying country while proportionally decreasing the target of the selling country, based on the volume of the transferred credits.57 If “regular” carbon units—not from financing emission reductions—are used as a basis for CAs, this could allow countries to claim carbon neutrality. Carbon neutrality is achieved when an entity balances its carbon emissions by investing in carbon credits or other reduction projects to offset its emissions. The International Carbon Reduction and Offset Alliance (ICROA) has published guidelines outlining when CAs are needed for carbon neutrality claims,58 proposing multiple approaches:

  1. NDC-Crediting Model: Here, corresponding adjustments are directly tied to an NDC-related crediting framework.
  2. Non-NDC Crediting Model: This involves mitigation outcomes that are outside the scope of NDCs, allowing flexibility but posing challenges for long-term sustainability as it would require countries to eventually move towards economy-wide NDCs.
  3. Financing Model: Outcomes are owned by the host country, which could prevent double counting and assist countries in meeting their NDC targets. However, this model would not allow non-state actors to claim carbon neutrality, as private sector involvement is essential for achieving these goals.59

While the financing option helps avoid double counting, it also limits the capacity of non-state actors to achieve carbon neutrality. The voluntary market has traditionally enabled private entities to make carbon neutrality claims, but under this model, such claims would be limited to financing reductions rather than direct emissions reductions.60

Debates on Corresponding Adjustments and Carbon Neutrality

The non-crediting model suggested by ICROA also has drawbacks, such as its unsustainability over the long term without a shift to broader NDCs.61 However, it could help countries transition to more comprehensive targets. On the other hand, the NDC-crediting model, despite requiring the development of Emissions Mitigation Mechanisms (EMMs), offers substantial advantages. It supports offsetting through the Paris Agreement, allows non-state actors to claim carbon neutrality, and helps close the ambition gap by enabling reductions beyond NDC scopes.62 However, the ICROA later revised its stance in a 2019 paper, arguing that carbon neutrality claims could be made using voluntary credits without needing corresponding adjustments.63 They suggested that since mitigation outcomes are reported and counted only by the selling country to the UNFCCC, and not at the corporate level, there is no risk of double counting.64

Strengthening Carbon Market Integrity Through Corresponding Adjustments

Despite the various approaches and ongoing debates, the best path forward seems to be the NDC-crediting approach. This model strengthens the legitimacy of carbon credit offsetting for achieving carbon neutrality while maintaining environmental integrity by preventing double counting. Ensuring robust and consistent use of corresponding adjustments under the Paris Agreement will be crucial for enhancing the transparency and effectiveness of global carbon markets.65

Additionality Under the Paris Agreement

Additionality is a crucial concept in carbon markets and has been mentioned frequently. However, a detailed review of how additionality functions under the Paris Agreement is necessary, as it will be relevant in subsequent sections. Additionality can be defined in various ways and is usually contextual, as there is no universally accepted definition. In general, additionality refers to whether a project or activity results in emissions reductions that would not have occurred without the incentive provided by the carbon market.

Determining additionality is challenging, especially in carbon markets where numerous variables can affect whether a project is truly “additional”. In practice, the assessment of additionality often depends on the type of additionality being evaluated. For example, investment additionality can be identified if a project’s profitability is lower than the minimum rate of return required for a comparable project or investment,66 or if the return is less than what would be expected under a “business-as-usual” scenario. The difficulty in defining additionality, coupled with the variety of projects emerging in voluntary carbon markets (VCMs), means that no single method can convincingly verify additionality across all contexts, even when standardized approaches are used.67

The term “business-as-usual” (BAU) is essential in the context of the Paris Agreement because it serves as a baseline for assessing additionality. To determine if a project is additional, one must demonstrate that it would not have occurred without the carbon market, as discussed in earlier chapters. Establishing a baseline—a comparison case showing what would happen in the absence of the project—is crucial for this determination. This baseline can be established using several methods, including modelling, historical data analysis, or comparing against a BAU approach.

Once a baseline is set, it is necessary to provide evidence that the project has resulted in emissions reductions beyond what would have occurred without it. This can be a complex task but can be facilitated through monitoring and reporting systems or third-party verification, both of which ensure that the reductions are genuine and measurable. If a project is demonstrated to be additional, it becomes eligible for carbon credits. However, it’s important to note that if credits are issued for a project that is not genuinely additional, global emissions might not increase, unless the BAU assessment overestimates the emissions that would have influenced the State’s NDC.68 In such cases, if the NDC target is lower than or equal to the BAU emissions, it could lead to an overall increase in global emissions.69

Challenges and Complications in Assessing Additionality

The challenge of additionality is intricately linked to the concept of “hot air,” which was a significant concern during the Kyoto Protocol and its Joint Implementation (JI) mechanism. Under these mechanisms, there was substantial evidence that BAU projections were often inaccurate, with over three-quarters of emissions units generated under JI issued with questionable environmental integrity.70 This issue continues under the Paris Agreement, where many NDC baselines exceed their BAU paths and are used as the basis for crediting emission reductions.71

Distinguishing ambitious NDCs from non-ambitious ones is essential, but doing so poses a methodological challenge. It could require a top-down assessment of NDCs and their associated projects, which contradicts the Paris Agreement’s bottom-up approach to climate mitigation. Additionally, it presents a political challenge since the “nationally determined” nature of NDCs means countries may resist external assessments of their targets, policies, or implemented projects.72

Further complicating additionality under the Paris Agreement, particularly concerning Article 6 mechanisms, is the ambiguity surrounding the conditionality of NDCs. Technical challenges arise in translating NDC metrics into additionality assessments, especially when using NDC targets as baselines assumes these targets are below BAU levels—a condition that is often not met.73 Therefore, accurately assessing additionality requires careful consideration of the specific conditions and metrics used by each country, which can vary widely.

Conclusion and Future Considerations for Carbon Markets

Understanding additionality and its complexities is vital for ensuring the integrity and effectiveness of carbon markets under the Paris Agreement. As we explore the future of these markets, addressing the challenges associated with additionality—such as ambiguous definitions, varying baselines, and the diverse nature of voluntary carbon markets—will be crucial for enhancing their credibility and ensuring that they contribute meaningfully to global emissions reductions.

The future prospects of carbon markets under the Paris regime will be looked at in a separate article. Exploring potential developments and the ongoing evolution of these mechanisms.

  1. United Nations Framework Convention on Climate Change (UNFCCC) Adoption of the Paris Agreement, COP21, Paris: United Nations [2015] Article 2 (1) (a) ↩︎
  2. Axel Michaelowa, Igor Shishlov and Dario Brescia, ‘Evolution of international carbon markets: lessons for the Paris Agreement’ (2019) 10 WIREs Clim Change 1-24, 12 ↩︎
  3. See for example: Article 13 (3) ↩︎
  4. UNFCCC, Report of the Conference of the Parties on its thirteenth session held in Bali, COP13 [2007] ↩︎
  5. UN Doc FCCC/SBSTA/2017/7, ‘United Nations Framework Convention on Climate Change, Subsidiary Body for Sci. and Tech. Advice, Rep. of the Subsidiary Body for Science and Technology, Advice on Its Forty-Seventh Session’ [2018] sections 87-92 ↩︎
  6. Michaelowa (n 2) 13 ↩︎
  7. Ling Chen, ‘Are Emissions Trading Schemes a Pathway to Enhancing Transparency under the Paris Agreement?’ (2018) 19 Vermont J’ Env L 306-337, 307 ↩︎
  8. See for example Canada, Submission on SBSTA Item 11(a) [2017] Article 6, Paragraph 2, Section 4; Republic of Korea, Submission on Art 6.2 and 6.4 of the Paris Agreement 2 [2017] ↩︎
  9. ibid ↩︎
  10. Lambert Schneider, et al, ‘Outside in? Using international carbon markets for mitigation not covered by nationally determined contributions (NDCs) under the Paris Agreement’ (2020) 20 Climate Policy 18-29, 19 ↩︎
  11. The Katowice Climate Package [2018] (often referred to as the Paris Rulebook) ↩︎
  12. Schneider (n 10) ↩︎
  13. ibid; Decision 18/CMA.1, Modalities, Procedures and Guidelines for the Transparency Framework for Action and Support Referred to in Article 13 of the Paris Agreement [2020], Annex, paragraph 77(d) ↩︎
  14. ibid; see generally UNFCCC, China’s Submission on Further Guidance for the Nationally Determined Contributions under the Paris Agreement, available https://www4.unfccc.int/sites/SubmissionsStaging/Documents/199_279_131197033692013328-Submission%20on%20NDC%20China.pdf ↩︎
  15. ibid ↩︎
  16. UN Doc. FCCC/CP/2015/7, UNFCCC Secretariat, ‘Synthesis Report on the Aggregate Effect of the Intended Nationally Determined Contributions’, para. 8; see also UN Doc. FCCC/CP/2016/2 (Update Note), UNFCCC Secretariat, ‘Aggregate Effect of the Intended Nationally Determined Contributions: An Update’, update note para 9 ↩︎
  17. Lambert Schneider & Stephanie La Hoz Theuer, ‘Environmental integrity of international carbon market mechanisms under the Paris Agreement’ (2019) 19 Climate Policy 386-400, 389 ↩︎
  18. Schneider (n 10) 20 ↩︎
  19. Malte Meinshausen and Ryan Alexander, ‘NDC & INDC factsheets’ (2016) accessible: https://www.climatecollege.unimelb.edu.au/ndc-indc-factsheets ↩︎
  20. Schneider (n 10) 21 ↩︎
  21. Paris Agreement, Article 4.4 ↩︎
  22. Schneider (n 10) 22 ↩︎
  23. Schneider (n 17) 389 ↩︎
  24. ibid 390 ↩︎
  25. Carsten Warnecke et al, ‘Vulnerability of CDM Projects for Discontinuation of Mitigation Activities: Assessment of Project Vulnerability and Options to Support Continued Mitigation’ (DEHSt 2017) 100 ↩︎
  26. Anja Kollmuss et al, ‘Has Joint Implementation Reduced GHG Emissions? Lessons Learned for The Design of Carbon Market Mechanisms’ (2015) SEI WP 2015-07 1-124, 76 ↩︎
  27. Michaelowa (n 2) 12 ↩︎
  28. Guy Turner et al, ‘Future Demand, Supply and Prices for Voluntary Carbon Credits—Keeping the Balance’ (2021) Trove Research, 7 ↩︎
  29. ibid ↩︎
  30. Hanna‐Mari Ahonen et al, ‘Governance of Fragmented Compliance and Voluntary Carbon Markets Under the Paris Agreement’ (2022), 10 Politics and Governance 235-245, 236 ↩︎
  31. Sebastian Lang et al, What future for the voluntary carbon offset market after Paris? An explorative study based on the Discursive Agency Approach (2019) 19 Climate Policy 414-426, 416 ↩︎
  32. ibid ↩︎
  33. ibid ↩︎
  34. ibid ↩︎
  35. ibid 417 ↩︎
  36. Ahonen (n 30) ↩︎
  37. Schneider (n 17) 388 ↩︎
  38. Ahonen (n 30) ↩︎
  39. ibid ↩︎
  40. Axel Michaelowa et al, ‘Catalysing private and public action for climate change mitigation: The World Bank’s role in international carbon markets.’ (2021) 21 Climate Policy 120–132, 126 ↩︎
  41. Jon Philips, ‘Governance and technology transfer in the Clean Development Mechanism in India’ (2013) 23 Global Environmental Change 1594–1604, 1602 ↩︎
  42. Ahonen (n 30) 237 ↩︎
  43. ibid 238 ↩︎
  44. Lang (n 31) 419 ↩︎
  45. ibid ↩︎
  46. Nicolas Kreibich and Lukas Hermwille, ‘Caught in between: credibility and feasibility of the voluntary carbon market post-2020’ (2021) 21 Climate Policy 939-957, 947 ↩︎
  47. ibid ↩︎
  48. Ahonen (n 30) 239 ↩︎
  49. ibid 240 ↩︎
  50. ibid ↩︎
  51. Kreibich (n 46) ↩︎
  52. Ahonen (n 30) 240 ↩︎
  53. International Civil Aviation Organization, ‘CORSIA emissions unit eligibility criteria’ (2021) ↩︎
  54. Ahonen (n 240) ↩︎
  55. Axel Michaelowa et al ‘Operationalizing the share of proceeds for Article 6’ (2019) Climate Finance Innovators ↩︎
  56. Ahonen (n 30) 240 ↩︎
  57. Lang (n 31) 419 ↩︎
  58. ICROA, ‘Guidance report: Pathways To Increased Voluntary Action by Non-State Actors’ (2017) ↩︎
  59. ibid ↩︎
  60. ibid ↩︎
  61. ibid 8 ↩︎
  62. ibid 12 ↩︎
  63. ICROA, ‘ICROA’s Position on Scaling Private Sector Voluntary Action Post-2020’ (2020) ↩︎
  64. Kreibich (n 46) 949 ↩︎
  65. Kreibich (n 46) 951 ↩︎
  66. Axel Michaelowa et al, ‘Additionality Revisited: Guarding the Integrity of Market Mechanisms Under the Paris Agreement’ (2019) 19 Climate Policy 1211-1224, 1213 ↩︎
  67. ibid 1214 ↩︎
  68. ibid 1215 ↩︎
  69. ibid ↩︎
  70. See generally Kollmuss (n 26) ↩︎
  71. Michaelowa (n 2) ↩︎
  72. Michaelowa (n 66) ↩︎
  73. Michaelowa (n 2) 14 ↩︎

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