> For the complete documentation index, see [llms.txt](https://documentation.carbonregistry.com/documentation/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://documentation.carbonregistry.com/documentation/icr-program/validation-and-verification/criteria/icr-validation-and-verification-specifications-v2.0.md). # ICR Validation and Verification Specifications v2.0 ![](https://2441265052-files.gitbook.io/~/files/v0/b/gitbook-x-prod.appspot.com/o/spaces%2FfIdoGcZZdvap67xjb5h1%2Fuploads%2FGw982sq0pK7Dkr9I6pUb%2F0.png?alt=media) ***Summary*** ICR serves as a framework for *climate projects* of any size, promoting environmental integrity through accelerating credible action and ensuring credibility, consistency, and transparency in quantification, *monitoring*, reporting, *validation*, and *verification* | Version no. | 2.0 | | --------------- | ---------------- | | Date of Version | 15. October 2024 | {% file src="/files/BTMCfupvoU4XF8hcFP6Z" %} ### Introduction The *ICR program* establishes a normalized *criteria* and framework for independent third-party accredited *validation* of projects and methodologies, along with *verification* of *GHG emission mitigations*. The program adopts the principles from and aligns with *ISO 14064-2* and *ISO 14064-3*. The mandatory requirements for conformity with the *ICR program* are detailed in the following documents: * ICR requirement document * ICR methodology requirements * ICR definitions Procedural requirements are detailed in the following documents: * ICR process requirements * ICR methodology approval process The ICR documentation is available on ICRs website, and isare regularly updated to reflect program updates. Note that new requirements take effect immediately upon issuance, however projects that have started *validation/verification* may continue without adapting the revised criteria. In some cases, a grace period may also be granted to allow proponents ample time to adapt to the changes. *VVBs* should refer directly to the ICR website for comprehensive information regarding program updates. Additionally, specific information for *VVBs* may be provided directly through the *ICR registry* platform. ### 0.1 Validation and Verification Independent third-party *validation* and *verification* play a crucial role in upholding the integrity and quality of greenhouse gas (GHG) emission mitigation achieved by projects registered with the *ICR program*. *Validation/verification* bodies (*VVBs*) have three key roles within the *ICR program*: *GHG project* validation, *GHG emission mitigations* *verification*, and assessment of methodologies under the ICR methodology approval process. To be eligible for providing *validation* and *verification* services under the *ICR program*, *VVBs* must be accredited under an ICR-*approved GHG program* and/or hold *accreditation* under *ISO 14065* by an *accreditation body* that is a member of the *International Accreditation Forum (IAF)*. Temporary approval may be granted to *VVBs* that provide documentation of being in the *accreditation* process. The specific *accreditation* requirements for *VVBs* are detailed in the ICR requirement document. The ICR validation and *verification* specifications aim to enhance the consistency, quality, and transparency of project *validation* and *verification* within the *ICR program*, as well as provide guidance on assessing methodologies under the ICR methodology approval process. These specifications should be used in conjunction with other *ICR program* documents that outline the program's framework, as well as *ISO 14064-3*, which establishes program-neutral specification for *validation* and *verification* of *GHG* related activities. ### 0.2 Purpose The specifications serve to provide further clarification on ICR requirements and, in some instances, clarifications on the application of *ISO 14064-3* on *validation* and *verification* as they relate to the *ICR program*. The specifications do not discuss *ISO 14065* or other VVB *accreditation*-specific topics such as IAF MD6, IAF ID12, nor do they offer methodology-specific or *sectoral scope*-specific guidance which *VVBs* should consider for their engagement and assessment activities. While *VVBs* are the primary i*ntended users* of these specifications, the guidance presented may also be useful for project proponents and *methodology developers*. The *VVB* shall follow the *validation* and *verification* *requirements* from *ISO 14065* and *ISO 17029* towards requirements for the competence, consistent operation and *impartiality* of bodies performing *validation/verification* as *conformity assessment activities.* For *validation* and *verification* activities the *VVB* shall follow *ISO 14064-3* and IAF MD 6 for requirements and guidelines. Additional to the *ISO 14064-3* and IAF MD 6 the *VVB* shall follow the guidance provided in this document. The structure of the document is aligned with the structure of *ISO 14064-3*. Some sections are intentionally without content for consistency with *ISO 14064-3*. ### 1. Scope This document specifies principles and requirements and provides guidance for verifying and validating greenhouse gas (GHG) statements. It is applicable to project *GHG statements* relating to quantification, *monitoring* and reporting of activities intended to cause greenhouse gas (GHG) emission mitigations intending to register the project with the International Carbon Registry (ICR) and *issue* international carbon credits (*ICCs*) or for *methodology* *validation* according to ICR methodology approval process. *ISO 14064-3* is indispensable for applying this document. ### 2. Normative References ICR Requirement Document ICR Methodology Requirements ICR Definitions ICR Process Requirements ICR Methodology Approval Process ISO 14064-2, Greenhouse gases — Part 2: Specification with guidance at the project level for quantification, monitoring and reporting of greenhouse gas emission reductions or removal enhancements. ISO 14064-3, Greenhouse gases — Part 3: Specification with guidance for the verification and validation of greenhouse gas statements ISO 14065, General principles and requirements for bodies validating and verifying environmental information ISO 14066, Greenhouse gases — Competence requirements for greenhouse gas validation teams and verification teams ### 3. Definitions For the purposes of this document, the terms and definitions given in the ICR definitions apply in addition definitions and acronyms from *ISO 14064-2*, *ISO 14064-3*, *ISO 17029* and *ISO 14065* apply. If there exists inconsistency in definitions, ICR definitions prevail. ### 4. Principles To support *VVBs* in comprehending the overall objectives of the *ICR program* and *ISO 14064-2* requirements, overarching principles serve as valuable guidance for *validation* and *verification*. These principles offer direction for *VVBs* in circumstances where project- or methodology-specific requirements lack complete specificity. While the *ISO 14064-2* and *ISO 14064-3* principles are not auditable criteria, they play a significant role in *GHG projects* and acts as a guiding light for *validation* and *verification* assessment. These principles provide a framework and set of guidelines that help ensure the accuracy, consistency, and reliability of GHG-related information and help maintaining the integrity and quality of the *GHG projects* and *GHG emission mitigations* claimed. *VVBs* shall consider the principles during project *validation*, *verification*, and *methodology* assessments and exercise professional judgement for the purpose evaluating how the assessment harmonizes with the principles. |

ISO 14064-2 principles\[1]

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ISO 14064-3 principles\[2]

| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ### 5. Requirements Applicable to Verification/Validation ### 5.1 Pre-Engagement Activities When a *VVB* is engaged to carry out a *validation* or *verification*, both the *VVB* and the client need to reach a mutual understanding regarding the objectives, scope, criteria, *level of assurance*, and *materiality* of the assessment as outlined in section 5.1.1 in *ISO 14064-3*. These five elements serve as the foundation for developing *validation* and/or *verification* plans, associated evidence gathering and sampling plans. The *VVB* shall consider acknowledgement that ICR and interested parties to the ICR are the primary *intended users* of project design descriptions, *monitoring reports*, produced by the proponent and *validation* and *verification report*s produced by the VVB, where the proponents intends to *issue* *ICCs* as representing the *GHG emission mitigations* in t *CO2-e*. The *VVB* shall confirm that the project has been pre-registered with the ICR before signing a *validation* agreement with the project proponent. The *VVB* shall confirm that the project has been validated and registered with the ICR before signing a *verification* agreement with the proponent. When performing joint *validation* and *verification*, the project needs to be pre-registered. #### 5.1.1 General *Validation* and *verification* bodies (*VVBs*)are eligible to provide *validation* and *verification* services under the ICR if they have signed an agreement with ICR and are accredited under an ICR *approved GHG program* and/or accredited under *ISO 14065* by an *accreditation body* that is a member of the *IAF*. The *VVB* shall hold such *accreditation* or approval for *validation* or *verification* (as applicable) for the *sectoral scope(s)* applicable to the project. Where the project falls under more than one *sectoral scope*, the *VVB* shall hold *accreditation* or approval for *validation* or *verification* (as applicable) for all relevant *sectoral scopes.* *VVBs* who are in the process of achieving *accreditation* or expanding their *sectoral scope* of *accreditation* may conduct a *validation* or *verification* as a part of their witness audit during their *accreditation* process with a member of the IAF. Approval of *VVBs* under *accreditation* or expansion of *sectoral scopes* is granted for up to 12 months. The *VVB* and the client need to reach a mutual understanding for the *criteria* for *validation/verification* activities. For *validation* activities minimum *criteria* are: * ISO 14064-2 * ICR requirement document And for *verification*: * ISO 14064-2 * ICR requirement document * Project design description The *VVB* and the proponent may add other *criteria* for the *validation/verification*, e.g., approved *methodology*, other benefits (*SDGs*). *VVBs* are encouraged to conduct an assessment prior to undertaking project *validation* to ensure the project is eligible under the *ICR program*. New requirements take effect immediately upon issuance of revised documentation, however projects that have started *validation/verification* may continue without adapting the revised criteria. In some cases, a grace period may also be granted to allow proponents ample time to adapt to the changes. *VVBs* should refer directly to the ICR website for comprehensive information regarding program updates. Additionally, specific information for *VVBs* may be provided directly through the *ICR registry* platform. #### 5.1.2 Type of Engagement The *VVB* may engage in *validation* or *verification* activities. When reporting on *validation* and *verification* activities *VVBs* shall use *validation* and *verification report* templates provided by ICR respectively. The *VVB* may perform a joint (mixed engagement) *verification* and *validation* activities performed at the same time. When performing joint *validation* and *verification* the *VVB* shall use the ICR validation and *verification report*. #### 5.1.3 Level of Assurance The concept of *materiality* is applicable to the *verification* of all types of projects registered with ICR. It is however not applicable to uncertainties related to measurement, or temporary deviations and permanent changes to the registered *monitoring* plan or applied methodologies. **5.1.3.1 Verification** The *ICR program* requires a reasonable *level of assurance* in *verification* that *GHG* assertions are free of *material* errors, omissions, and misstatements. An omission, misstatement, or erroneous reporting of information is *material* if it might lead, at an aggregated level, to an overestimation of the total *GHG emission mitigations* achieved by a registered *project activity* equal to or higher than the *materiality* threshold. The *VVB* shall plan and perform *verification* with an attitude of professional scepticism and rely on professional judgement when applying the concept of *materiality*. A reasonable *level of assurance* imply that some data or information may not be checked. However, the *VVB* should design its *verification* and sampling plans to detect all *material* errors, omissions or misstatements, and any unchecked data or information should not contain any *material* errors, omissions or misstatements. For a reasonable *level of assurance* engagement, the *VVB* must test a sufficient amount of data to ensure with confidence that no *material* errors are present. The amount of testing to be conducted is determined based on the outcome of a risk assessment. **5.1.3.2 Validation** For *validation* the *ICR program* requires *limited assurance* on the process for formulating the projection on projected *GHG emission mitigations*. All *validation* opinions shall clearly state that assurance is provided only on the reasonable basis for the assumptions, limitations and methods used to project or forecast information, and not on the content of the projections or forecasts. All *validation* opinions shall include a warning that actual impacts may be different from the *GHG emission mitigations* projection when verified since anticipated events may not occur as expected and the variation may be material. #### 5.1.4 Objectives The initial step in the *validation* and *verification* involves defining objectives and identifying the greenhouse gas (GHG) assertions that will be evaluated during the *validation* or *verification* process. The primary goal of project *validation* or *verification* is to assess these assertions in accordance with the requirements of the *ICR Program*, *ISO 14064-2* and where applicable, the applied *methodology* or other identified criteria. The specific objectives may differ depending on whether it is a *validation* or *verification* engagement. Additionally, the scope, criteria, *level of assurance*, and *materiality* of the *validation* and *verification* assessment should be considered when establishing the objectives. **5.1.4.1 Verification Objectives** *Verification* takes place after the project has started its implemented and produces *GHG emission mitigation*. It involves an *ex-post* assessment of the monitored *GHG* data relevant information to the project operation, implementation, and monitoring. During the *verification* process, *VVBs* are responsible for assessing the *monitoring report* and associated date. Considering the following: * Continued conformity to *ISO 14064-2* * Continued conformity of the project to the ICR requirements. * The degree to which the methods and procedures, including *monitoring* procedures, have been implemented as outlined in the validated project design description and *monitoring* plan. * The accuracy of the reported *GHG emission mitigations* in the *monitoring report*, with emphasis on their *materiality*. **5.1.4.2 Validation Objectives** *Validation* requires *VVBs* to evaluate the project description based on the following criteria: * Conformity of the project to the *ISO 14064-2* * Conformity of the project to the ICR requirements. * Conformity of the project to the applied *methodology*, where applicable. * Reasonableness that methods and procedures described in the project will achieve claimed *GHG emission mitigations*. #### 5.1.5 Criteria The *criteria* specify the standards or benchmarks against which the project shall be assessed during *validation* or *verification*. These *criteria* serve as the basis for determining compliance, performance, or other relevant aspects. The project proponent may request the *VVB* to add *criteria* for *validation* and *verification*. The *VVB* shall evaluate the requested *criteria* for it to be auditable and further the *criteria* needs to be publicly available. While it is not necessary for *VVBs* to document every criterion applicable to the *validation* or *verification* engagement, they should indicate the relevant documents that contain the criteria, such as the ICR requirement document, *ISO 14064-2*, where applicable the applied *methodology* or other applied criteria. Further details about key *validation* and *verification* *criteria* are discussed in Section 5.1.5. **5.1.5.1 Validation** The *criteria* against which the *validation* or *verification* is conducted are guided by the requirements of the *ICR program* and *ISO 14064-2*. When applying a *methodology* to demonstrate conformity to the criteria, the *methodology* may be added to the criteria. When a *methodology* is applied the *VVB* needs to have a comprehensive understanding of the *methodology* before conducting the assessment. If the project applies methodologies from other *approved GHG program*s *VVBs* should refer to the guidance provided by those programs regarding the application of the *methodology*. Note that projects may rely on methodologies to demonstrate conformity to the *ICR program* requirements. When projects apply methodologies partially, the *VVB* shall evaluate how it affects the overall performance of the project and assess impacts of any deviations from the *methodology* on the performance. When projects do not apply an established *methodology* the *VVB* needs to have comprehensive knowledge and understanding about the sectors the *project activities* fall under and shall conduct an extensive assessment of how the project conforms to the *criteria* and the overarching principles of *ISO 14064-2* and the ICR requirement document. When project do not apply an approved *methodology* the *validation* shall include assessment of the justification for “selection or establishment of the *criteria* and procedures” relating to clauses 6.3, 6.4, 6.5, 6.6, 6.7, 6.8 and 6.10 of *ISO 14064-2*. **5.1.5.2 Verification** For *verification* the *criteria* are the same in addition to the project design description. #### 5.1.6 Scope When determining the scope of the assessment, *VVBs* need to consider the physical boundaries, project sites or facilities, and the temporal boundaries which indicate the specific years during which *GHG emission mitigations* are quantified. For validation, the temporal boundaries are determined based on the ICR project *crediting period* requirements outlined in the ICR requirement document. For *verification*, the temporal boundaries are determined by the duration of the *monitoring* period. #### 5.1.7 Materiality Threshold *Materiality* refers to the concept that individual misstatements or the aggregation of misstatements could influence the *intended users’* decisions. Meaning that errors, omissions, or misrepresentations, whether occurring individually or collectively, can impact *GHG claims* and consequently influence the decisions made by *intended users.* The *materiality* threshold is a predefined level set to determine what is considered significant enough to influence the decision-making process. It helps identify the boundaries within which errors or discrepancies are deemed immaterial or inconsequential. The determination of *materiality* is important in validation, *verification*, and reporting processes to ensure that information provided is accurate, reliable, and relevant. Adhering to *materiality* thresholds helps maintain the integrity and credibility of *GHG projects,* *issued* instruments and their associated claims. The *materiality* threshold, which determines the level of significance that triggers action, cannot be negotiated between the *project proponent* and the *VVB*. It is crucial to adhere to the *materiality* thresholds as it informs the determination of the threshold. The *VVB* planning and conducting *verification* shall achieve a reasonable *level of assurance* that the reported *GHG emission mitigations* are free from *material* errors, omissions or misstatements. An omission, misstatement, or erroneous reporting of information is *material* if it might lead, at an aggregated level, to an overestimation of the total *GHG emission mitigations* achieved by a registered *project activity* equal to or higher than the following thresholds: 1. 2 per cent of the *GHG emission mitigations* for *project activities* achieving a total *GHG emission mitigations* equal to or more than 250,000 t *CO2-e*/yr. 2. 5 per cent of the *GHG emission mitigations* for *project activities* achieving a total *GHG emission mitigations* equal to or less than 250,000 t *CO2-e*/yr. 3. For projects activities achieving a total *GHG emission mitigations* equal to or less than 10,000 t *CO2-e*/yr, 10 per cent is allowed. **5.1.7.1 Materiality Considerations** *Materiality* encompasses both qualitative and quantitative aspects. When evaluating qualitative *materiality*, *VVBs* are responsible for determining whether a project conforms to the ICR requirements and when applicable *methodology* requirements. Certain qualitative discrepancies, such as those related to ownership or applicability criteria, must always be acknowledged as significant non-conformities. In other instances, qualitative discrepancies may be less definitive and could potentially manifest as quantitative discrepancies. When encountering such less definite qualitative discrepancies, *VVBs* should exercise professional judgement to identify immediate *material* issues and determine which ones require further investigation through sampling and testing. Regarding quantitative *materiality*, *VVBs* assess the significance of data errors, omissions, or misrepresentations in relation to the cumulative estimate of *GHG emission reductions* and removals presented in the project description or *monitoring report*. It is important to note that uncertainties inherent in applied *methodology* or identified in the project’s documentation should not be factored into the *materiality* assessment. While all *material* errors, omissions, and misrepresentations shall be addressed for a project to receive an unmodified *validation* or *verification* *opinion*, non-*material* errors found in the project documents should still be addressed by the *project proponent* to the extent feasible, as per the findings provided by the *VVBs*. ### 5.2 Verification/Validation Team Selection The *VVB* shall disclose how competence of the *validation/verification team* has been determined in the *validation/verification report.* The *verification team* members shall not be involved in more than five consecutive *verification*s or up to five years *monitoring* whichever comes first. During the *validation*/*verification* assessment, the *validation/verification team* shall be added as project members in the *registry* platform. ### 5.3 Verification/Validation Activities and Techniques The *VVB* shall disclose activities and techniques performed in the *validation*/*verification* *report*. ### 5.4 Specific Requirements ### 5.4.1 Verifier/Validator Communication Within 21 days from the closing meeting the *VVB* shall communicate any clarification, *material misstatements* and nonconformities raised during the assessment. The time for the project to respond to the communication may range from 1-8 weeks, based on the expert judgement by the *VVB* and extensivity of the response required. Non-*material misstatement*s shall be communicated to the project within 4 weeks from the closing meeting. When the *VVB* findings are adverse, ICR shall be informed. ### 5.4.2 Sufficiency of Evidence When the *VVB* determines that there is insufficient information to support the *GHG statement* the *VVB* shall allow the project to provide such information within 4 weeks. If the project does not provide sufficient information the *VVB* shall follow section 5.4.1. ### 5.4.3 Intentional Misstatement Where the *VVB* believes there exists intentional *misstatement* or noncompliance by the project with laws and regulations, the *VVB* shall communicate the matter to the ICR. ### 5.4.4 Documented Information The *VVB* shall share *verification*/*validation* plan with the ICR and upload to the ICR platform, not for public disclosure. When the *verification*/*validation* plan has been updated, revised version shall be shared with the ICR and uploaded to the ICR platform. ### 5.4.5 Process for Completing a Verification/Validation For further clarification on project processes and involvement of *VVBs* in the process are discussed further in the ICR process requirements. ### 6. Verification ### 6.1 Planning #### 6.1.1 Strategic Analysis **6.1.1.1 General** During the *verification* strategic analysis, the *VVB* shall document relevant outcomes from the analysis in the ICR *verification report* template appropriately. The *validation team* shall consider all information provided in the *ICR registry*, the documentation provided by the project proponent, consistency with documentation provided to the *VVB* by the project proponent, and information in the *registry* platform. The *validation team* shall consider all media provided by the proponent to the *registry* platform. All insights provided for the *validation team* shall assess if they relate to the *project activities* and represent the documentation fairly. *Validation* and *verification* of *multiple project activities* shall assess conformity of the multiple *project activity* to requirements for *multiple project activities* under section 5 of the ICR requirement document. ICR allows for grouped projects meaning expansion of *project activities* over time and over a geographically dispersed area. New *project activity* instances can be added to the project over time (ie, following initial project validation) within predefined geographic areas, provided they meet the set of eligibility *criteria* set out in the PDD. The new instances are validated at the time of *verification*. Inclusion of additional *project activities* under a grouped project shall be validated, based on the information reported in the *monitoring report*, for conformity to the eligibility criteria. For instances where a grouped project is expanded the *VVB* needs to ensure added project elements meet the *validation criteria* and the established eligibility criteria for the grouped project. **6.1.1.2 Additional Requirements for Project GHG Statement Verification** No additional guidance or requirements. **6.1.1.3 Additional Requirements for Product GHG Statement Verification** Not applicable #### 6.1.2 Risk Assessment **6.1.2.1 General** Qualitative risks identified shall be documented in the *verification report*. When the proponent request *validation* of other criteria, e.g. *SDGs*, the *VVB* shall include them in the risk assessment. They shall be documented separately. **6.1.2.2 Types of Risks** Inherent risks refer to the risks that are inherent to the operations of the *GHG project*. These risks arise from the nature of the *project activities*, the complexity of *GHG SSRs*, the accuracy of data collection and *monitoring* methods, and other relevant factors. Inherent risks highlight potential vulnerabilities in the *GHG emission mitigations* accounting process that could lead to misstatements in overall *GHG emission mitigations.* Control risks are the risks associated with the design and effectiveness of the *GHG projects* internal controls over *GHG emission mitigations* activities. Internal controls are policies, procedures, and safeguards put in place to ensure the accuracy and reliability of data collected. High control risks suggest that the internal controls might be inadequate or poorly implemented, increasing the likelihood of errors or misstatements in *GHG emission mitigations* reported. *VVBs* shall assess control risks and determine if there are weaknesses that need to be addressed to improve the accuracy and reliability of the *GHG* accounting. Detection risks are the risks that an auditor may fail to detect *material misstatements* in *GHG* data during the assurance or auditing process. It relates to the effectiveness of audit procedures and the sampling methods used by auditors to evaluate the *GHG* data. Auditors shall minimize detection risks by employing appropriate audit procedures and sampling. **6.1.2.3 Risk Assessment Considerations** When *criteria* for *validation* are, in addition to *ISO 14064-2* and ICR requirement document, an approved *methodology*, the *VVB* may rely on specifics in the *methodology*, to reduce the level of detail in the risk assessment where the *methodology* has considered some risk types, e.g., significant emission sources, *statutory requirements*, quantification methods. The *VVB* shall consider risks associated with applied methodologies align with best practices, on the basis of the best available scientific knowledge, and technical advancements. **6.1.2.4 Information Sources for Risk Assessment** No additional guidance or requirements. **6.1.2.5 Additional Requirements for Project GHG Statement Verification** No additional guidance or requirements. **6.1.2.6 Additional Requirements for Product GHG Statement Verification** Not applicable. **6.1.2.7 Uses for Risk Assessment Information** The risk assessment may be used to evaluate if remote audit may be applicable. Risk assessment may be used, where relevant, to inform ICR if the *VVB* considers the applied *methodology* not in line with alignment with best practices, on the basis of the best available scientific knowledge, and technical advancements #### 6.1.3 Evidence-Gathering Activities **6.1.3.1 General** For the evidence-gathering design the *VVB* shall consider the ICR requirements and other applied *criteria* for the *verification*. **6.1.3.2 Data Trail** No additional guidance or requirements. **6.1.3.3 GHG Information System and Controls** No additional guidance or requirements. **6.1.3.4 GHG Data and Information** No additional guidance or requirements. **6.1.3.5 Data Aggregation Process** No additional guidance or requirements. **6.1.3.6 Application of Selected Verification Activities and Techniques** **6.1.3.6.1 Analytical Testing** No additional guidance or requirements. **6.1.3.6.2 Control Testing** No additional guidance or requirements. **6.1.3.6.3 Estimate Testing** No additional guidance or requirements. **6.1.3.6.4 Sampling** In instances where it is not feasible to conduct an individual assessment of each initial or new additional multiple *project activity* due to their number, the *VVB* shall document and explain sampling techniques used for the *validation/verification* of such instances. **6.1.3.6.5 Evaluation of Ownership** *VVBs* are not responsible for giving an opinion on the legal right of *GHG emission mitigations*. However, they are required to assess project ownership and rights to *claim* *GHG emission mitigations* from the *project activities* communicated in the *GHG statement*, with a reasonable *level of assurance*. This assessment involves evaluating whether the *project proponent* can demonstrate their claim to project ownership through the evidence they provide. The evidence may include contractual rights, such as *legal title* to the relevant plant or equipment generating *GHG emission mitigations*, or binding agreements e.g. long-term leases for land management. The extent of due diligence necessary to evaluate project ownership evidence varies depending on the specific project. At a minimum, *VVBs* shall assess whether the *project proponent* has provided adequate evidence to establish the authenticity of the documentation supporting their claim of project ownership. Additionally, *VVBs* shall evaluate the regulatory and jurisdictional framework in which the project is implemented to ensure there are no apparent conflicts with the project proponent's assertions. In cases where limited knowledge or expertise exists regarding a specific geographic jurisdiction or sector, *VVBs* are encouraged to seek external expertise for a comprehensive evaluation. *VVBs* may rely on: 1. Project ownership obtained through the issuance or authorization of a competent authority as per statute, regulation, or decree. 2. Project ownership acquired in accordance with *applicable laws.* 3. Project ownership derived from a statutory, property, or contractual right over the plant, equipment, or process that generates *GHG emission mitigations* (provided the *project proponent* retains ownership). 4. Project ownership derived from a statutory, property, or contractual right over the land, vegetation, or conservation or management process that generates *GHG emission mitigations* (provided the *project proponent* retains ownership). 5. An enforceable and irrevocable agreement with the holder of the statutory, property, or contractual right over the plant, equipment, or process or over the land, vegetation, or conservation or management process that generates *GHG emission mitigations*, transferring project ownership to the project proponent. 6. Project ownership resulting from the implementation or enforcement of laws, statutes, or regulatory frameworks that mandate or incentivize activities generating *GHG emission mitigations*. The *VVB* shall confirm for each *monitoring* period that no *double counting* exists to a reasonable *level of assurance*, considering section 5.8 and 5.10 of the ICR requirement document. #### 6.1.4 Site Visits When planning and performing remote assessment the *VVB* shall consider IAF ID 12:2023 **6.1.4.1 Site and Facility Selection** No additional guidance or requirements. **6.1.4.2 Circumstances Requiring a Site or Facility Visit** Example of unexplained *material* changes in emissions, removals and storage can be *material* deviation from validated *GHG emission mitigations* from the project design or *material* changes from last *verification* assessment, reversal events or *non-performance* of the project. **6.1.4.3 Activities to Perform During Site Visits** *Monitoring* practices are derived from the *monitoring* plan from the project design. The *VVB* shall identify any activities that may be assessed by remote assessment. #### 6.1.5 Verification Plan The *VVB* shall upload the final version of the *verification* plan to the *ICR registry* platform. The *VVB* shall upload any changes made to the *verification* plan to the *ICR registry* platform during the *verification* after the *verification* has been completed. The *verification* plan is not intended to be publicly available. #### 6.1.6 Evidence-Gathering Plan The evidence-gathering plan is not required to be uploaded to the *registry* platform. #### 6.1.7 Approval of Verification and Evidence-Gathering Plans No additional guidance or requirements. ### 6.2 Execution Any identification of areas requiring further clarification and discrepancies shall be addressed. *VVBs* must clearly document the following: * **Clarification Requests (CLs)**: Project reporting lacks transparency and further information is needed to determine if a *material misstatement* or *non-conformity* is present. * **Corrective Action Requests (CARs)**: The *VVB* has identified a *material misstatement* or *non-conformity* that the *project proponent* must address. Any requests for clarification, misstatements and non-conformities shall be shared with the proponent as soon as practically possible. The *VVB* shall use the Appendix in the ICR validation and *verification report* template or the ICR *verification report* template for submission and response by the proponent. ### 6.3 Completion For *bundled* project activities the *VVB* shall state its opinion on conformity if the *bundled project activities* with the *criteria* and describe any steps taken to assess the conformity. For added project element under a grouped *project activities* the *VVB* shall state its opinion on conformity to the eligibility criteria and describe any steps taken to assess the conformity. The *VVB* shall complete the *verification* as soon as practically possible and share the result with the proponent, no later than 4 weeks after the end of the assessment. Any results shall further be shared with the ICR. #### 6.3.1 Evaluation of the GHG Statement **6.3.1.1 Evaluation of Changes** No additional guidance or requirements. The *VVB* shall consider all comments received from any public consultation, if they affect the *GHG statement* by the proponent. **6.3.1.2 Evaluation of Sufficiency and Appropriateness of Evidence** No additional guidance or requirements. **6.3.1.3 Evaluation of Material Misstatements** No additional guidance or requirements. **6.3.1.4 Evaluation of Conformity with Criteria** *Methodology* can refer to *criteria* and procedures established by the proponent in the project design for the quantification, baseline, project emissions etc. **6.3.1.5 Evaluation of Changes from Prior Periods** If a deviation has been applied the *VVB* shall assess if any deviations are *material* and affects the relevance of the established *criteria* and procedures for the quantification of *GHG emission mitigations*, the project's additionality, or the suitability of the *baseline scenario* Assessment of deviations from project design description should determine whether the deviation is appropriately described and justified, and whether the project remains in conformity with the *validation* criteria. The process, findings and conclusions of the assessment needs to be addressed in the *verification report* and the deviation shall also be reported on in all subsequent *verification report*s. #### 6.3.2 Conclusion and Draft Opinion **6.3.2.1 General** No additional guidance or requirements. **6.3.2.2 Unmodified Opinion** When the *VVB* drafts an unmodified opinion, it shall be using the standard wording provided for in the ICR *verification report* template or the ICR validation and *verification report* template. **6.3.2.3 Modified Opinion** When the *VVB* drafts a modified opinion, it shall be using the standard wording provided for in the ICR *verification report* template or the ICR validation and *verification report* template. The *VVB* shall however include to what extent the *VVB* can’t issue an unmodified opinion and disclose if it impairs the usefulness of claimed *GHG emission mitigations*. **6.3.2.4 Adverse Opinion** When the *VVB* has drafted an adverse opinion, he shall share that with the ICR as soon as practicable. **6.3.2.5 Disclaiming the Issuance of an Opinion** When the *VVB* has disclaimed the issuance of an opinion he shall share that with ICR as soon as practicable. #### 6.3.3 Verification Report The verification report shall describe the *verification* process, any findings raised during *verification*, actions to react, and the conclusions reached by the *VVB*. The *VVB* shall use the *verification report* template for the *verification report* (or *validation* and *verification report* template for joint *validation* and *verification*) and follow all instructional text contained in the template. The *verification report* shall include a *verification* statement and the opinion of the *verification*. The *verification* statement shall state the volume of *GHG emission mitigation outcomes* generated during the *monitoring* period and verified with respect to non-permanence risk and *leakage* eligible to be *issued* as *ICCs*. ### 7. Validation ### 7.1 Planning #### 7.1.1 Strategic Analysis For the strategic analysis other relevant information referred to in section 7.1.1 in *ISO 14064-3* may include other *criteria* applied for the *validation* and *stakeholder* consideration. Where relevant, the *VVB* should inform ICR if the *VVB* considers the applied *methodology* not in line with alignment with best practices, on the basis of the best available scientific knowledge, and technical advancements #### 7.1.2 Materiality Thresholds See section 5.1.7. #### 7.1.3 Estimate Testing For avoidance of doubt, estimate *methodology* can refer to *criteria* and procedures applied in relevant sections from *ISO 14064-2* and appropriateness of proponent’s establishment, justification and applied *criteria* and procedures for demonstrating that the project results in *GHG emission reductions* or *removal enhancements* that are additional to what would occur in comparison to the determined *GHG baseline*. #### 7.1.4 Assessment of GHG-Related Activity Characteristics **7.1.4.1 General** Where a *methodology* is applied the *VVB* shall consider if it aligns with best practices, on the basis of the best available scientific knowledge, and technical advancements and are scientifically proven and peer-reviewed. Where *criteria* and procedures are developed and not following an approved *methodology* the *VVB* shall consider if they align with best practices, on the basis of the best available scientific knowledge, and technical advancements and are scientifically proven and peer-reviewed. The *VVB* shall consider all comments received from any public consultation, if they affect the *GHG statement* by the proponent. The *VVB* shall further consider claimed SDG contributions and environmental and socio-economic safeguards implemented in the evidence-gathering plan. **7.1.4.2 Recognition** The *VVB* may consult with the ICR if there are any restrictions on participation of the project within the *ICR program*. The *VVB* should consider especially sections 5.3, 5.4, 5.9, 4.2.1 and 6.4.1 in the ICR requirements and the likelihood of the project meeting the stipulated requirements. **7.1.4.3 Ownership** See section 6.1.3.6.5 **7.1.4.4 GHG Boundary** *VVBs* shall assess whether the *GHG SSRs* identified for the project and those identified in the *baseline scenario* are equivalent and consistent. *VVBs* shall assess whether the project boundary includes, at minimum, all *GHG SSRs* controlled by the project proponent, related to the project and affected. **7.1.4.5 Baseline Selection** The *VVB* shall determine whether the baseline identified for the proposed *project activity* is the scenario that reasonably represents the anthropogenic emissions by *GHG SSRs* that would occur in the absence of the proposed *project activity*. When following an approved *methodology,* the *VVB* shall determine whether any procedure contained in the *methodology* to identify the most reasonable *baseline scenario* has been correctly applied. If the applied methodologies require the use of methodological tools to establish the baseline scenario, the *VVB* shall refer to the methodologies on the application of these methodological tools. In such cases, the specific guidance in the methodologies shall supersede the corresponding requirements of the methodological tools. If applied approved *methodology* requires several alternative scenarios to be considered in the identification of the most plausible baseline scenario, the *VVB* shall, based on financial expertise and local and sectoral knowledge, determine whether all scenarios that are considered by the *project proponent* and any scenarios that are supplementary to those required by the methodologies, are realistic and credible in the context of the proposed *project activity* and that no alternative scenario has been excluded. If the proponent doesn’t apply an approved *methodology* for the baseline or relies on a *methodology* the *VVB* shall consider alternative scenarios considered by the proponent when determining the most plausible and conservatively determined baseline and exercise professional judgement if the *baseline scenario* represents the most likely scenario. The *VVB* shall determine whether the most plausible *baseline scenario* identified is reasonable by validating the assumptions, calculations and rationales used in the *PDD*. It shall determine whether documents and sources referred to in the *PDD* are correctly quoted and interpreted. The *VVB* shall cross-check the information provided in the *PDD* with other verifiable and credible sources, such as local expert opinion, if available. The *VVB* shall determine, relying on its knowledge of the *sector* and/or advice from local *technical experts,* weather all applicable ICR requirements have been taken into account in the identification of the *baseline scenario* for the proposed *project activity*, as well as relevant national and/or sectoral policies, regulations, NDCs, local energy availability, energy expansion plans, and the economic situation in the project sector. When not applying or relying on a *methodology*, or where the *baseline scenario* is not prescribed in the applied methodologies, the *VVB* shall assess the list of identified credible alternatives to the proposed *project activity* in the *PDD* selected to determine the most realistic baseline scenario. The *VVB* shall assess the alternative baseline scenarios in the *PDD* and determine whether the alternatives include as one of the options that the *project activity* is undertaken without being registered as a proposed *project activity*, the alternatives are plausible that the *VVB* considers to be viable means of supplying the comparable outputs or services that are to be supplied by the proposed *project activity*, relying the basis of its local and sectoral knowledge and the alternatives comply with all applicable and enforced legislation. The *VVB* shall further determine if the alternative baseline scenarios are credible and complete. For *bundled* project activities of the same type, demonstration of the *baseline scenario* and *additionality* may be combined. A *bundled project* with *multiple project activities* refers to the implementation of different types of *project activities* and can entail application of a combination of methodologies or *criteria* and procedures for quantification of *GHG emission mitigations*. The *VVBs* needs to perform the assessment of baseline and *additionality* separately for each *project activity*. Where the *baseline scenario* is prescribed in applied methodologies, no further analysis is required. **7.1.4.5.1 Additionality** The *VVB* shall determine whether the proposed *project activity* is additional as demonstrated in the *PDD*. The *VVB* shall assess and verify the reliability and credibility of all data, rationales, assumptions, justifications and documentation provided by the *project proponent* to support the demonstration of additionality. This requires the *VVB* to critically assess the evidence presented, using local knowledge, sectoral and financial expertise. Where applicable, the *VVB* shall consider methodological tools and guidelines to demonstrate the *additionality* of proposed *project activities*. The *VVB* shall also consider specific complementary or alternative requirements included in the applied methodologies for demonstrating the *additionality* of the proposed *project activity*. *VVB* needs to assess if projects meet the relevant level of additionality, i.e. project shall demonstrate they meet the applied level of additionality. PD/PPs and the *VVB* may rely on arguments from positive lists or similar automatic *additionality* tools but shall make an independent assessment. **Level 1** The *VVB* shall determine whether the description of how to undertake the *ex-ante* and *ex-post* calculations of baseline, project and *leakage GHG emissions* as well as *GHG emission mitigations* to be achieved by the proposed *project activity* is in accordance with the applied methodologies or *criteria* and procedures prescribed in the *PDD*. The *VVB* shall determine whether the correct equations and parameters have been used, in accordance with the applied methodologies or with prescribed *criteria* and procedures in the *PDD*. The *VVB* shall verify the justification given in the *PDD* for the choice of data and parameters used in the equations: 1. Data and parameters remaining constant: If data and parameters are not monitored throughout the *crediting period* of the proposed *project activity*, but are already determined and will remain fixed throughout the *crediting period*, the *VVB* shall determine whether all data sources and assumptions are appropriate and calculations are correct as applicable to the proposed *project activity*, and will result in an accurate or otherwise conservative estimate of the *GHG emission mitigations*. 2. Monitored data and parameters: If data and parameters will be monitored or estimated during implementation and become available after *validation* of the proposed *project activity*, the *VVB* shall determine whether the estimates provided for in the *PDD* are reasonable. **Level 2** The *VVB* shall, relying on local and sectoral knowledge, determine whether the proposed *project activity* is. 1. not required by *statutory requirements*, Level 2a; 2. required by *statutory requirements* but the *VVB* has determined that they are systematically not enforced and non-compliance with those requirements is widespread in the *host country*, Level 2b. **Level 3** The *VVB* shall confirm whether the proposed *project activity* is not *common practice* relying on official sources and local and sectoral expertise to: 1. Assess whether the geographical region of the *common practice* analysis is appropriate for the assessment of *common practice* related to the *project activity*’s technology or industry type. 2. Determine to what extent similar and operational projects (e.g. using a similar technology or practice), other than the *project activities*, have been undertaken in the defined region; 3. Assess, if similar and operational projects, other than the *project activities*, are already widely observed and commonly carried out in the defined region, whether there are essential distinctions between the proposed CDM *project activity* and other similar activities. For the barriers analysis, the types of barriers that may be assessed are: * **Investment Barriers:** Similar activities have only been implemented with grants or other non-commercial financing terms. Similar activities are defined as activities that rely on a broadly similar technology or practices, are of a similar scale, take place in a comparable environment with respect to regulatory framework. No capital is available from domestic or international capital markets due to real or perceived risks associated with investments in the country where the *project activity* is to be implemented, e.g. by the credit rating of the country or other country investment reports of reputed origin. * **Technological Barriers**: Skilled and/or properly trained labor to operate and maintain the technology is not available in the applicable geographical area, which leads to an unacceptably high risk of equipment disrepair, malfunctioning or another underperformance. Lack of infrastructure for implementation and logistics for maintenance of the technology. The process/technology failure risk in the local circumstances is significantly greater than for other technologies that provide services or outputs comparable The particular technology used in the proposed *project activity* is not available in the applicable geographical area. * **Institutional Barriers**: Institutional barriers include other barriers not reflected above such as organizational, cultural, social, or educational barriers. **Level 4** When investment analysis is used to demonstrate the level 4 *additionality* of the proposed *project activity*, the *VVB* shall determine whether the proposed *project activity* would not be: 1. The most economically or financially attractive alternative; or 2. Economically or financially feasible without the revenue from the sale of *ICCs*. The *VVB* shall apply the most recent version of the CDM Methodological tool: Investment analysis, Tool27\[3]. The *VVB* shall determine whether the proposed *project activity* is not the most economically or financially attractive alternative, or that it is not economically or financially feasible without the revenues from sale of *ICCs*. 1. The proposed *project activity* would produce no financial or economic benefits other than *GHG emission mitigations* related income, e.g. negative IRR. The *VVB* shall determine whether the documented costs associated with the proposed *VVB* *project activity* and the alternatives identified demonstrate that there is at least one alternative which is less costly than the proposed *project activity*, Level 4b; 2. The proposed *project activity* is less economically or financially attractive than at least one other credible and realistic alternative, Level 4a; 3. The financial returns of the proposed *project activity* would be insufficient to justify the required investment, Level 4a. **Level 5** The *VVB* shall determine whether the proposed *project activity* and resulting *GHG emission mitigations* are not included in the host-country national *GHG* inventory or that the *project proponent* has attained a letter of confirmation for corresponding adjustment subject to section B of Annex II of COP26 decision -/CMA.3 on Article 6.2. **7.1.4.6 Activity Measurement** For avoidance of doubt, *GHG* quantification *methodology* can refer to *criteria* and procedures applied in sections 6.7 and 6.8 from *ISO 14064-2*. **Non-Permanence** The non-permanence risk shall be assessed for projects with *GHG emission* *SSRs* that may be reversed. *GHG project activities* are not subject to risk assessment if they do not store carbon in biomass or carbon pools. Where applicable the *VVB* shall confirm whether the *project proponent* has addressed non-permanence and specified in the *PDD*. The *VVB* shall assess the project’s *non-performance* risk and the defined permanence of the *GHG emission mitigations*. **7.1.4.7 Secondary Effects** No additional guidance or requirements. **7.1.4.8 Quantification Methodologies and Measurements** For avoidance of doubt, *GHG* quantification *methodology* can refer to *criteria* and procedures applied in sections 6.7, 6.8 from *ISO 14064-2*. Further, proponents may rely on good practice guidelines demonstrating conformity to the *criteria* as stipulated in *ISO 14064-2*. Methodologies established by *approved GHG programs* are generally considered a good practice guidelines. When projects apply methodologies but deviate from the prescribed *criteria* and procedures the *VVBs* shall ensure that the deviations do not negatively affect the conservativeness of the quantification of *GHG emission mitigations*, except where the deviations result in greater accuracy. **7.1.4.9 GHG Information System and Controls** Assessing data management, the *VVB* shall also consider other *criteria* applied. **7.1.4.10 Functional Equivalence** No additional guidance or requirements. **7.1.4.11 Calculation of GHG Statement** *VVBs* shall assess all data sources, assumptions and calculations for correctness and applicability to the project. Where models are used to estimate *GHG emission mitigations* the *VVBs* shall assess whether the model is understandable, transparent steps and applies appropriate parameters and adjusted for the context of the project. Where *VVBs* find *uncertainty* associated with a project’s data, parameters and *monitoring* procedures, the principle of conservativeness should be applied to adjust estimates of *GHG emission mitigations* and, where appropriate, manage the risk of associated *uncertainty*. **7.1.4.12 Future Estimates** The *VVB* shall evaluate projected *GHG emission mitigations* for the *crediting period* adjusted for *leakage* (*GHG SSRs* affected/secondary effects). **7.1.4.13 Uncertainty** No additional guidance or requirements. **7.1.4.14 Sensitivity** The *VVB* should adapt identified assumptions to be assessed during the next verification assessment. **7.1.4.15 Other Benefits and Safeguards** The *VVB* shall consider if the project proponent has completed the ICR ESES-SD tool and that parameters determined for monitoring are relevant to demonstrate alignment with claimed mitigations for environmental and socio-economic safeguards or SDG contributions. #### 7.1.1 Validation Plan The *VVB* shall upload the final version of the *validation* plan to the *registry* platform. The *VVB* shall upload any changes made to the *validation* plan to the *registry* platform during the *validation* after the *validation* has been completed. The *validation* plan is not intended to be publicly available. #### 7.1.2 Evidence-Gathering Plan The evidence-gathering plan is not required to be uploaded to the *registry* platform. #### 7.1.3 Approval of Validation and Evidence-Gathering Plans No additional guidance or requirements. #### 7.1.4 Amendments to Validation and Evidence-Gathering Plans Any updates to the *validation* plan shall be uploaded to the *ICR registry* platform. ### 7.2 Execution #### 7.2.1 General No additional guidance or requirements. #### 7.2.2 Evaluation of the GHG Statement No additional guidance or requirements. #### 7.2.3 Proper Disclosure The *VVB* shall consider, in addition to the project design and other disclosure, presentation of information in the *ICR registry* platform and evaluate. ### 7.3 Completion #### 7.3.1 General For *bundled project activities* the *VVB* shall state its opinion on conformity if the *bundled project activities* with the *criteria* and describe any steps taken to assess the conformity. The *VVB* shall complete the *validation* as soon as practically possible and share the result with the proponent. Any results shall further be shared with the ICR. #### 7.3.2 Opinion **7.3.2.1 General** No additional guidance or requirements. **7.3.2.2 Unmodified Opinion** When the *VVB* drafts an unmodified opinion, it shall be using the standard wording provided for in the ICR validation report template or the ICR validation and *verification report* template. **7.3.2.3 Modified Opinion** When the *VVB* drafts a modified opinion, it shall be using the standard wording provided for in the ICR *verification report* template or the ICR validation and *verification report* template. It shall however include to what extent the *VVB* can’t issue an unmodified opinion and disclose if it impairs the usefulness of claimed *GHG emission mitigation*. **7.3.2.4 Adverse Opinion** When the *VVB* has drafted an adverse opinion, he shall share that with the ICR as soon as practicable. **7.3.2.5 Disclaiming the Issuance of the Opinion** When the *VVB* has disclaimed the issuance of an opinion he shall share that with ICR as soon as practicable. #### 7.3.3 Validation Report The *validation report* shall describe the *validation* process, any findings raised during validation, actions to react, and the conclusions reached by the *validation* body. The *validation* body shall use the *validation report* template (or *validation* and *verification report* template for joint *validation* and *verification*) and follow all instructional text in the *validation report* template. The *validation report* shall include a *validation* statement and the opinion of the validation. Where the project being validated does not meet the *validation* criteria, the *validation/verification* body shall produce an adverse *validation opinion* and provide the *validation report* to the *project proponent* and ICR. The *project proponent* shall inform the ICR of any adverse *validation opinion* and is ineligible for *registration* until implementation of corrective actions and the *validation/verification* body has closed any non-conformities and provided a positive *validation* opinion. ### 8. Independent Review The independent reviewer shall not be involved in more than five consecutive *verification*s or up to five years *monitoring* whichever comes first. ### 9. Issuance of Opinion ### 9.1 General ### 9.2 Types of Opinions The *ICR program* applies the following names for opinion are Unmodified, Modified, Adverse, Disclaim the issuance of an opinion. Where the project being validated does not meet the *validation* criteria, the *VVB* shall produce an adverse *validation opinion* and provide the *validation report* to the *project proponent* and ICR. If project impacts under *verification* assessment do not meet the *verification* criteria, the *VVB* shall produce an adverse *verification* *opinion* and provide the *verification report* to the *project proponent* and ICR. ### 9.3 Contents of Opinion The *opinion* shall include the *level of assurance*. The *criteria* for the *validation/verification*. ### 10. Facts Discovered after the Verification/Validation For any facts or new information that could materially affect *verification* or *validation opinion* discovered after the date of the opinion the *VVB* shall immediately report such information to the proponent and the ICR. ### 11. Methodology Validation *Approved VVBs* are eligible to conduct *validation* of *methodology* under the methodology approval process. The *VVB* shall hold *accreditation* for *validation* for the *sectoral scope(s)* applicable to the *methodology*. Where the *methodology* falls under more than one *sectoral scope*, the *VVB* shall hold *accreditation* for *validation* for all relevant *sectoral scopes*. In the process of *methodology* approval, *VVBs* are required to assess the *methodology*. This assessment entails a comprehensive desk review encompassing all aspects outlined in the ICR methodology approval process and ICR methodology requirements. The assessment may involve an iteration where the *VVBs* provide CLs and CARs that must be addressed by the developer until satisfactory resolution. *Validation* involves determining if the proposed *methodology* is eligible to generate *GHG emission mitigation outcomes* when applied. *Validation* shall be conducted according to *ISO 14064-3*, especially section 7, and *ISO 14065* and these ICR validation and verification specifications, especially section 7. The *criteria* for *validation* are *ISO 14064-2*, ICR methodology requirements, and applicable requirements from the ICR requirement document. During *methodology* assessment, *VVBs* need to assess whether the *methodology* conforms to the *validation criteria* with the establishment of *criteria* and procedures ensuring conservativeness and scientific integrity and technical advancements and are scientifically proven and peer-reviewed and alignment with other principles from section 4 of the ICR methodology requirements. *Methodology* assessment requires background research, review of documentation, and interviews with experts and key stakeholders to determine whether the *criteria* and procedures established in the *methodology* conform to requirements and principles set out in the ICR methodology requirements, ICR requirement document and good practice standards. *VVBs* need to consider underlying assumptions and approaches used in the *methodology* and assess whether and how the *methodology* incorporates relevant scientific and sector-specific considerations. *VVBs* need to consider that methodologies shall be written in a manner that provides a prescriptive set of *criteria* and procedures that projects can apply and be assessed by *VVBs* to minimize subjective interpretation by project proponents applying the *methodology* and *VVBs* assessing projects. This includes using precise language, avoiding vague terminology, and ensuring the application and proper use of the keywords “can,” “shall,” “should,” and “may.” *VVBs* are responsible for assembling a competent *validation team* capable of conducting the assessment of the *methodology*, considering sector-specific competencies and qualifications. The teams shall include an impartial, suitably qualified technical reviewer. In cases where intricate technical or scientific expertise is demanded beyond the VVB's technical expertise, *VVBs* shall engage external *technical experts* for the *validation* who are experts in the pertinent field. Given the dynamic nature of science and technology in various sectors, these experts play a pivotal role in ensuring that the *methodology* adheres to the latest scientific best practices. ### 11.1 Key Components Methodologies establish detailed *criteria* and procedures that project proponents need to adhere to for project design following the *methodology*. The exhaustive requisites for methodologies are outlined within the ICR methodology requirements and complementary documentation. During *methodology* assessments, *VVBs* shall assess the alignment of the *methodology* with ICR requirements and its capacity to maintain rigor and scientific integrity. *VVBs* are further required to assess that methodologies present a comprehensive, prescriptive framework of *criteria* and procedures that projects can apply and *VVBs* can assess, thereby curbing preventing subjective interpretations by project proponents and *VVBs* applying the *methodology*. #### 11.1.1 Applicability Conditions *VVBs* shall assess whether the *methodology* provides a clear and defined specification and/or list of *project activities* eligible under the *methodology*. This means that applicability conditions cannot be open ended. Applicability conditions shall not include *criteria* and procedures that are addressed in other sections of the *methodology*. #### 11.1.2 Boundary The project boundary in a *methodology* sets out *criteria* and procedures for identifying and describing the *GHG SSRs* relevant to the project and baseline scenarios. The *VVB* shall assess whether the *methodology* has provided adequate justification for the included and excluded *GHG SSRs* and whether the *GHG SSRs* identified for the project and those identified in the *baseline scenario* are equivalent and consistent. *VVBs* shall assess whether the boundary includes, at minimum, all *GHG SSRs* controlled by the *project proponent* and related to the project (leakage). #### 11.1.3 Baseline Scenario All methodologies need to establish *criteria* and procedures for identifying the *baseline scenario* and determining the most plausible scenario. *VVBs* shall assess whether procedures for identifying the *baseline scenario* allows for identifying the most plausible baseline scenario, see section 6.4 in *ISO 14064-2*, and determine whether the procedure takes into account relevant information concerning present or future conditions such as political, technical, environmental and socio-economic conditions. #### 11.1.4 Additionality The procedures for demonstrating *additionality* provide a step-wise approach to demonstrate whether a *project activity* would have occurred in the absence of the intervention of the carbon market. The *ICR program* relies on benchmarking of additionality. The *VVB* shall assess if the level of *additionality* can reasonably be met for *project activities*. #### 11.1.5 Quantification of GHG Emission Mitigations During the assessment of quantification *criteria* and procedures, the *VVB* shall assess the appropriateness of applied formulas, calculation, and quantification methods. These methods should offer a coherent and consistent approach to determine net greenhouse gas emission mitigations. The assessment also involves assessing the application of suitable parameters within the calculation methods or formulas. Quantification *criteria* and procedures inherently involve a level of *uncertainty*. *VVBs* shall assess whether the *methodology* relies on assumptions, parameters, or procedures carrying significant *uncertainty*. The *methodology* should incorporate measures to manage such *uncertainty*. The *VVBs* are advised to refer to *good practice guidance* on *uncertainty* to assess methodological uncertainties. *VVBs* should give special attention to *uncertainty* when employing indirect methods like models, default factors, and proxies to estimate *GHG emission mitigations*. This is particularly crucial when direct measurements are impractical due to *project activity* nature or cost constraints. When methodologies adopt a model-based approach, *VVBs* should assess the model's foundation in publicly recognized and reputable sources. *VVBs* may also need to determine whether a model has been appropriately calibrated for the specific ecological jurisdiction. Methodologies should offer a mechanism to calibrate or refine model *uncertainty* using available data and measurements. Evaluating *GHG SSRs* affected by the *project activities* (leakage) can pose challenges due to intricate interconnections between a *project activity* and external activities. *VVBs* shall determine if changes in *GHG emissions* outside the project's boundary can be directly linked to the *project activities*. When a project induces *GHG* emission alterations beyond its boundary, these emissions are classified as leakage. An essential consideration for *VVBs* is whether the *methodology* addresses potential emissions sources upstream and downstream of the *project activity*. As a project's impact can span various upstream and downstream effects, *VVBs* should assess the significance and direct correlation of these effects with the project's activity, guided by the principle of relevance. *VVBs* shall ensure that appropriate *criteria* and procedures address distinct types of leakage, i.e. market leakage, activity-shifting leakage, ecological leakage, economic leakage, substitution leakage, technology leakage, where applicable: #### 11.1.6 Monitoring When assessing *monitoring* data and parameters, *VVBs* shall assess that default factors and standards utilized originate from publicly accessible, reputable, and recognized sources, such as the IPCC or government publications. These factors and standards should be peer-reviewed and suitable for the specific *GHG SSRs* being assessed, while also reflecting the most up-to-date data. In cases where methodologies lack explicit data values, *VVBs* are required to assess whether the *methodology* outlines proper procedures for project proponents to determine these values. *VVBs* shall also assess the appropriateness of measurement methods prescribed by the *methodology* considering trade-offs between accuracy, cost-benefit and *uncertainty*. If a *methodology* selects a less accurate *monitoring* approach for a particular *GHG SSR*, the *VVB* must assess whether the *methodology* implements procedures to ensure that estimates remain conservative. ### 11.2 Reporting *Methodology* assessment reports should clearly outline both the assessment process and its outcomes, any findings raised during validation, actions to react, and the conclusions reached by the *validation* body. The *validation report* shall include a *validation* statement and the opinion of the validation. The VVB shall use the ICR methodology *validation* template. The documentation shall encompass all CLs, CARs, and the responses from the *methodology developer*. *VVBs* are responsible to ensure that methodology assessment reports present an adequate level of detail, facilitating comprehension of interested parties regarding the methodology's alignment with ICR requirements and scientific best practices. The *validation* statement shall be according to *ISO 14065* ### 12. Other ### 12.1 Oversight In addition to the *accreditation* requirements to which all *VVBs* must adhere, ICR reserves the right to conduct oversight activities. Oversight activities are conducted to ensure an adequate level of quality control and assess performance of the VVB operating under the *ICR program*. It’s intended to supplement *accreditation body* oversight and audit processes during ongoing *validation* and *verification* activities and to complement ABs regular audits and provide additional input to ABs assessments. Oversight activities conducted by ICR may include the following: * Review of information and supplementary documentation submitted by *VVBs* regarding project specific conflict of interest determinations. * Review of VVB documentation such as *validation/*verification requirements stipulated in *ISO 14064-3* and this document. * Review of *Validation Reports, Verification Reports*, and *Verification Opinion*; and * Participation during onsite assessments. ### 12.2 Training and Continuous Improvement VVB shall allocate time for training on the ICR requirements. All *VVBs* shall be members of the VVB forum and shall participate in biannual meetings with ICR. ### 12.3 Clarification Requests If *VVBs* require further clarification from ICR, they can request guidance from the VVB forum , with forms on the ICR website or the *registry* platform. They may also inquire guidance by sending an email to . For inquiries related to proprietary or commercially sensitive matters, *VVBs* may contact the ICR management directly. When inquiring for guidance from the ICR on interpretation of requirements an explicit reference shall be made to the relevant stipulation. Requests shall clearly outline the specific areas requiring clarification, including any relevant context and background information. Guidance provided by ICR directly to *VVBs* or are outlined in this ICR validation and verification specifications shall not be considered as decisions, approvals, or consultations regarding specific *project activities*. ### Appendix I – Document History | Version | Date | Comment | | ------- | ---------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 1.0 | 9.10.2023 | First version. | | 2.0 | 15.10.2024 |

Structure and readability improved. Added details about methodology validation, oversight details, training.

After public consultation language made clearer.

| 1. Section 4, ISO 14064-2:2019 ↑ 2. Section 4, ISO 14064-3:2019 ↑ 3. ↑