๐Ÿ”„ICR Grievance process


The ICR is committed to the timely and effective resolution of grievances (i.e., complaints and appeals) concerning the ICR program. This ICR grievance process outlines the procedures for handling complaints and appeals to the ICR by stakeholders.

Version no.


Date of Version

8. February 2024


The International Carbon Registry (ICR) is a GHG program and a comprehensive platform that adheres to the principles of the Paris Agreement and ISO 14064 series of standards, providing a robust framework for managing and validating climate projects globally. ICR offers a user-friendly registry system for project proponents to manage the entire lifecycle of climate projects, including tracking carbon credit inventories, facilitating market reach, and managing carbon credit portfolios by organizations.


The ICR is committed to the timely and effective resolution of grievances (i.e., complaints and appeals) concerning the ICR program. This ICR grievance process outlines the procedures for handling complaints and appeals to the ICR by stakeholders.


The ICR grievance process applies to complaints and appeals. If the person submitting a complaint to ICR is already a party to an agreement with ICR. That agreement specifies a dispute resolution procedure. Then, the complainant shall follow that procedure. Disputes arising from an ICR agreement lie outside the scope of the ICR grievance process. Without limiting the preceding, any dispute between a project proponent, project developer, validation and verification body, or other entities shall be resolved according to relevant clauses of current agreements between the parties.

Where the complainant submits a complaint related to an agreement with a third party that it is complaining about, the complainant must first seek to resolve the complaint following the terms of that agreement and obtain an enforceable court judgment or arbitral award. ICR will not act as an intermediary concerning commercial disputes between parties.

ICR exclusively holds the authority to decide if a Complainant is qualified to submit a Complaint. ICR will examine the information provided by the complainant to aid in its decision-making process and, at its own discretion, may request additional information from the complainant.

The ICR grievance process is not intended to substitute, circumvent, or override the legal rights of any party within its local jurisdiction to use judicial mechanisms where available and appropriate.


In addition to the definitions provided in ICR definitions, the following definitions apply.

Appeal means an objection to a decision made by ICR in response to a complaint submitted by the complainant.

Complaint means expressing dissatisfaction with a decision or operation of the ICR, including concerns over the ICR program's management. It covers situations where the program's rules result in unfair, accidental, or unintended negative impacts, as well as any disagreements or grievances that arise during the planning and execution of project activities.

Complainant means national authorities, local stakeholders, project proponents or developers, authorized representatives, registry users, validation and verification bodies, or unrelated parties.

Complaint process

Complainants are required to provide ICR with essential details when submitting a complaint.

  • The complainant's complete name (unless submitting anonymously);

  • The full name(s) of any relevant organization(s);

  • Contact details of the complainant, including phone number and email address;

  • A comprehensive explanation of the complaint, outlining the main concerns and who the complaints are related;

  • The project's ID, if available.

Anonymous submissions are allowed. However, anonymity could limit its capacity to fully resolve the complaint's issues as it might need further clarification from the complainant. If ICR determines anonymity is baseless, particularly if it's employed for submitting unfounded complaints lacking in merit for ICR's involvement, such anonymous complaints may be dismissed.

Complaints lacking sufficient detail for ICR to assess and address the issues presented effectively may hinder ICR's ability to assist. ICR maintains the authority to dismiss Complaints that:

  • Fail to provide adequate evidence supporting the claims or do not demonstrate a valid reason for action;

  • Omit any of the required information listed above;

  • At ICR's sole discretion, they are deemed inappropriate or unmanageable through its complaints handling process.

ICR might request additional information or documents from the complainant. If so, this will be requested within a specific timeframe. ICR will keep the complainant informed about the progress of their case as deemed suitable.

By submitting a complaint, the complainant automatically consents to all terms outlined. Additionally, the complainant acknowledges that failing to adhere to the specified procedure for filing the complaint could lead to its dismissal by ICR.

ICR systematically records and monitors all lodged complaints. Upon submission, the complainant will be sent an email that confirms the complaint's receipt. The complainant will be kept informed about the progress of the complaint at every step of the process.

Once the complaint process is concluded, the complainant will be invited to share feedback on their experience with ICRโ€™s complaint handling process. ICR keeps records of all complaints to evaluate and enhance the customer experience.



  • ICR receives the complaint.

  • Within 30 business days of receiving it, ICR will send an email to the complainant to acknowledge the complaint's receipt. This email will include the complaint's the contact information of the ICR personnel and, if applicable, other outsourced experts who will oversee the complaint's resolution process.

  • For complaints related to legal disputes, ICR may indicate the complaint on the applicable project's page on the registry website.


  • An ICR personnel will review the complaint.

  • ICR may inform any parties known to be affected by the complaint as deemed necessary. ICR will protect the confidentiality of any complainants wishing to remain anonymous and will not share their identity with external parties.

  • ICR may request input from the affected parties.

  • ICR commits to making every reasonable effort to formulate a preliminary response to the complaint within 60 business days from the date of its receipt.

  • ICR may share a preliminary response with the complainant and any impacted parties to gather their input.


  • ICR will consider any feedback received (if any) and finalize its response.

  • After determining the most suitable resolution to the complaint at its discretion, ICR will deliver the final written response to the complainant.

  • ICR aims to issue a final written reply to the complaint within 90 business days of receiving it.

  • The final response may be posted on the ICR website or, for complaints concerning legal disputes, on the specific project's page on the ICR registry website. To safeguard the anonymity of complainants, ICR may choose not to publish responses to anonymous complaints.


If a complaint is not resolved to the complainant's satisfaction, they can initiate an appeal process, thereby becoming an โ€œappellantโ€ through the following steps:

  1. The appellant must submit a written appeal to ICR, including:

  2. appellantโ€™s name,

  3. updated contact information,

  4. the grounds for the appeal, highlighting any new evidence or information not previously submitted with the original complaint, and

  5. the reference to the initial complaint.

  6. The appeal should be sent to ICR with "Appeal" clearly indicated in the email's subject line. ICR will confirm the receipt of the appeal within 30 days.

  7. The appeals committee will examine the appeal, comprising at least two ICR personnel and potentially including external advisors at ICR's discretion within 60 business days from receipt.

  8. ICR will issue a written decision to the appellant, which will stand as the definitive, conclusive decision on the issue raised, with no option for further appeal or complaint. ICR commits to delivering this final written response within three months of the appeal's submission.

If the complainant has not appealed within 30 business days from receipt of ICRโ€™s decision, ICR considers the issue resolved.


ICR will maintain the confidentiality of all information the complainant provides regarding the complaint and any subsequent appeal, should the complainant or appellant specifically request confidentiality. However, this confidentiality does not extend to information provided by the complainant or appellant that:

  • Is already lawfully available in the public domain;

  • shall be disclosed under any applicable law, according to the rules of the ICR program, or any other terms and conditions applicable to the ICR program;

  • needs to be shared with an ICR advisor to facilitate the assessment of a complaint or appeal under this process, on the condition that such sharing is critical for the assessment and the advisor agrees to confidentiality obligations.

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