ICR Grievance Process v2.0
Summary
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.
2.0
Date of Version
06. March 2026
General
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.
ICR maintains a formal grievance process to ensure that complaints and appeals concerning the ICR program are handled in a fair, transparent, timely, and impartial manner. This grievance process forms part of the ICR governance framework and is intended to safeguard environmental integrity, procedural correctness, and stakeholder confidence in the ICR program.
Grievance
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.
Complaints and appeals under this process shall be reviewed and adjudicated by the ICR Program Advisory Panel (PAP) in accordance with its procedures, ensuring independence from ICR management and operational staff involved in the original decision.
Scope
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 grievance process applies to decisions or actions taken under the ICR program, including but not limited to validation and verification outcomes, issuance or non-issuance of carbon credits, compliance with ICR standards and methodologies, and determinations made under this grievance process.
The grievance process does not apply to private commercial disputes, contractual disagreements between parties, or matters already subject to binding judicial or arbitral proceedings.
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.
Definitions
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.
Appellant means a complainant who submits an appeal against a determination issued under this grievance process.
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;
Fall outside the scope of the ICR grievance process as defined in Section 3;
Constitute private commercial disputes between parties;
Are manifestly unfounded, abusive, repetitive, or submitted in bad faith.
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.
Admissibility Review
Upon receipt of a complaint, ICR management shall conduct an admissibility review to determine whether the complaint:
Falls within the scope of the ICR grievance process;
Contains sufficient information to allow meaningful review;
Has been submitted in good faith;
Is not subject to parallel judicial or arbitral proceedings concerning the same matter.
ICR may request additional information or documentation from the complainant to determine admissibility.
ICR shall notify the complainant in writing whether the complaint has been deemed admissible.
If a complaint is deemed inadmissible, ICR shall provide a brief written explanation.
Referral to the Program Advisory Panel (PAP)
If deemed admissible, the complaint shall be referred to the Program Advisory Panel (PAP) for independent review and determination.
ICR management and staff involved in the original decision shall not participate in the PAP’s deliberation of the complaint.
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.
All complaints, admissibility determinations, and final decisions shall be documented and retained as part of the official ICR program record.
Complaint Review by the Program Advisory Panel (PAP)
Upon referral of an admissible complaint under Section 5, the Program Advisory Panel (PAP) shall conduct an independent and impartial review of the complaint.
Scope of Review
The PAP shall assess whether:
The relevant ICR requirements, methodologies, and procedures were correctly applied;
The decision under review was consistent with the ICR Requirement Document and other applicable program rules;
The principles of the ICR program (including relevance, completeness, consistency, accuracy, transparency, conservativeness, and impartiality) were upheld;
There has been a material procedural error or technical inconsistency affecting the outcome.
Review Process
In conducting its review, the PAP may:
Review all documentation related to the complaint, including project documentation, validation and verification reports, methodology documentation, and prior correspondence;
Request additional written submissions from the complainant, affected parties, ICR management, or the relevant validation and verification body (VVB);
Seek advisory input from independent sectoral or technical experts, where appropriate;
Conduct written proceedings or, where necessary, a virtual hearing.
Members of the PAP participating in the complaint review shall declare any actual, potential, or perceived conflicts of interest and recuse themselves where appropriate. Such recusals shall be documented in the meeting record.
ICR management and staff involved in the original decision shall not participate in the PAP’s deliberations.
Complaint Determination
Following its review, the PAP shall issue a written determination, including the rationale for its conclusions and any corrective measures or recommendations, where applicable.
The PAP may:
Confirm the original decision;
Recommend corrective action or procedural remedy;
Recommend reconsideration of the matter under specified conditions;
Determine that the complaint is unfounded.
The written determination shall be communicated to the complainant and relevant parties and retained as part of the official ICR program record.
Timeline
Reception
ICR receives the complaint;
Within 20 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;
ICR shall conduct an admissibility review within 30 business days of receipt.
Complaint Review by the PAP
If deemed admissible, the complaint shall be referred to the PAP;
The PAP shall make every reasonable effort to issue a written complaint determination within 60 business days from confirmation of admissibility;
Where exceptional circumstances arise (e.g., complexity, need for expert input), the complainant shall be informed of any justified extension.
Figure 1: Grievance process - complaints
Appeals
If a complaint is not resolved to the complainant's satisfaction, they can initiate an appeal process, thereby becoming an “appellant” through the following steps:
Submission of Appeal
The appellant must submit a written appeal to ICR within 30 business days of receiving the complaint determination, including:
Appellant’s name;
Updated contact information;
Reference to the initial complaint;
Grounds for the appeal, highlighting any new evidence or information not previously submitted with the original complaint;
Identification of any alleged procedural error, misinterpretation of ICR requirements, material oversight, or new evidence.
The appeal shall 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.
Admissibility of Appeal
ICR shall conduct an admissibility review to confirm that the appeal:
Has been submitted within the required timeframe;
Falls within the scope of this grievance process;
Clearly identifies grounds for reconsideration.
If deemed admissible, the appeal shall be referred to the PAP for adjudication in its appellate capacity.
Appeal Review by the PAP
Appeals shall be reviewed by a different composition of the PAP than those members who participated in the original complaint determination. Members involved in the initial review shall not participate in the appeal adjudication.
The PAP, acting in appellate capacity, may:
Review the full complaint record;
Consider new evidence or arguments submitted;
Request additional information from relevant parties;
Seek technical input where necessary.
The appeal review shall focus on whether:
There was a material procedural error;
There was a misinterpretation or misapplication of ICR requirements;
The original determination failed to consider relevant evidence;
The outcome was inconsistent with the principles of the ICR program.
Appeal Decision
The PAP shall issue a written appeal decision, including a clear rationale.
The appeal decision may:
Uphold the original determination;
Modify the determination;
Overturn the determination and recommend corrective action.
The appeal decision shall be final and binding within the ICR governance framework.
The ICR Board shall not reassess the technical merits of the appeal decision but may review whether the grievance and appeal procedures were conducted in accordance with established ICR rules in cases of alleged procedural irregularity.
If the complainant has not appealed within 30 business days from receipt of ICR’s decision, ICR considers the issue resolved.
Appeals Timeline
An appeal must be submitted within 30 business days of receipt of the complaint determination;
ICR shall conduct an admissibility review of the appeal within 15 business days;
If deemed admissible, the PAP (in separate composition) shall issue a written appeal decision within 60 business days of admissibility confirmation;
The total duration of the appeal process shall not normally exceed 90 business days unless exceptional circumstances justify extension.
Figure 2: Grievance process - Appeals
Confidentiality
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.
The PAP and any external experts engaged in the grievance or appeal process shall be bound by confidentiality obligations consistent with the ICR confidentiality and impartiality policy.
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.
ICR may publish summaries of complaint or appeal determinations in anonymized form to promote transparency and program integrity.
Impartiality and Independence
ICR shall ensure that the grievance and appeal processes are conducted independently and free
from undue influence. Persons involved in the original decision under complaint shall not participate in the complaint review or appeal adjudication.
Members of the PAP shall declare any actual, potential, or perceived conflicts of interest prior to participating in complaint or appeal deliberations.
Where a conflict of interest exists, the member shall recuse themselves from the proceedings, and such recusal shall be documented in the official record.
Appeals shall be reviewed by a different composition of the PAP than those who participated in the original complaint determination.
ICR management and operational staff shall not participate in the deliberations or decision-making of the PAP regarding complaints or appeals.
Reporting and Recordkeeping
ICR shall maintain a formal record of all complaints and appeals, including admissibility determinations, recusals, written decisions, and any corrective actions taken.
The PAP shall provide an annual summary report to the ICR Board outlining:
The number of complaints received;
The number of complaints deemed admissible;
The number of appeals submitted;
General categories of issues raised;
Any systemic procedural or technical issues identified.
The ICR Board shall review the annual summary for governance oversight purposes but shall not reassess individual technical determinations.
Appendix – Document History
Version
Date
Comment
1.0
20.2.2022
First version.
2.0
6.3.2026
Updated grievance and appeal procedures. Clarified roles and responsibilities, including review by the Program Advisory Panel (PAP), instead of appeals committee.
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