> 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-v3.0.md).
# ICR Validation and Verification Specifications v3.0
#### *Summary*
The ICR Program is a greenhouse gas crediting program for climate projects of any size. It promotes environmental integrity by establishing requirements for credible, consistent and transparent quantification, monitoring, reporting, validation and verification.
| Version no. | 3.0 |
| --------------- | --------------- |
| Date of Version | 9. October 2026 |
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The pdf version is the official version for the document
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## Introduction
The ICR Program establishes requirements and procedures for independent third-party validation of projects and methodologies and verification of GHG emission mitigations under the International Carbon Registry.
The ICR Program is aligned with ISO 14064-2 and ISO 14064-3. ISO 14064-2 provides project-level requirements for quantification, monitoring and reporting of GHG emission reductions and removal enhancements. ISO 14064-3 provides the validation and verification framework applied by VVBs when assessing GHG statements under the ICR Program.
ICR requirements are applied as program criteria within ISO 14064-3 validation and verification engagements. This document specifies ICR Program-level requirements and guidance for VVBs when validating or verifying conformity with ICR requirements. It does not establish a validation or verification process separate from ISO 14064-3 or from the VVB’s accredited procedures.
VVBs performing validation or verification under the ICR Program shall operate under ISO 14065 accreditation issued by an accreditation body recognized by ICR for the relevant activity and scope. Assessment of conformity with ISO 14065, ISO 14064-3, ISO 14066, ISO 17029, and accreditation requirements remain the responsibility of the relevant accreditation body. ICR approval and oversight of VVBs relate to performance under the ICR Program and do not constitute accreditation assessment.
The mandatory requirements for conformity with the ICR Program are detailed in the applicable ICR Program documents, including, as relevant:
* ICR Requirement Document;
* ICR Process Requirements;
* ICR Methodology Requirements;
* ICR Methodology Approval Process;
* ICR Definitions;
* ICR Additionality Specifications;
* ICR Approved Methodologies, Modules and Tools;
* ICR Article 6.2 Procedures;
* ICR Environmental and Socio-economic Safeguards and Sustainable Development Tool and related monitoring tool;
* applicable ICR reporting templates and template instructions; and
* other ICR requirements, decisions, clarifications, approval conditions, registry requirements, or scheme requirements applicable to the engagement.
ICR Program documents are updated from time to time. New or revised requirements take effect upon issuance unless otherwise specified by ICR. Where validation or verification has already started before revised requirements take effect, the applicable transition provisions, grace periods, or specific instructions issued by ICR shall apply. VVBs shall refer to the current ICR Program documents, ICR website, registry platform, and formal ICR communications for applicable updates.
### Validation and Verification
Independent third-party validation and verification support the integrity, credibility, consistency, and transparency of GHG emission mitigation outcomes under the ICR Program.
VVBs may perform the following activities under the ICR Program, subject to ICR approval, the VVB agreement, and the VVB’s applicable accreditation scope:
1. project validation;
2. verification of GHG emission mitigations for a monitoring period;
3. joint validation and verification;
4. validation or verification of design changes, deviations, baseline updates, monitoring plan changes, project instance inclusions, or other changes requiring VVB assessment under ICR requirements; and
5. methodology, module, or tool validation under the ICR Methodology Approval Process.
Validation and verification under the ICR Program shall be conducted in accordance with ISO 14064-3, applicable ICR requirements, this document, and the VVB’s accredited procedures.
Validation or verification opinions issued under the ICR Program support ICR Program decisions but do not constitute registration, issuance, conversion, methodology approval, acceptance of a design change, or any other ICR Program decision.
### Purpose
This document provides ICR specifications for validation and verification engagements conducted under the ICR Program. It clarifies how VVBs are expected to identify, assess, conclude on, and report conformity with ICR Program criteria within ISO 14064-3 validation and verification engagements.
This document is intended to:
1. support consistent application of ICR requirements by approved VVBs;
2. clarify the relationship between ISO 14064-3 validation and verification activities and ICR Program criteria;
3. support transparent and traceable validation and verification reporting;
4. clarify ICR-specific expectations for project validation, verification, joint validation and verification, and methodology validation;
5. support ICR review, registration, issuance, conversion, methodology approval, and oversight processes;
6. preserve VVB professional judgement and compatibility with accredited validation and verification under ISO 14065; and
7. support consistent use of ICR validation, verification, validation and verification, and methodology validation report templates.
This document does not prescribe the VVB’s internal procedures, detailed audit methods, sampling approaches, evidence-gathering methods, or accreditation management system. The VVB shall determine such matters in accordance with its accredited procedures, applicable ISO requirements, the engagement scope, applicable criteria, assessed risks, materiality where applicable, and the evidence necessary to support the validation or verification conclusion.
The structure of this document is aligned with ISO 14064-3. Some sections may be intentionally brief or may not duplicate ISO 14064-3 requirements, where the ICR-specific interface is addressed elsewhere in this document.
## Scope
This document specifies ICR Program requirements and provides guidance for validation and verification activities conducted under the ICR Program.
This document applies to:
1. validation of project design descriptions submitted under the ICR Program;
2. verification of GHG emission mitigations and monitoring reports for registered ICR projects;
3. joint validation and verification engagements;
4. validation or verification of design changes, deviations, baseline updates, monitoring plan changes, project instance inclusions, or other post-validation or post-registration changes requiring VVB assessment under ICR requirements;
5. methodology, module, or tool validation under the ICR Methodology Approval Process; and
6. remote, onsite, or hybrid validation and verification activities where such activities are used as part of the engagement.
This document is applicable to GHG statements and project documentation relating to quantification, monitoring, reporting, validation, and verification of GHG emission reductions or removal enhancements intended for registration, issuance, conversion, methodology approval, or other ICR Program decisions.
For project validation and verification, project documentation includes supporting ICR tools and forms where required by ICR, including the ESES-SD Tool and related monitoring information. Such tools support assessment of the PDD, PDDMR, monitoring report, safeguards, other benefits, SDG contributions, and related claims and do not establish a separate assurance engagement unless expressly specified by ICR.
ISO 14064-3 is indispensable for applying this document to validation and verification engagements. ISO 14064-5 shall be considered where remote activities or techniques are used.
## Normative References
The following documents are referenced in this document and may contain criteria applicable to validation, verification, joint validation and verification, or methodology validation under the ICR Program. The applicable version shall be the version required by ICR for the relevant engagement.
### ICR Program Documents
* ICR Requirement Document;
* ICR Process Requirements;
* ICR Methodology Requirements;
* ICR Methodology Approval Process;
* ICR Definitions;
* ICR Additionality Specifications;
* ICR Approved Methodologies, Modules and Tools;
* ICR Article 6.2 Procedures, where applicable;
* ICR Environmental and Socio-economic Safeguards and Sustainable Development Tool;
* ICR Environmental and Socio-economic Safeguards and Sustainable Development Monitoring Tool;
* applicable ICR project description document, monitoring report, and project description document and monitoring report templates and template instructions;
* applicable ICR validation, verification, validation and verification, and methodology validation report templates and template instructions;
* applicable ICR approved or ICR accepted methodologies, modules, tools, methodological guidance, decisions, clarifications, approval conditions, registry requirements, and scheme requirements.
### ISO Standards
* 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 14064-5, Greenhouse gases — Part 5: Guidance for the verification and validation of greenhouse gas statements using remote activities and techniques;
* 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;
* ISO 17029, Conformity assessment — General principles and requirements for validation and verification bodies.
### Other References
ICR may consider relevant IAF documents, accreditation body requirements, and scheme owner good practice documents when maintaining the ICR Program and communicating with accreditation bodies. Such documents do not replace the VVB’s accreditation requirements or the accreditation body’s role in assessing conformity with accreditation and applicable ISO requirements.
Other references may include, as relevant:
1. IAF MD 6, IAF Mandatory Document for the Application of ISO 14065:2020;
2. IAF MD 25, Criteria for Evaluation of Conformity Assessment Schemes;
3. the VVB agreement between ICR and the approved VVB; and
4. applicable accreditation body rules, procedures, or decisions.
These documents may inform ICR scheme maintenance, VVB approval, oversight, cooperation with accreditation bodies, and implementation of the VVB agreement, but shall not be treated as validation or verification criteria unless expressly identified as applicable criteria by ICR.
## Definitions
For the purposes of this document, the terms and definitions in ICR Definitions apply when interpreting and assessing conformity with ICR Program requirements.
The terms and definitions in ISO 14064-2, ISO 14064-3, ISO 14064-5, ISO 14065, ISO 14066, and ISO 17029 apply when interpreting and assessing conformity with the requirements of those standards. Where the same or a similar term has different meanings under an ISO standard and the ICR Program, the VVB shall apply the definition associated with the criterion being assessed and shall clearly document any distinction that may affect the engagement conclusion or opinion.
**Clarification request (CL)** means an engagement finding raised by the VVB to the project proponent, responsible party or methodology developer where project or methodology documentation lacks transparency or further information is needed to determine whether a material misstatement or non-conformity is present.
**Corrective action request (CAR)** means a finding raised where the VVB has identified a material misstatement or non-conformity that the project proponent, responsible party or methodology developer shall correct or otherwise address, and whose resolution or remaining effect shall be evaluated during the current engagement.
**Forward action request (FAR)** means a finding identifying a prospective matter, condition, assumption or action that does not constitute a misstatement or non-conformity in the current engagement and does not affect the current conclusion or opinion, but requires assessment during a subsequent monitoring period or validation or verification engagement.
**ICR Program criteria** means requirements formally issued or approved by ICR, or expressly accepted by ICR for a specific engagement, and identified as applicable to that engagement. These may include applicable ICR Program documents, approved methodologies, modules and tools, published decisions and clarifications, approval conditions, registry requirements, applicable third-party scheme requirements, reporting template instructions, and other formally issued ICR requirements.
**Project-specific criteria and procedures** means criteria and procedures established in project documentation to demonstrate conformity with ISO 14064-2 and ICR requirements where no approved methodology, module, tool, or methodological guidance is applied for the relevant project design element. Project-specific criteria and procedures are assessed only for the project under validation and do not constitute approval of a methodology, module, tool, or methodological guidance for wider application under the ICR Program.
**Activities and techniques applied remotely (remote activities and techniques)** means validation or verification activities and techniques performedby a member or members of the validation or verification team who are not physically present at the relevant site, facility, location, or information source, using information and communication technology or other remote means. These may include remote interviews and observations, review of digital records, remote sensing, geospatial information, digital monitoring systems, and other information and communication technology-enabled evidence-gathering techniques. The use of activities and techniques applied remotely does not, by itself, constitute an in-person site or facility visit.
**Joint validation and verification** means an engagement in which validation and verification activities are conducted in the same engagement or reported in the same report, while retaining distinct validation and verification objectives, criteria, scopes, conclusions, and opinions.
## Principles
The principles in ISO 14064-2 and ISO 14064-3 apply to validation and verification engagements under the ICR Program.
Principles support professional judgement, risk-based planning, evidence evaluation, proper disclosure, and interpretation of requirements where project-specific, methodology-specific, or program-specific requirements do not fully prescribe the treatment of a matter.
Principles are not stand-alone auditable requirements unless they are expressed as criteria in ISO 14064-2, applicable ICR Program documents, an applied methodology, module, tool, methodological guidance, project-specific criteria and procedures, or another accepted criterion. However, principles shall guide the VVB’s assessment of conformity, evidence sufficiency, conservativeness, transparency, and reasonableness of conclusions.
The VVB shall apply the principles when planning, performing, concluding, reviewing, and reporting validation and verification activities under the ICR Program.
| **ISO 14064-2 principles**[**\[1\]**](#footnote-1) | **ISO 14064-3 principles**[**\[2\]**](#footnote-2) |
| ----------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------- |
|
|
## Requirements Applicable to Verification/Validation
### Pre-Engagement Activities
The VVB shall conduct pre-engagement activities in accordance with ISO 14064-3, this document, applicable ICR Program requirements, and the VVB’s accredited procedures.
Where remote activities or techniques are anticipated, the VVB shall consider ISO 14064-5 when determining whether such activities or techniques are suitable for the engagement.
For ICR engagements, the VVB and the client shall establish a mutual understanding of the engagement objectives, scope, criteria, level of assurance where applicable, and materiality. The VVB shall recognize that ICR and users of the ICR registry are intended users of project design descriptions, monitoring reports, validation reports, verification reports, validation and verification reports, methodology validation reports, and related validation or verification opinions submitted for registration, issuance, conversion, methodology approval, or other ICR Program decisions.
The VVB shall confirm that the project has the appropriate status under the ICR Program before accepting the engagement. A project shall be pre-registered before the VVB accepts a project validation engagement. A project shall be registered before the VVB accepts a verification engagement, unless the engagement is a joint validation and verification, in which case the project shall be pre-registered.[\[3\]](#footnote-3)
For ICR engagements, the VVB shall determine whether the engagement can be accepted or continued, taking account of:
1. the type of engagement requested;
2. the applicable ICR Program criteria;
3. the intended use of the validation or verification opinion;
4. the project type, methodology, sectoral scope, geographic scope, and complexity of the activity;
5. the competence, impartiality, and resources necessary to perform the engagement;
6. whether sufficient and appropriate evidence is expected to be available;
7. whether any restrictions, conflicts, or limitations may prevent the VVB from reaching an independent conclusion; and
8. where remote activities or techniques are anticipated, whether such activities or techniques are suitable for the engagement type, scope, criteria, project context, available information systems, and expected evidence needs.
ICR requirements shall be treated as program criteria within the validation or verification engagement. The VVB shall assess conformity with applicable ICR requirements through its ISO 14064-3 validation or verification procedures.
This document does not prescribe the VVB’s internal procedures, evidence-gathering methods, sampling approach, or detailed audit techniques. The VVB shall determine these in accordance with its accredited management system, applicable ISO requirements, and the risk, complexity, criteria, materiality, and evidence needs of the engagement.
Where the VVB anticipates using activities or techniques remotely, the VVB shall not accept or continue the engagement on the basis of such activities or techniques where known limitations would prevent the VVB from obtaining sufficient and appropriate evidence or reaching an independent conclusion.
#### General
VVBs are eligible to provide validation and verification services under the ICR Program where they have signed an agreement with ICR and hold ISO 14065 accreditation issued by an accreditation body recognized by ICR for the relevant validation or verification activity and sectoral scope.
The VVB shall designate and disclose to ICR the ISO 14065 accreditation under which each ICR engagement is conducted. The designated accreditation shall cover the applicable validation or verification activity and sectoral scope and shall be issued by an accreditation body recognized by ICR.
The VVB shall hold accreditation and ICR approval for validation or verification, as applicable, for the sectoral scope or scopes relevant to the project. Where the project falls under more than one sectoral scope, the VVB shall hold accreditation and ICR approval for all relevant sectoral scopes, unless ICR has accepted another arrangement consistent with the VVB’s accreditation and applicable ICR requirements.
Before accepting an ICR validation or verification engagement, the VVB shall determine whether:
1. the VVB is approved by ICR for the relevant validation or verification activity;
2. the engagement can be performed under the VVB’s ISO 14065 accreditation issued by an accreditation body recognized by ICR;
3. the project status under the ICR Program is appropriate for the engagement type;
4. the project type, sector, activity, methodology, GHG statement, and intended engagement fall within the VVB’s accredited and ICR-approved scope;
5. the VVB has access to competent personnel for the applicable project type, sector, methodology or criteria, and ICR Program requirements;
6. impartiality risks have been identified and can be managed in accordance with the VVB’s accredited procedures and ICR requirements;
7. the applicable criteria can be identified and are sufficiently available to support the engagement;
8. the project proponent has made available documentation necessary to assess conformity with the applicable criteria; and
9. the engagement can be conducted in accordance with ISO 14064-3, ISO 14065, this document, and applicable ICR Program requirements.
The VVB shall not accept the engagement where these conditions cannot be met, unless the matter is resolved before engagement acceptance.
The VVB and the client may agree to include additional criteria in the engagement, provided that such criteria meet the requirements of Section 5.1.5.5.
New or revised ICR requirements take effect upon issuance unless otherwise specified by ICR. Where validation or verification has already started before revised requirements take effect, the applicable transition provisions, grace periods, or specific instructions issued by ICR shall apply. VVBs shall refer to the current ICR Program documents, ICR website, registry platform, and any formal ICR communications for applicable updates.
#### Type of Engagement
The VVB shall identify the engagement type before acceptance. The engagement type may include:
1. validation of a project design description;
2. verification of GHG emission mitigations for a monitoring period;
3. joint validation and verification;
4. validation of a methodology, module, or tool under the ICR Methodology Approval Process;
5. validation or verification of a design change, deviation, baseline update, monitoring plan change, or other change after validation or registration;
6. validation or verification of inclusion of project instances under grouped project activities, where applicable; and
7. other validation or verification activities required under ICR Program documents.
For joint validation and verification, the VVB shall define separate validation and verification objectives, criteria, scopes, conclusions, and opinions, even where the activities are planned, conducted, or reported together.
Where more than one engagement type is performed at the same time, the VVB shall ensure that the objectives, criteria, scope, findings, conclusions, and opinions for each engagement type are clearly distinguished.
The VVB shall use the applicable ICR reporting template for the engagement type.
Where the engagement type is unclear, the VVB shall obtain clarification from ICR before issuing the report or opinion.
#### Level of Assurance
**Verification**
The ICR Program requires reasonable assurance for verification of GHG emission mitigations unless ICR has expressly specified otherwise for the applicable project type, instrument, or engagement.
For verification, the VVB shall determine whether the GHG statement for the monitoring period is free from material misstatement and whether the reported GHG emission mitigations conform with the applicable criteria.
The VVB shall plan and perform the verification with professional skepticism and professional judgement. The VVB shall design verification activities, including sampling and testing, based on the outcome of the risk assessment, the applicable materiality threshold, the required level of assurance, and the evidence needed to support the verification conclusion.
A reasonable assurance engagement does not require every item of data or information to be tested. However, the VVB shall design and perform verification activities sufficient to obtain reasonable assurance that the GHG statement is free from material misstatement.
**Validation**
For validation under the ICR Program, the VVB shall apply the validation approach and terminology of ISO 14064-3.
The validation opinion shall state whether the project design, assumptions, methods, limitations, and projected GHG emission mitigations provide a reasonable basis for the GHG statement and conform with the applicable criteria.
Validation evaluates the reasonableness of assumptions, methods, limitations, and projected outcomes and shall not be described as reasonable assurance over future GHG emission mitigations unless expressly required by applicable criteria.
The validation opinion shall state that actual GHG emission mitigations may differ from projected GHG emission mitigations because anticipated events, conditions, implementation, data, or assumptions may not occur as expected, and the difference may be material.
#### Objectives
The VVB shall define the objectives of the engagement based on the engagement type, scope, criteria, level of assurance where applicable, materiality where applicable, and intended use of the validation or verification opinion.
The primary objective of validation or verification under the ICR Program is to assess the relevant GHG statement and conformity with applicable criteria, including ISO 14064-2, applicable ICR Program requirements, and, where applicable, the applied methodology, module, tool, methodological guidance, project-specific criteria, or other accepted criteria.
Where supporting tools or forms are required by ICR, including the ESES-SD Tool or ESES-SD monitoring information, the VVB shall assess them in relation to the PDD, PDDMR, monitoring report, GHG statement, and claims included in the ICR submission.
**Verification Objectives**
For project verification, the VVB shall determine whether:
1. the GHG statement for the monitoring period is free from material misstatement;
2. the project implementation and reported GHG emission mitigations conform with ISO 14064-2;
3. the project implementation and reported GHG emission mitigations conform with the ICR Requirement Document and other applicable ICR Program requirements;
4. the applied approved methodology, module, tool, or methodological guidance has been correctly applied, where applicable;
5. the project has been implemented in accordance with the validated PDD, PDDMR, monitoring plan, or other validated project design documentation;
6. deviations, design changes, baseline updates, monitoring changes, data gaps, uncertainty, leakage, non-permanence events, reversals, safeguards, ownership, double counting, and other relevant matters have been addressed, where applicable;
7. the monitoring plan and applicable monitoring requirements have been implemented;
8. the reported GHG emission mitigations are materially correct for the monitoring period; and
9. the verified GHG emission mitigations are eligible for issuance or conversion under the ICR Program.
Where ex-post additionality reporting is required for the monitoring period, the verification objective is to assess whether such reporting has been completed and supported in accordance with applicable ICR requirements. Ex-post additionality reporting shall be evaluated in accordance with the ICR Additionality Specifications and any applicable transition, renewal, disclosure, or reassessment requirements.
**Validation Objectives**
For project validation, the VVB shall determine whether:
1. the project design conforms with ISO 14064-2;
2. the project design conforms with the ICR Requirement Document and other applicable ICR Program requirements;
3. the applied approved methodology, module, tool, or methodological guidance has been correctly applied, where applicable;
4. the project-specific criteria and procedures are appropriate and sufficient where no approved methodology is applied;
5. the baseline scenario, additionality demonstration, project boundary, SSR selection, quantification approach, monitoring plan, safeguards, ownership, title, double counting provisions, and non-permanence treatment conform with applicable criteria;
6. the assumptions, methods, procedures, and evidence supporting the ex-ante GHG statement are reasonable;
7. the project design provides a sufficient basis for future monitoring, verification, and issuance; and
8. any limitations, deviations, uncertainties, or unresolved issues affect the validation opinion.
Where the ESES-SD Tool is required, the validation objective includes assessment of consistency between the completed ESES-SD assessment, the PDD or PDDMR, stakeholder consultation information, monitoring arrangements, and related claims.
**Joint validation and verification objectives**
For joint validation and verification, the VVB shall establish separate validation and verification objectives.
The validation objective shall address conformity of the project design with the applicable validation criteria.
The verification objective shall address conformity of project implementation and reported GHG emission mitigations with the applicable verification criteria for the monitoring period.
The VVB shall ensure that a verification conclusion is not used to compensate for an unresolved validation issue, and that a validation conclusion is not used to compensate for insufficient verification evidence.
**Methodology validation objectives**
For methodology validation, the VVB shall determine whether:
1. the methodology conforms with ISO 14064-2 applied at methodology level, mutatis mutandis;
2. the methodology conforms with the ICR Methodology Requirements;
3. the methodology conforms with the ICR Requirement Document and other applicable ICR Program requirements;
4. the methodology provides clear, operational, scientifically credible, conservative, and verifiable criteria and procedures for project-level application;
5. application of the methodology can support project-level conformity with ISO 14064-2 and the ICR Requirement Document; and
6. the methodology is sufficiently specific to support consistent project design, validation, monitoring, verification, and, where applicable, issuance.
Detailed specifications for methodology validation are specified in Section 11.
#### Criteria
The VVB shall identify the criteria applicable to the validation or verification engagement before performing the engagement.
Criteria specify the standards, requirements, rules, benchmarks, procedures, or other requirements against which the project, methodology, GHG statement, or reported GHG emission mitigations are assessed.
The VVB shall assess whether the criteria are suitable for the engagement, including whether they are relevant, complete, reliable, understandable, available to intended users, and capable of supporting a validation or verification conclusion.
ICR Program criteria shall not be replaced, reduced, or overridden by additional criteria, contractual requirements, guidance, examples, non-approved methodologies, or project proponent procedures unless ICR has expressly accepted such treatment.
**Validation**
For project validation, the criteria shall be:
1. ISO 14064-2;
2. the ICR Requirement Document;
3. the applied approved methodology, module, tool, or methodological guidance, where applicable;
4. the ICR Environmental and Socio-economic Safeguards and Sustainable Development Tool;
5. the ICR Article 6.2 Procedures, where Article 6.2 eligibility, authorization, corresponding adjustment, or international transfer-related claims are included in the ICR submission; and
6. any other ICR requirement, decision, clarification, approval condition, scheme requirement, or accepted criterion applicable to the engagement.
The VVB shall assess whether the project design conforms with the applicable criteria and whether the project design provides a reasonable basis for achieving the claimed GHG emission mitigations.
Where no approved methodology is applied, the VVB shall assess the project’s conformity with ISO 14064-2 and the ICR Requirement Document, including the project-specific criteria and procedures established by the project proponent for baseline determination, additionality, project boundary, SSR selection, quantification, monitoring, uncertainty, data quality, safeguards, and other applicable project design elements.
Where an approved methodology, module, tool, or methodological guidance is applied, the VVB shall assess whether it has been applied correctly and whether the project remains in conformity with ISO 14064-2 and the ICR Requirement Document.
Where a provision in an applied methodology, module, tool, or methodological guidance is inconsistent with or less stringent than the ICR Requirement Document or other applicable ICR Program requirements, the controlling ICR requirement shall take precedence unless ICR has issued a specific determination to the contrary.
Guidance, examples, background information, non-approved methodological references, or good-practice documents may support the VVB’s assessment but shall not be treated as validation criteria unless accepted by ICR or otherwise applicable under ICR Program requirements.
Where no approved methodology is applied, the validation shall include assessment of the justification for the selection or establishment of criteria and procedures relating to the relevant ISO 14064-2 project design requirements, including baseline, project boundary, SSR selection, quantification, monitoring, uncertainty, data quality, and other relevant elements.
The ICR Environmental and Socio-economic Safeguards and Sustainable Development Tool is applicable to all ICR project validations as a required supporting tool for disclosure and assessment of safeguards, other benefits, SDG contributions, and environmental or socio-economic risks.
The completed ESES-SD assessment shall be assessed together with the PDD, PDDMR, stakeholder consultation information, monitoring plan, and other relevant project documentation. The VVB shall assess whether the information presented in the ESES-SD assessment is complete, consistent with the project documentation, and sufficient to support the safeguards, other benefits, SDG contributions, and related claims made in the ICR submission.
The VVB is not required to provide assurance over broad environmental, social, economic, human-rights, or sustainable-development performance beyond the applicable ICR requirements, the ESES-SD Tool, and the claims included in the project documentation.
Where the project seeks Article 6.2 eligibility, corresponding adjustment treatment, or other international transfer-related designation under the ICR Program, the VVB shall assess whether the project documentation identifies the applicable Article 6.2 criteria, claims, authorization status, authorized uses, vintages, quantity limits, and related monitoring or reporting obligations. The VVB’s assessment shall support the validation conclusion but shall not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
**Verification**
For project verification, the criteria shall be:
1. ISO 14064-2;
2. the ICR Requirement Document;
3. the applied approved methodology, module, tool, or methodological guidance, where applicable;
4. the validated PDD, PDDMR, monitoring plan, or other validated project design documentation;
5. the validated ESES-SD assessment and ESES-SD monitoring information submitted for the monitoring period;
6. the ICR Article 6.2 Procedures, where Article 6.2 eligibility, authorization, corresponding adjustment, or international transfer-related claims are included in the monitoring report, PDDMR, registry submission, or verification scope; and
7. any other ICR requirement, decision, clarification, approval condition, scheme requirement, or accepted criterion applicable to the engagement.
The VVB shall assess whether the project has been implemented in conformity with the applicable criteria and validated project design, and whether the reported GHG emission mitigations for the monitoring period are materially correct and eligible for issuance or conversion under the ICR Program.
Where project implementation has deviated from the validated project design, the VVB shall assess whether the deviation affects conformity with ISO 14064-2, the ICR Requirement Document, the applied methodology where applicable, the GHG statement, eligibility for issuance or conversion, or the verification opinion.
For verification, the VVB shall consider the validated ESES-SD assessment and ESES-SD monitoring information as supporting documentation for assessing safeguards, other benefits, SDG contributions, incidents, complaints, corrective actions, and related claims reported in the monitoring report or PDDMR.
The VVB shall assess ESES-SD monitoring information in relation to the monitoring report, validated project design, and applicable ICR requirements. Verification of ESES-SD information shall be limited to the safeguards, other benefits, SDG contributions, monitoring obligations, incidents, corrective actions, and claims included in the project documentation or monitoring report.
Where the verification includes Article 6.2 eligibility, corresponding adjustment treatment, or other international transfer-related claims, the VVB shall assess whether the monitoring report, PDDMR, registry submission, or other relevant documentation is consistent with the applicable Article 6.2 criteria, authorization status, authorized uses, vintages, quantity limits, monitoring obligations, and prior validation conclusions. The VVB’s assessment shall support the verification conclusion but shall not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
**Joint validation and verification criteria**
For joint validation and verification, the criteria shall include the applicable project validation criteria and project verification criteria.
The VVB shall apply the validation criteria to the project design and the verification criteria to project implementation and GHG emission mitigations for the monitoring period.
The VVB shall clearly distinguish findings, conclusions, and opinions relating to validation from those relating to verification.
**Methodology validation criteria**
For methodology validation, the criteria shall be:
1. ISO 14064-2, applied at methodology level *mutatis mutandis*;
2. the ICR Methodology Requirements;
3. the ICR Requirement Document;
4. the ICR Additionality Specifications, where the methodology includes additionality criteria or procedures;
5. any other ICR requirement, decision, clarification, approval condition, or accepted criterion applicable to the methodology validation.
The VVB shall assess whether the methodology provides clear, complete, consistent, scientifically credible, conservative, operational, and verifiable criteria and procedures for project-level application under the ICR Program.
Detailed requirements for methodology validation are specified in Section 11.
**Additional criteria**
The project proponent or methodology developer may request that additional criteria be included in the engagement.
The VVB shall include additional criteria only where they are:
1. clearly defined;
2. publicly available or otherwise available to intended users;
3. suitable for validation or verification;
4. auditable;
5. consistent with ISO 14064-2, the ICR Requirement Document, the ICR Methodology Requirements where applicable, and other applicable ICR requirements;
6. accepted by the VVB as suitable criteria for the engagement; and
7. accepted by ICR where the additional criteria affect the intended ICR Program decision, public claims, registry treatment, registration eligibility, issuance eligibility, conversion eligibility, or methodology approval.
Additional criteria shall not reduce, override, or replace applicable ICR Program criteria unless ICR has expressly accepted such treatment.
The validation or verification report shall identify any additional criteria and shall distinguish them from ICR Program criteria.
#### Scope
The VVB shall define the scope of the engagement before performing validation or verification activities.
When determining the scope of the engagement, the VVB shall consider the physical boundaries, project sites or facilities, temporal boundaries, GHG statement, applicable criteria, project documentation, and intended use of the opinion. For validation, temporal boundaries are determined based on the crediting period and project design under the applicable ICR requirements. For verification, temporal boundaries are determined by the monitoring period.
The scope shall identify, as applicable:
1. project title, project ID, project proponent, project type, sectoral scope, and geographic boundary;
2. the project activity or project activities included in the engagement;
3. whether the engagement covers a stand-alone project, bundled project, grouped project activity, project instance, or hybrid project;
4. the applied methodology, modules, tools, methodological guidance, and versions, where applicable;
5. the PDD, PDDMR, monitoring report, methodology document, or other GHG statement versions assessed;
6. the crediting period, monitoring period, and GHG statement covered;
7. the GHG SSRs and GHG emission mitigations included;
8. any design changes, deviations, baseline updates, monitoring changes, project instance inclusions, or other changes included in the engagement;
9. safeguards, other benefits, SDG contributions, Article 6.2-related claims, authorization, corresponding adjustment, ownership, title, double counting, or claim-related matters included in the engagement scope;
10. whether any remote activities or techniques are planned where such activities or techniques materially affect the evidence-gathering approach; and
11. any limitations on scope and their effect on the VVB’s conclusion.
The scope shall be sufficient to support the intended use of the opinion and ICR’s registration, issuance, conversion, methodology approval, or other program decision.
#### Materiality Threshold
Materiality refers to the significance of individual or aggregated misstatements, omissions, or misrepresentations that could influence the decisions of intended users.
For ICR verification, materiality is applied to the reported GHG emission mitigations for the monitoring period and is not subject to negotiation between the project proponent and the VVB.
The VVB shall plan and conduct verification to obtain reasonable assurance that the reported GHG emission mitigations are free from material errors, omissions, or misstatements. An omission, misstatement, or erroneous reporting of information is quantitatively 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 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 total GHG emission mitigations of less than 250,000 t CO2-e/yr and more than 10,000 t CO2-e/yr; and
3. 10 per cent of the GHG emission mitigations for project activities achieving total GHG emission mitigations equal to or less than 10,000 t CO2-e/yr.
For a monitoring period that is shorter or longer than twelve months, the project size band shall be determined by expressing the reported GHG emission mitigations for the monitoring period as an annualized quantity. The VVB may use the latest validated ex-ante estimate or monitored results from the client to determine the provisional band when planning the verification but shall confirm the applicable band using the final reported ex-post quantity before issuing the verification opinion.
The quantitative thresholds apply to overestimation of GHG emission mitigations. A misstatement resulting in an understatement, or a qualitative matter or non-conformity, shall not be considered immaterial solely because it does not result in an overestimation. The VVB shall evaluate such matters based on their nature, cause, extent, and potential to affect the GHG statement, conformity with the applicable criteria, issuance or conversion eligibility, or decisions of intended users.
The use of remote activities or techniques shall not change the applicable materiality threshold or reduce the VVB’s responsibility to identify material misstatements and material non-conformities.
**Materiality Considerations**
Materiality includes quantitative considerations related to the GHG statement and reported GHG emission mitigations.
Some ICR requirements are conformity requirements rather than quantitative materiality matters. Requirements relating to project eligibility, ownership, title, applicability conditions, additionality, safeguards, double counting, authorization, non-permanence, reversals, methodology applicability, or other issuance-relevant criteria shall not be disregarded solely because their effect on quantified GHG emission mitigations is below the quantitative materiality threshold.
Where ex-post additionality reporting is required, the VVB shall assess the completeness and support of the reporting in accordance with Section 6.3.1.1. A change identified through such reporting shall not, solely by reason of that change, be treated as a material misstatement or non-conformity.
Where a non-conformity with ICR requirements could affect registration, issuance, conversion, claims, ownership, environmental integrity, or the intended use of the opinion, the VVB shall evaluate the matter according to its nature, cause, effect, and relevance to the applicable ICR Program decision.
Uncertainties inherent in an applied methodology or identified in project documentation shall not be treated as misstatements solely because they exist. The VVB shall assess whether uncertainty has been identified, quantified or described where required, and treated in accordance with the applicable criteria, including conservativeness requirements.
Material errors, omissions, misrepresentations, and material non-conformities shall be addressed before the VVB issues an unmodified opinion. Non-material errors identified in project documentation or monitoring information should be corrected by the project proponent where feasible.
### Verification/Validation Team Selection
The VVB shall select a validation or verification team with competence appropriate to the engagement scope, objectives, criteria, risks, and complexity.
In addition to competence requirements under ISO 14065 and ISO 14066, the VVB shall consider whether the team has access to competence in the following areas, as applicable:
1. ICR Program requirements and procedures;
2. ISO 14064-2 project-level GHG accounting;
3. the applied methodology, sector, technology, and mitigation activity;
4. additionality assessment, including common practice, statutory, financial, policy, and barrier-based additionality;
5. baseline determination, including dynamic baselines and baseline updates;
6. monitoring systems, data quality, uncertainty, and QA/QC;
7. leakage, non-permanence, reversal risk, insurance, buffer, adjustment, and ongoing monitoring obligations;
8. ownership, title, double counting, claims, and Article 6.2 requirements, where applicable;
9. safeguards, other benefits, and stakeholder-related requirements, where applicable;
10. jurisdictional, legal, linguistic, market, and contextual factors relevant to the project or methodology;
11. methodology validation and scientific integrity, where applicable; and
12. remote activities and techniques, including evaluation of remotely obtained evidence, where such activities or techniques are used.
For methodology validation, the VVB shall ensure that the validation team has access to competence sufficient to assess the methodology’s scientific basis, applicability conditions, baseline approach, additionality procedures, quantification methods, monitoring provisions, uncertainty treatment, conservativeness, and future verifiability. Where necessary, the VVB shall use technical experts in accordance with its accredited procedures.
Where the VVB uses technical experts, the VVB shall manage their use under its accredited procedures and shall retain responsibility for the validation or verification conclusion.
The validation or verification report shall identify the validation or verification team and their respective roles. It shall summarize the basis on which the VVB determined that the team collectively possessed the competence necessary for the engagement, at a level sufficient to support ICR review.
Evidence supporting the competence determination may include relevant qualifications, documented sectoral or technical experience, experience in the host country or a comparable jurisdiction, demonstrated language capability, and the use of competent local or technical experts.
Qualified translation or interpretation may support communication and evidence gathering but shall not, by itself, be considered evidence of technical, legal, or jurisdictional competence.
Full curricula vitae or confidential personnel records are not required in the public report. The VVB shall retain supporting competence records and make them available to ICR upon request, subject to applicable confidentiality and personal data requirements.
Where personnel who participated in the validation of a project are proposed for a subsequent verification of the same project, including the first subsequent verification, the VVB shall identify and assess any resulting impartiality risks, including self-review and familiarity risks, before assigning those personnel. The VVB shall document the safeguards applied to reduce the identified risks to an acceptable level and shall not assign the personnel where this cannot be achieved.
Personnel who participated in the validation shall not perform the independent review of a subsequent verification of the same project. Where the verification requires reassessment of a matter for which such personnel were responsible during validation, that matter shall be assessed and concluded on by another competent member of the verification team who was not responsible for that matter during validation.
For a joint validation and verification engagement, the VVB shall appoint a team leader for each component. The same person may be appointed as team leader for both components where the VVB determines and documents that the person possesses the competence required to lead both components and that associated impartiality risks have been reduced to an acceptable level in accordance with the VVB’s accredited procedures.
The appointment of a common team leader shall not affect the requirement to maintain separately supported and clearly distinguished validation and verification objectives, criteria, scopes, findings, conclusions and opinions.
The joint validation and verification report shall identify the team leader for each component and, where the same person leads both components, summarize the basis for determining the person’s competence and the impartiality safeguards applied.
A verification team member shall not be involved in more than five consecutive verifications of the same project or in verifications covering, in aggregate, more than five years of monitoring for the same project, whichever occurs first, unless the VVB determines that continued involvement is necessary due to project complexity, the need for continuity, limited availability of suitably competent personnel, or a first verification covering more than five years. The monitoring period for the first verification may exceed five years. Where an exception is applied, the VVB shall document the justification and how familiarity risks are identified and managed in accordance with its accredited procedures and applicable ICR requirements.
During the validation or verification assessment, the validation or verification team shall have access to the project in the ICR registry platform.
### Verification/Validation Activities and Techniques
The VVB shall determine validation and verification activities and techniques in accordance with ISO 14064-3, this document, and its accredited procedures.
The activities and techniques selected shall be sufficient to address the applicable criteria, the risks identified by the VVB, and the intended use of the validation or verification opinion.
The VVB shall not rely solely on assertions by the project proponent, methodology developer, or other interested party where independent evidence is necessary to support the conclusion.
The VVB may use onsite, remote, or hybrid activities and techniques when conducting validation or verification, provided that the selected activities and techniques are suitable for the engagement objectives, scope, criteria, assessed risks, and required level of assurance where applicable.
Where activities or techniques are applied remotely, the VVB shall consider ISO 14064-5 and shall determine whether the remote activities or techniques can provide sufficient and appropriate evidence. Remote activities or techniques shall not be used as a substitute for onsite activities where onsite observation or inspection is necessary to address identified risks, applicable criteria, methodology requirements, or evidence limitations.
Use of remote or hybrid activities shall not change the engagement scope, applicable criteria, level of assurance, materiality threshold, or VVB responsibility for the validation or verification conclusion.
The VVB shall disclose the activities and techniques performed in the validation or verification report.
### Specific Requirements
#### Verifier/Validator Communication
The VVB shall communicate clarification requests, material misstatements, non-conformities, and other findings to the project proponent or methodology developer in a timely manner and in accordance with the VVB’s procedures and applicable ICR requirements.
The VVB shall communicate to ICR, without undue delay, any matter identified during the engagement that may indicate:
1. intentional misstatement;
2. fraud or serious misrepresentation;
3. material risk of over-crediting;
4. double counting or ownership conflict;
5. reversal or non-permanence event not appropriately reported;
6. material non-conformity with ICR requirements;
7. inability to obtain sufficient and appropriate evidence;
8. material limitation on the scope of the engagement;
9. material issue affecting authorization, corresponding adjustment, Article 6.2 claims, or other international transfer-related claims; or
10. material safeguard, other benefit, SDG contribution, complaint, grievance, incident, or claim-related issue that may affect conformity with ICR requirements or public claims.
The VVB shall use clarification requests, corrective action requests and forward action requests. The VVB shall document each finding, the basis for its classification, the response received and its resolution or status in the applicable ICR report.
For each forward action request, the VVB shall identify the matter to be followed up and the action, condition, evidence or trigger to be assessed during the subsequent engagement. A forward action request shall not be used to defer correction or resolution of a current misstatement, non-conformity, insufficiency of evidence or other matter affecting the current conclusion, opinion, project eligibility, registration, issuance or conversion.
Where unresolved matters may affect registration, issuance, conversion, methodology approval, claims, corresponding adjustment, reversal treatment, or ICR oversight, the VVB shall ensure that such matters are clearly identified in the validation or verification report or otherwise communicated to ICR through the applicable process.
#### Sufficiency of Evidence
The VVB shall obtain sufficient and appropriate evidence to support the validation or verification conclusion.
Evidence shall be relevant to the applicable criteria and sufficiently reliable to support the VVB’s professional judgement.
Where evidence is incomplete, inconsistent, unavailable, confidential, or subject to limitations, the VVB shall assess the effect on the conclusion and opinion.
Evidence obtained through remote activities or techniques shall be evaluated for sufficiency and appropriateness in the same manner as other evidence. Where remote evidence is incomplete, unreliable, not sufficiently traceable, or insufficient to address identified risks or applicable criteria, the VVB shall obtain additional evidence, revise the evidence-gathering approach, perform onsite activities where necessary, qualify the opinion, or decline to issue an opinion, as appropriate.
The VVB shall not issue an unmodified opinion where insufficient or inappropriate evidence prevents a conclusion on material aspects of the engagement.
#### Intentional Misstatement
Where the VVB identifies indicators of intentional misstatement, manipulation of data, omission of material information, misrepresentation of ownership or claims, deliberate overstatement of GHG emission mitigations, misrepresentation of Article 6.2 authorization or corresponding adjustment status, or other serious misrepresentation, the VVB shall evaluate the effect on the engagement conclusion and opinion.
The VVB shall communicate such matters to ICR without undue delay where they may affect project eligibility, registration, issuance, conversion, methodology approval, ownership, claims, authorization, corresponding adjustment or ICR oversight.
The VVB shall not issue an unmodified opinion where intentional misstatement or deliberate omission results in unresolved material misstatement or unresolved material non-conformity with applicable ICR criteria.
#### Documented Information
The VVB shall maintain documented information sufficient to demonstrate the basis for acceptance, planning, execution, review, conclusion, and issuance of the validation or verification opinion.
Documented information shall include, as applicable:
1. engagement type, objectives, criteria, and scope;
2. competence and impartiality considerations;
3. risk assessment and materiality considerations;
4. evidence reviewed and activities performed;
5. findings, non-conformities, clarification requests, and resolutions;
6. significant professional judgements;
7. conclusions on applicable ICR requirements;
8. independent review;
9. final opinion and report;
10. where remote activities or techniques were used, the rationale for their use, the evidence obtained, any limitations identified, and how the VVB addressed those limitations; and
11. where Article 6.2, authorization, corresponding adjustment, safeguards, other benefits, SDG contributions, or other claims are included in the engagement scope, the basis for the VVB’s conclusion on those matters.
The VVB shall upload the validation or verification plan, and any revised plan, to the ICR registry platform. Where the plan includes remote or hybrid activities that materially affect the evidence-gathering approach, the plan shall identify the purpose of those activities, the evidence expected, any limitations, and any contingency actions where the evidence obtained is insufficient.
#### Process for Completing a Verification/Validation
Before issuing the validation or verification opinion, the VVB shall confirm that:
1. the engagement objectives, criteria, and scope have been addressed;
2. sufficient and appropriate evidence has been obtained;
3. material findings and non-conformities have been resolved or appropriately reflected in the opinion;
4. the report transparently presents the basis for the conclusion;
5. the independent review has been completed in accordance with the VVB’s procedures;
6. the opinion type is consistent with the evidence and unresolved issues;
7. where remote or hybrid activities were used, any limitations affecting the sufficiency or appropriateness of evidence have been resolved or appropriately reflected in the report and opinion;
8. the report and opinion meet applicable ICR template and submission requirements; and
9. where authorization, corresponding adjustment, Article 6.2 claims, safeguards, other benefits, SDG contributions, ownership, double counting, or other claim-related matters are included in the engagement scope, unresolved issues have been evaluated for their effect on the report, opinion, and intended ICR Program decision.
Further requirements on project processes and the involvement of VVBs in the ICR project cycle are specified in the ICR Process Requirements.
## Verification
## Planning
### Strategic Analysis
#### General
The VVB shall perform the verification strategic analysis in accordance with ISO 14064-3, Section 5 of this document, and the VVB’s accredited procedures.
For ICR project verification, the strategic analysis shall consider, as applicable:
1. the project type, sector, technology, scale, location, and implementation context;
2. the applicable verification criteria, including ISO 14064-2, the ICR Requirement Document, other applicable ICR Program requirements, the applied approved methodology, module, tool, or methodological guidance where applicable, and the validated PDD, PDDMR, monitoring plan, or other validated project design documentation;
3. the monitoring period and GHG statement covered by the verification;
4. the results, assumptions, limitations, findings, and conclusions of the validation report and any previous verification reports;
5. project implementation status and any material differences from the validated project design;
6. the monitoring plan, monitored parameters, data sources, data controls, and data quality arrangements;
7. the quantification approach, including baseline, project, leakage, reversal, and net GHG emission mitigation calculations;
8. deviations, design changes, baseline updates, monitoring plan changes, or changes from prior monitoring periods;
9. ex-post additionality reporting required for the monitoring period, where applicable;
10. leakage and other secondary effects;
11. non-permanence, reversals, storage losses, post-crediting monitoring, insurance, buffer, or adjustment arrangements, where applicable;
12. ownership, title, double counting, and claims relevant to issuance or conversion;
13. safeguards, other benefits, SDG contributions, stakeholder comments, complaints, grievances, incidents, corrective actions, and related claims relevant to the monitoring period;
14. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims, where included in the monitoring report, PDDMR, registry submission, or verification scope;
15. grouped or bundled project structure, and any project instances included or monitored during the period;
16. public comments, ICR clarification requests, ICR review findings, registry information, media, or other public information relevant to the GHG statement;
17. whether sufficient and appropriate evidence is expected to be available; and
18. whether onsite, remote, or hybrid evidence-gathering activities are expected to be necessary to address the verification risks.
The results of the strategic analysis shall be used in the risk assessment and in determining the nature and extent of evidence-gathering activities.
The VVB shall document relevant outcomes from the strategic analysis in the verification report at a level sufficient to support the verification conclusion and ICR review.
For multiple project activities, bundled projects, grouped project activities, and included project instances, the VVB shall consider whether the project structure and monitored activities conform with the applicable ICR requirements and the validated project design. Where new project activity instances are included in a grouped project during verification, the VVB shall assess whether those instances conform with the validated eligibility criteria and applicable monitoring requirements.
#### Additional Requirements for Project GHG Statement Verification
For ICR project GHG statement verification, the VVB shall consider, as applicable:
1. the validated PDD, PDDMR, monitoring plan, validation report, and previous verification reports;
2. the monitoring report and supporting monitoring evidence for the monitoring period;
3. whether the project has been implemented in accordance with the validated project design;
4. whether the applied methodology, module, tool, or methodological guidance has been applied correctly during the monitoring period, where applicable;
5. whether monitored data and calculations support the reported GHG emission mitigations;
6. whether reported GHG emission mitigations are eligible for issuance or conversion under the ICR Program;
7. whether any change, deviation, data gap, reversal, non-permanence event, leakage event, or other matter affects the verification conclusion; and
8. whether authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims included in the monitoring report, PDDMR, registry submission, or verification scope are supported by sufficient and appropriate evidence and are consistent with applicable ICR requirements.
Where the project was validated without an approved methodology and relies on project-specific criteria and procedures, the VVB shall assess whether those validated criteria and procedures have been applied consistently during the monitoring period.
#### Additional Requirements for Product GHG Statement Verification
Product GHG statement verification is outside the scope of the ICR Program unless expressly accepted by ICR for a specific engagement. Product-related information included in project documentation shall be assessed only to the extent it is relevant to the project GHG statement, applicable ICR criteria, safeguards, other benefits, or claims included in the verification scope.
### Risk Assessment
#### General
The VVB shall perform a verification risk assessment in accordance with ISO 14064-3, Section 5 of this document, and the VVB’s accredited procedures.
For ICR project verification, the VVB shall identify risks of material misstatement and risks of non-conformity with applicable verification criteria.
The risk assessment shall consider, as applicable:
1. risk that reported GHG emission mitigations are overstated;
2. risk that the project has not been implemented in accordance with the validated project design;
3. risk that monitored data are incomplete, inaccurate, unsupported, or not traceable;
4. risk that the monitoring plan has not been implemented as validated;
5. risk that quantification methods, parameters, emission factors, default values, or models have not been applied correctly;
6. risk that baseline updates, dynamic baseline calculations, or changes from prior periods are incorrect or unsupported;
7. risk that leakage or other secondary effects are omitted or understated;
8. risk that reversals, storage losses, non-permanence events, or post-crediting obligations are not identified, monitored, quantified, or reported;
9. risk that required ex-post additionality reporting is incomplete or unsupported, or that a change relevant to crediting-period renewal is not disclosed; and risk that a separate non-conformity with another applicable criterion may affect baseline validity, project eligibility or issuance eligibility;
10. risk that ownership, title, double counting, or claims are not adequately supported;
11. risk that safeguards, other benefits, SDG contributions, complaints, incidents, corrective actions, or related claims reported for the monitoring period are incomplete, inconsistent with the validated project design, or not supported by sufficient and appropriate evidence;
12. risk that authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims are incomplete, unsupported, inconsistent with authorization documentation, or inconsistent with applicable ICR requirements;
13. risk that grouped project instances or bundled project activities do not conform with eligibility criteria or monitoring requirements;
14. risk arising from reliance on estimates, sampling, indirect measurements, remote sensing, models, or third-party datasets;
15. risk arising from changes in law, regulation, policy, market conditions, technology adoption, operational conditions, or project control; and
16. risk arising from the use of remote activities or techniques, where such activities or techniques are planned or relied upon.
Qualitative risks identified by the VVB shall be addressed in verification planning and, where material to the conclusion, summarized in the verification report.
The VVB shall set performance materiality below the applicable ICR quantitative materiality threshold, in accordance with ISO 14064-3 and its accredited procedures, taking account of the assessed verification risks. Performance materiality shall be used to plan and perform the verification and does not replace or alter the applicable ICR materiality threshold.
#### Types of Risks
The VVB shall consider inherent risk, control risk, and detection risk in the context of the ICR project, monitoring system, GHG statement, and applicable verification criteria.
Inherent risks may arise from the nature of the project activity, complexity of GHG SSRs, uncertainty in baseline or project data, use of estimates or models, non-permanence risk, leakage, project-level discretion, or complexity of the applied methodology.
Control risks may arise from weaknesses in monitoring procedures, data controls, calibration, data aggregation, record retention, roles and responsibilities, project instance management, or oversight of third-party data.
Detection risks may arise from limitations in evidence availability, sampling, remote assessment, monitoring frequency, access restrictions, dispersed project activities, or complex data systems.
The VVB shall design evidence gathering activities to reduce verification risk to an acceptable level consistent with the agreed level of assurance and materiality.
#### Risk Assessment Considerations
When the project applies an approved methodology, module, tool, or methodological guidance, the VVB may consider the methodology’s specified monitoring, quantification, uncertainty, leakage, data quality, and risk treatment requirements in determining verification risks.
The VVB shall not reduce the extent of risk assessment solely because a methodology has been applied. The VVB shall assess whether the methodology has been applied correctly and whether project-specific circumstances create additional risks.
Where the project relies on project-specific criteria and procedures, the VVB shall assess whether the project proponent has applied those criteria and procedures consistently with the validated project design and applicable ICR requirements.
The VVB shall consider heightened verification risk where:
1. the project has material deviations or design changes;
2. the project applies dynamic baselines or baseline updates;
3. monitored parameters are estimated, modelled, sampled, or indirectly measured;
4. data gaps, missing records, substitutions, or conservative assumptions are used;
5. the project includes multiple sites, grouped project activities, or dispersed project instances;
6. the project involves non-permanence, reversal risk, storage, biological carbon pools, or long-term monitoring obligations;
7. ownership, title, double counting, or claims depend on third-party documentation;
8. the monitoring report identifies material changes relevant to additionality, baseline validity, or eligibility;
9. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims depend on host country documentation, registry treatment, third-party information, or post-issuance action;
10. remote activities or techniques are planned for material evidence-gathering activities; or
11. the VVB identifies limitations in access to sites, personnel, source records, digital systems, or other evidence necessary to support the verification conclusion.
#### Information Sources for Risk Assessment
Information sources for risk assessment may include, as applicable:
1. validated PDD, PDDMR, monitoring plan, and validation report;
2. previous monitoring reports and verification reports;
3. monitoring records, measurement data, calibration records, QA/QC records, and data aggregation files;
4. spreadsheets, models, datasets, emission factors, default values, or parameter calculations;
5. site records, operational records, production data, energy data, land-use records, inventory records, or other activity data;
6. evidence of ownership, title, authorization, contracts, leases, benefit-sharing, or right to claim;
7. evidence relating to reversals, storage losses, non-permanence events, insurance, buffer, or adjustment arrangements;
8. evidence relating to safeguards, stakeholder comments, grievances, or other benefits where included in the verification scope;
9. evidence relating to host country authorization, corresponding adjustment, Article 6.2 eligibility, authorized uses, vintages, quantity limits, or other international transfer-related claims, where included in the verification scope;
10. regulatory, policy, market, or sectoral information relevant to ex-post additionality reporting or baseline updates;
11. ICR review findings, clarification requests, registry information, public comments, and media or other public information relevant to the GHG statement; and
12. interviews, site visit observations, remotely obtained evidence, remote sensing, photographs, geospatial data, or other independent evidence.
#### Additional Requirements for Project GHG Statement Verification
The VVB shall assess the risk that the reported GHG emission mitigations for the monitoring period are not materially correct or are not eligible for issuance or conversion.
The risk assessment shall consider whether:
1. all monitored parameters required by the validated monitoring plan have been reported;
2. monitored parameters are supported by sufficient and appropriate evidence;
3. calculations have been performed in accordance with the applicable criteria;
4. data gaps, substitutions, estimates, or conservative adjustments are justified and correctly applied;
5. changes from the validated project design affect the GHG statement or conformity with criteria;
6. events during the monitoring period affect leakage, non-permanence, reversals, safeguards, ownership, title, double counting, or claims;
7. any material matter requires reassessment, validation of a design change, ICR clarification, correction, or qualification of the verification opinion; and
8. any Article 6.2, corresponding adjustment, authorization, or international transfer-related claims included in the monitoring report, PDDMR, registry submission, or verification scope are complete, supported, and consistent with applicable ICR requirements.
#### Additional Requirements for Product GHG Statement Verification
No additional ICR-specific requirements apply. Product GHG statement verification is outside the scope of ICR project verification unless expressly accepted by ICR for a specific engagement.
#### Uses for Risk Assessment Information
The VVB shall use the risk assessment to determine the nature and extent of evidence-gathering activities, including document review, interviews, recalculation, sampling, control testing, analytical procedures, site visits, remote activities or techniques, or technical expert input.
Where remote activities or techniques are planned, the VVB shall consider ISO 14064-5 when evaluating whether the planned evidence-gathering approach is sufficient to address identified risks.
Where risks relate to conformity matters that are not solely quantitative, the VVB shall design evidence-gathering activities sufficient to support a conclusion on conformity with the applicable criteria, even where the matter does not directly affect the quantified GHG statement.
Where, during risk assessment or verification, the VVB identifies concerns that an applied methodology, project-specific procedure, data source, model, or assumption may not be scientifically credible, technically appropriate, or consistent with applicable ICR requirements, the VVB shall evaluate the effect on the verification conclusion and, where appropriate, communicate the matter to ICR.
Where ex-post additionality reporting is required, the VVB shall consider the risk that the reporting is incomplete, unsupported, or fails to disclose information relevant to crediting-period renewal. The treatment of any reported change shall be determined in accordance with Section 6.3.1.1.
### Evidence-Gathering Activities
#### General
The VVB shall design evidence-gathering activities in accordance with ISO 14064-3, the verification plan, the evidence-gathering plan, this document, and its accredited procedures.
For ICR project verification, evidence-gathering activities shall be sufficient to support conclusions on:
1. project implementation in accordance with the validated project design;
2. monitoring plan implementation;
3. data quality, data trail, and information controls;
4. reported GHG emission mitigations for the monitoring period;
5. conformity with ISO 14064-2, the ICR Requirement Document, the applied approved methodology where applicable, and the validated PDD, PDDMR, or monitoring plan;
6. eligibility of reported GHG emission mitigations for issuance or conversion;
7. safeguards, other benefits, SDG contributions, incidents, corrective actions, and related claims reported in the monitoring report, PDDMR, ESES-SD monitoring information, or other project documentation submitted for verification;
8. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims included in the monitoring report, PDDMR, registry submission, or verification scope; and
9. material qualitative issues affecting verification.
The VVB shall not rely solely on declarations by the project proponent where independent or corroborating evidence is necessary to support the conclusion.
#### Data Trail
The VVB shall assess whether the data trail is complete and traceable from primary data sources to the reported GHG emission mitigations.
The VVB shall assess, as applicable:
1. source records for monitored parameters;
2. transfer of data from source records to monitoring records;
3. aggregation of data across systems, sites, project instances, or time periods;
4. application of units, conversions, emission factors, parameters, and formulas;
5. calculations of baseline emissions or removals, project emissions or removals, leakage, reversals, deductions, and net GHG emission mitigations; and
6. version control and consistency between the monitoring report, spreadsheets, models, registry uploads, and supporting documents.
Where safeguards, other benefits, SDG contributions, or related claims rely on monitored quantitative information, the VVB shall assess the traceability of that information to the extent necessary to support the verification conclusion on those claims.
Where the VVB identifies breaks in the data trail, it shall assess the effect on the GHG statement and the verification opinion.
#### GHG Information System and Controls
The VVB shall assess whether the GHG information system and controls have been implemented as described in the validated monitoring plan and are effective for the monitoring period.
The VVB shall assess, as applicable:
1. roles and responsibilities for data collection, review, approval, and reporting;
2. monitoring procedures and frequency;
3. calibration, maintenance, and accuracy of measurement equipment;
4. QA/QC procedures;
5. controls over spreadsheets, models, data systems, and manual calculations;
6. treatment of data gaps, missing data, outliers, substitutions, and conservative adjustments;
7. record retention and availability of evidence;
8. controls over third-party data, remote sensing data, laboratory data, supplier data, or externally managed datasets;
9. controls for grouped projects, multiple sites, or dispersed project instances; and
10. controls for dynamic baseline updates, reversal monitoring, or long-term monitoring obligations, where applicable.
#### GHG Data and Information
The VVB shall assess whether GHG data and information for the monitoring period are accurate, complete, consistent, conservative where required, and supported by sufficient and appropriate evidence.
The VVB shall assess, as applicable:
1. monitored activity data;
2. baseline data;
3. project emissions or removals data;
4. leakage or affected SSR data;
5. reversal, storage loss, or non-permanence data;
6. emission factors, removal factors, GWP values, parameters, default values, and model inputs;
7. uncertainty estimates, conservative adjustments, and deductions; and
8. evidence supporting qualitative claims relevant to the verification criteria.
Qualitative claims shall be assessed only to the extent they are included in applicable criteria, the monitoring report, PDDMR, registry submission, or other project documentation submitted for verification.
#### Data Aggregation Process
The VVB shall assess whether data aggregation has been performed correctly and consistently across the monitoring period, project sites, project instances, technologies, activities, or data streams.
The VVB shall assess, as applicable:
1. aggregation of primary data into monitored parameters;
2. aggregation of project, baseline, leakage, and reversal quantities;
3. treatment of partial periods, commissioning dates, shutdowns, interruptions, and operational changes;
4. treatment of project instance inclusion dates or exclusion dates;
5. consistency between aggregation rules and the applied methodology or validated project-specific procedures; and
6. prevention of double counting within the project boundary or across project instances.
#### Application of Selected Verification Activities and Techniques
**Analytical Testing**
Where analytical testing is used, the VVB should assess whether trends, ratios, expected values, prior-period comparisons, and other analytical results are reasonable in light of the project activity, monitoring period, and validated project design.
The VVB shall investigate material unexpected changes, including changes in activity levels, mitigation rates, leakage, reversal indicators, baseline parameters, or data quality.
**Control Testing**
Where control testing is used, the VVB shall assess whether controls relevant to the GHG statement operated effectively during the monitoring period.
Control testing may address, as applicable:
1. data capture and transfer;
2. meter calibration and maintenance;
3. spreadsheet and model controls;
4. review and approval controls;
5. access controls and version control;
6. controls over third-party data;
7. controls over project instance data;
8. controls over reversal, leakage, or non-permanence monitoring;
9. controls over authorization, corresponding adjustment, Article 6.2 or other claim-related documentation where relevant to the verification scope.
**Estimate Testing**
Where estimates are used, the VVB shall assess whether the estimate is justified, conservative where required, and consistent with the applicable criteria.
The VVB shall assess, as applicable:
1. basis and method for the estimate;
2. data sources and assumptions;
3. uncertainty and sensitivity;
4. consistency with prior periods;
5. whether the estimate is permitted by the methodology, validated monitoring plan, or ICR requirements; and
6. whether conservative adjustment is required.
**Sampling**
Where sampling is used, the VVB shall assess whether the sampling approach is appropriate for the population, materiality, risk, variability, and intended use of the GHG statement.
When sampling relies on remote sensing, geospatial analysis, forest inventories, or other indirect evidence, the VVB shall assess the suitability, whether the data and sampling approach are appropriate, reliable, and sufficient to support the verification conclusions and limitations of the sampling approach and associated datasets.
*Multiple project activities*
For multiple project activities, the VVB shall assess whether the sampling approach supports conclusions on eligibility, monitoring implementation, data quality, and GHG emission mitigations across the included project activities or instances.
The sample shall be representative of the population and determined using a combination of risk-based and random selection, where appropriate.
Where sampling is used to draw conclusions across a population of grouped project activities, multiple sites, or project instances, the minimum sample size shall be the square root of the relevant population (√N), rounded up to the next whole number, where N is the total number of project activities, sites, or instances within the population to which the conclusion will be applied.
The minimum sample size is a sampling floor and shall not be interpreted as demonstrating that the sample is sufficient. The VVB shall increase the sample where required by the verification risk assessment, population variability, geographic dispersion, differences in technology or implementation, data quality, monitoring arrangements, previous sampling coverage, or other relevant circumstances. Where an applicable methodology, ICR requirement, statistical calculation, or the VVB’s accredited procedures requires a larger sample, the larger sample shall be used.
Where the population contains materially different categories, the VVB shall stratify the population or otherwise ensure that each material category is adequately represented in the sample.
Where a non-conformity identified in the sample indicates potential systemic non-conformity, the VVB shall assess whether additional sampling, broader evidence-gathering, correction, or further program action is required.
Where sampling is applied to grouped project activities, multiple sites, or project instances, the VVB shall document the basis for the sampling approach and whether the sample supports conclusions on both GHG emission mitigations and applicable conformity matters.
The minimum sample size determines the number of project activities, sites, or instances subject to detailed assessment. Whether that assessment requires an in-person site or facility visit, or may be conducted using activities and techniques applied remotely, shall be determined separately in accordance with Section 6.1.4.
The VVB shall document the basis for the sampling approach in accordance with its accredited procedures.
**Evaluation of Ownership**
The VVB is not responsible for issuing a legal opinion on ownership, title, or the legal right to GHG emission mitigations. However, the VVB shall assess whether the project proponent has provided sufficient and appropriate evidence to support ownership, title, authorization, or right to claim the GHG emission mitigations reported for the monitoring period.
Evidence may include, as applicable:
1. issuance or authorization by a competent authority;
2. rights obtained in accordance with applicable law;
3. statutory, property, contractual, or other enforceable rights over the plant, equipment, process, land, vegetation, conservation activity, management process, or other asset or activity that generates the GHG emission mitigations;
4. enforceable agreements transferring the right to claim GHG emission mitigations to the project proponent;
5. evidence of land tenure, leases, concessions, benefit-sharing arrangements, or other relevant rights; and
6. evidence of authorization, corresponding adjustment, or claim-related arrangements, where applicable.
Where Article 6.2 eligibility, corresponding adjustment treatment, or other international transfer-related claims are included in the verification scope, evidence may also include host country authorization, attestation, authorized uses, vintages, quantity limits, registry information, or other documentation required under applicable ICR requirements.
The VVB shall assess whether any change during the monitoring period affects ownership, authorization, benefit-sharing, land tenure, contractual rights, or claims to the GHG emission mitigations.
The VVB shall assess whether there is evidence of double counting, competing claims, duplicate registration, duplicate issuance, or issuance under another GHG program for the same GHG emission mitigations.
Where the VVB identifies unresolved ownership, title, authorization, claim, or double counting issues, it shall assess the effect on issuance or conversion eligibility and the verification opinion.
The VVB’s assessment of authorization, corresponding adjustment, or international transfer-related claims shall not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
### Site Visits
The VVB shall determine whether site or facility visits are necessary based on the verification risk assessment, project type, monitoring arrangements, data quality, materiality, prior verification results, and availability and reliability of other evidence.
Remote activities and techniques may support site or facility selection and may supplement evidence-gathering. Remote activities and techniques shall not be used as a substitute for a site or facility visit where onsite observation or inspection is necessary to obtain sufficient and appropriate evidence.
Where remote activities or techniques are used in connection with site or facility assessment, the VVB shall consider ISO 14064-5.
#### Site and Facility Selection
Where a project includes multiple sites, grouped project activities, or dispersed project instances, the VVB shall justify the number of site or facility visits and the site or facility selection approach in accordance with its accredited procedures.
The minimum sample size established in Section 6.1.3.6.4 determines the minimum number of project activities, sites, or instances subject to detailed assessment. It does not, by itself, determine the number of in-person site or facility visits. The VVB shall determine the number and selection of sites or facilities to be visited in person based on the verification risk assessment and whether sufficient and appropriate evidence can be obtained without on-site observation or inspection.
The selection shall consider, as applicable:
1. material contribution to reported GHG emission mitigations;
2. risk of data error or non-conformity;
3. new or changed sites or project instances;
4. geographic, technological, operational, or management diversity;
5. prior findings, data gaps, reversals, leakage, complaints, or ICR review findings; and
6. feasibility and reliability of evidence available without a site or facility visit.
#### Circumstances Requiring a Site or Facility Visit
A site or facility visit shall be performed where the VVB determines that document review, remote activities, or other evidence-gathering activities are not sufficient to obtain sufficient and appropriate evidence for material matters.
Circumstances that may indicate the need for a site or facility visit include, as applicable:
1. first verification after project registration;
2. material change from the validated project design;
3. material data gaps or unresolved inconsistencies;
4. significant changes in monitoring systems, ownership, operation, or project control;
5. inclusion of new project instances under a grouped project;
6. reliance on physical measurement systems or site-specific controls that cannot be adequately assessed without onsite observation;
7. reported or suspected reversal, non-permanence event, leakage event, or safeguard issue;
8. prior verification findings or ICR review findings indicating elevated risk;
9. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims, where included in the verification scope; and
10. unexplained material changes in reported GHG emission mitigations, including changes from the validated project design or prior verification periods.
The VVB may justify not performing a site or facility visit where it determines that sufficient and appropriate evidence can be obtained through other means. The rationale shall be documented in the verification report or supporting verification records.
#### Activities to Perform During Site Visits
The VVB shall determine site visit activities in accordance with the risk assessment and evidence-gathering plan.
Site visit activities may include, as applicable:
1. inspection of project implementation and operating conditions;
2. observation of monitoring equipment, measurement systems, or data collection processes;
3. review of primary records and local data systems;
4. interviews with responsible personnel or relevant stakeholders;
5. confirmation of project boundaries, project instances, or activity locations;
6. assessment of control implementation;
7. observation of safeguards, leakage, reversal, or non-permanence indicators where relevant;
8. reconciliation of site-level data with the monitoring report;
9. confirmation of ownership, title, project control, or other evidence supporting the right to claim GHG emission mitigations, where relevant;
10. observation of stakeholder engagement processes, grievance mechanisms, or community-related project activities, where relevant.
### Verification Plan
The VVB shall develop a verification plan in accordance with ISO 14064-3 and its accredited procedures. The verification plan shall be revised as necessary during verification.
The verification plan shall address the verification objectives, criteria, scope, level of assurance, materiality threshold, conformity matters, and significant verification risks.
The verification plan shall be sufficient to support conclusions on:
1. project implementation against the validated project design;
2. monitoring plan implementation;
3. data trail and GHG information controls;
4. reported GHG emission mitigations;
5. deviations, design changes, baseline updates, or changes from prior periods;
6. leakage, reversals, non-permanence, and adjustments where applicable;
7. ownership, title, double counting, safeguards, and claims where applicable; and
8. eligibility for issuance or conversion.
The VVB shall upload the final verification plan, and any revised verification plan, to the ICR registry platform. The verification plan is not intended for public disclosure.
### Evidence-Gathering Plan
The VVB shall develop an evidence-gathering plan in accordance with ISO 14064-3 and its accredited procedures.
The evidence-gathering plan shall specify evidence-gathering activities sufficient to support the verification conclusion.
The plan shall address, as applicable:
1. data sources and records to be tested;
2. parameters, calculations, models, and data streams to be assessed;
3. sampling approach, where applicable;
4. site visits, interviews, observations, recalculations, control testing, analytical testing, remote activities or techniques, or other techniques to be used;
5. evidence for deviations, design changes, baseline updates, data gaps, reversals, leakage, safeguards, ownership, double counting, and claims;
6. evidence for ex-post additionality reporting, where required;
7. evidence for authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims, where included in the verification scope; and
8. technical expert input, where used.
Where remote activities or techniques are used for material evidence-gathering activities, the VVB shall consider ISO 14064-5 and assess whether the planned activities can provide sufficient and appropriate evidence for the identified risks and applicable criteria.
The evidence-gathering plan is not required to be uploaded to the ICR registry platform unless requested by ICR or required under another applicable ICR process.
### Approval of Verification and Evidence-Gathering Plans
The VVB shall approve the verification plan and evidence-gathering plan in accordance with ISO 14064-3 and the VVB’s accredited procedures.
Amendments to the verification plan and evidence-gathering plan shall be approved in accordance with ISO 14064-3 and the VVB’s accredited procedures.
Any plan submitted to ICR shall be the version approved under the VVB’s procedures.
## Execution
The VVB shall perform verification activities in accordance with ISO 14064-3, the approved verification plan, and the evidence-gathering plan, as amended where necessary.
During execution, the VVB shall evaluate whether sufficient and appropriate evidence supports:
1. conformity of project implementation with the applicable verification criteria;
2. correct implementation of the validated monitoring plan;
3. completeness, accuracy, and traceability of monitored data;
4. correctness of calculations and quantified GHG emission mitigations;
5. eligibility of reported GHG emission mitigations for issuance or conversion; and
6. resolution or proper treatment of findings, non-conformities, data gaps, deviations, design changes, reversals, leakage, ownership issues, or other material matters.
Where included in the verification scope, sufficient and appropriate evidence shall also support conclusions on safeguards, other benefits, SDG contributions, authorization, corresponding adjustment, Article 6.2 eligibility, and related claims.
Where remote activities or techniques are used during execution, the VVB shall evaluate whether they operate as planned and provide sufficient and appropriate evidence. Where remote activities or techniques are insufficient, the VVB shall amend the evidence-gathering plan, obtain additional evidence, perform onsite activities where necessary, or reflect the limitation in the verification conclusion and opinion.
The VVB shall classify and document findings raised during verification in accordance with Sections 3 and 5.4.1. Each finding, the response received, its resolution, and the status of any forward action request shall be documented in the applicable ICR verification report or validation and verification report.
The VVB shall evaluate corrective actions and revised documentation before issuing the verification opinion.
Where the VVB identifies a matter that may materially affect issuance or conversion eligibility, the VVB shall report the matter clearly and, where required under Section 5.4.1, communicate it to ICR without undue delay.
## Completion
### Evaluation of the GHG Statement
#### Evaluation of Changes
The VVB shall evaluate changes during the monitoring period and determine whether they affect the GHG statement, conformity with criteria, or eligibility for issuance or conversion.
Changes may include, as applicable:
1. deviations from the validated project design;
2. design changes;
3. changes in project boundary, project activity, operating conditions, ownership, or project control;
4. changes in monitoring plan implementation or data systems;
5. baseline updates or dynamic baseline recalculations;
6. changes in emission factors, parameters, models, default values, or calculation procedures;
7. changes reported through ex-post additionality reporting, where required by applicable ICR requirements;
8. inclusion of new project instances under a grouped project;
9. reversals, storage losses, non-permanence events, or leakage events;
10. changes in regulatory, policy, market, or technology context relevant to the GHG statement; and
11. changes in authorization status, corresponding adjustment treatment, Article 6.2 eligibility, or other international transfer-related claims, where included in the verification scope.
Except as provided below for ex-post additionality reporting, where the VVB determines that a change materially affects the validated project design, baseline, additionality, methodology applicability, monitoring plan, quantification approach, or issuance eligibility, the VVB shall evaluate whether re-validation, validation of a design change, ICR clarification, correction, or a modified verification opinion is required.
The VVB shall consider public comments, ICR review findings, and other relevant information where they may affect the GHG statement, conformity with applicable criteria, or issuance or conversion eligibility.
**Additionality**
Where ex-post additionality reporting is required, the VVB shall assess whether the reporting is complete and supported in accordance with the ICR Additionality Specifications. Any resulting change in additionality status shall be disclosed but shall not reopen the additionality determination made at registration or affect project eligibility, continued issuance or the verification opinion during the established crediting period. The information shall be considered at crediting period renewal. Any separate non-conformity with another applicable criterion shall be assessed independently.
**Multiple project activities**
For bundled project activities, the VVB shall state its conclusion on conformity of the bundled project activities with the applicable criteria and describe the evidence-gathering activities performed to support that conclusion.
For added project instances under grouped project activities, the VVB shall state its conclusion on conformity with the validated eligibility criteria and applicable monitoring requirements, and describe the evidence-gathering activities performed to support that conclusion.
#### Evaluation of Sufficiency and Appropriateness of Evidence
The VVB shall evaluate whether sufficient and appropriate evidence has been obtained to support the verification conclusion.
The VVB shall not issue an unmodified verification opinion where evidence is insufficient to conclude on material aspects of:
1. monitored data;
2. calculations;
3. monitoring plan implementation;
4. conformity with the applied methodology or validated project-specific criteria;
5. deviations or design changes;
6. leakage, reversals, non-permanence, or adjustments;
7. ownership, title, double counting, or issuance eligibility; or
8. safeguards, other benefits, SDG contributions, authorization, corresponding adjustment, Article 6.2 eligibility, or related claims included in the verification scope.
#### Evaluation of Material Misstatements
The VVB shall evaluate identified misstatements, individually and in aggregate, against the quantitative materiality threshold and applicable conformity considerations.
The VVB shall assess whether misstatements affect:
1. reported GHG emission mitigations;
2. issuance or conversion eligibility;
3. baseline validity;
4. methodology applicability;
5. leakage or reversal deductions;
6. ownership, title, or double counting;
7. safeguards or other claims within the verification scope; or
8. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims within the verification scope.
Where corrected and uncorrected misstatements are identified, the VVB shall evaluate whether remaining misstatements are material to the GHG statement or the intended use of the verification opinion.
#### Evaluation of Conformity with Criteria
The VVB shall evaluate whether the project implementation and GHG statement for the monitoring period conform with the applicable verification criteria identified under Section 5.1.5.
For ICR project verification, the VVB shall determine whether:
1. the project has been implemented in accordance with the validated PDD, PDDMR, monitoring plan, and other validated project design documentation;
2. the project implementation and reported GHG emission mitigations conform with ISO 14064-2;
3. the project implementation and reported GHG emission mitigations conform with the ICR Requirement Document and other applicable ICR Program requirements;
4. the applied approved methodology, module, tool, or methodological guidance has been applied correctly, where applicable;
5. the validated project-specific criteria and procedures have been applied correctly where no approved methodology applies;
6. the monitoring plan has been implemented as validated, including monitoring frequency, measurement methods, QA/QC, calibration, data management, record retention, and treatment of data gaps;
7. monitored data are complete, traceable, and supported by sufficient and appropriate evidence;
8. baseline, project, leakage, reversal, and net GHG emission mitigation calculations have been performed in accordance with the applicable criteria;
9. deviations, design changes, monitoring plan changes, baseline updates, or changes from prior periods have been identified, justified, and assessed for their effect on conformity with criteria and the GHG statement;
10. dynamic baseline updates, where applicable, have been performed using validated update triggers, data sources, calculation procedures, timing, and monitoring requirements;
11. ex-post additionality reporting required for the monitoring period has been completed and supported, and any reported change has been evaluated in accordance with the ICR Additionality Specifications and applicable ICR requirements;
12. leakage and other secondary effects have been monitored, quantified, deducted, or justified in accordance with the applicable criteria;
13. non-permanence events, reversals, storage losses, post-crediting monitoring obligations, insurance, buffer, or adjustment arrangements have been addressed, where applicable;
14. ownership, title, right to claim, and double counting controls remain sufficient for issuance or conversion;
15. safeguards, other benefits, SDG contributions, incidents, complaints, corrective actions, and related claims reported for the monitoring period are consistent with the validated project design, ESES-SD assessment, monitoring report or PDDMR, and applicable ICR requirements;
16. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims included in the monitoring report, PDDMR, registry submission, or verification scope are supported by sufficient and appropriate evidence and are consistent with applicable ICR requirements;
17. grouped or bundled project activities, including included project instances, conform with applicable eligibility, monitoring, and data quality requirements;
18. the reported GHG emission mitigations are materially correct for the monitoring period; and
19. the reported GHG emission mitigations are eligible for issuance or conversion under the ICR Program.
Where the VVB identifies non-conformity with the applicable verification criteria, the VVB shall evaluate whether the matter results in a material misstatement, affects eligibility for issuance or conversion, requires correction, requires validation of a design change, requires ICR clarification, or affects the verification opinion.
The VVB shall not issue an unmodified verification opinion where unresolved non-conformity materially affects the GHG statement, conformity with criteria, or eligibility for issuance or conversion.
For projects validated using project-specific criteria and procedures, references to methodology in this section include the validated project-specific criteria and procedures established for baseline determination, project emissions or removals, leakage, quantification, monitoring, data quality, uncertainty, and other relevant project design elements.
Where ESES-SD monitoring information, the monitoring report, or PDDMR identifies adverse impacts, incidents, complaints, ineffective mitigation measures, or material changes in safeguard risk, the VVB shall assess whether these matters have been reported and addressed and whether they affect conformity with applicable ICR requirements, issuance eligibility, claims, or the verification opinion.
The VVB shall not verify broad ESG or sustainable-development claims beyond the applicable ICR requirements and the claims included in the monitoring report, PDDMR, ESES-SD monitoring information, or other project documentation submitted for verification.
The VVB’s assessment of Article 6.2, authorization, corresponding adjustment, or other international transfer-related claims shall support the verification conclusion but shall not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
#### Evaluation of Changes from Prior Periods
The VVB shall evaluate changes from prior monitoring periods and previous verification conclusions.
The evaluation shall consider, as applicable:
1. changes in reported mitigation outcomes;
2. recurring findings or unresolved issues from prior verifications;
3. changes in data systems, monitoring procedures, project boundaries, activity levels, or operating conditions;
4. changes in baseline parameters, dynamic baseline updates, emission factors, or models;
5. changes in leakage, reversal, or non-permanence risk;
6. changes reported through ex-post additionality reporting, where required by applicable ICR requirements;
7. changes in ownership, title, double counting risk, safeguards, or claims; and
8. changes in authorization, corresponding adjustment treatment, Article 6.2 eligibility, or other international transfer-related claims, where included in the verification scope.
Where deviations are applied, the VVB shall assess whether the deviation is appropriately described and justified and whether it affects the relevance of the established criteria and procedures, the project’s additionality, the suitability of the baseline scenario, the monitoring plan, reported GHG emission mitigations, or conformity with applicable criteria.
The process, findings, and conclusions of the assessment of deviations shall be addressed in the verification report. Where a deviation remains relevant to future monitoring periods, it shall also be addressed in subsequent verification reports.
### Conclusion and Draft Opinion
#### General
The VVB shall evaluate whether the evidence obtained supports the verification conclusion and draft opinion.
The VVB shall conclude whether:
1. the reported GHG emission mitigations are materially correct for the monitoring period;
2. the project has been implemented in conformity with the applicable verification criteria;
3. the reported GHG emission mitigations are eligible for issuance or conversion under the ICR Program;
4. any unresolved issue affects the opinion, issuance eligibility, or usefulness of the GHG statement.
Where authorization, corresponding adjustment, Article 6.2 eligibility, safeguards, other benefits, SDG contributions, or other claims are included in the verification scope, the VVB shall conclude whether unresolved issues relating to those matters affect the opinion, issuance or conversion eligibility, claims, or the intended use of the verification report.
#### Unmodified Opinion
The VVB may issue an unmodified verification opinion only where sufficient and appropriate evidence supports the conclusion that:
1. the reported GHG emission mitigations are materially correct;
2. the project conforms with the applicable verification criteria;
3. material findings and non-conformities have been resolved; and
4. no unresolved material limitation affects issuance or conversion eligibility.
A quantified misstatement below the applicable materiality threshold may remain uncorrected within an unmodified opinion where the VVB determines that the misstatement is not qualitatively material, individually or in aggregate, and does not constitute an unresolved non-conformity with the applicable criteria.
Where claim-related matters are included in the verification scope, no unresolved material limitation shall affect the reliability of those claims for the intended use of the verification report.
The VVB shall use the applicable ICR report template and standard opinion wording, where required.
#### Modified Opinion
Where the VVB issues a modified opinion, the opinion and verification report shall clearly describe:
1. the matter giving rise to the modification;
2. the affected criteria, monitoring period, data, calculations, or project elements;
3. whether the matter affects the reported GHG emission mitigations;
4. whether the matter affects issuance or conversion eligibility;
5. the extent to which the usefulness of the GHG statement is impaired; and
6. whether the matter affects authorization, corresponding adjustment, Article 6.2 eligibility, safeguards, other benefits, SDG contributions, or other claims included in the verification scope.
A modified opinion may be issued only where the VVB has obtained sufficient and appropriate evidence, the GHG statement is not materially misstated, and the matter giving rise to the modification is confined and does not prevent the VVB from concluding that the applicable eligibility and issuance criteria have been met. A modified opinion shall not be used as an alternative to closing a CAR or CL necessary to establish conformity with the applicable criteria or the sufficiency of evidence.
The VVB shall use the applicable ICR report template and standard opinion wording, where required, and shall adapt the wording only to the extent necessary to clearly describe the modification.
#### Adverse Opinion
The VVB shall issue an adverse opinion where an unresolved material misstatement or material non-conformity remains, including where the project does not meet an applicable eligibility or issuance criterion. A matter may be qualitatively material irrespective of whether its quantified effect is below the applicable materiality threshold.
The VVB shall communicate the adverse opinion to ICR without undue delay.
#### Disclaiming the Issuance of an Opinion
Where the VVB is unable to obtain sufficient and appropriate evidence to support a verification conclusion, the VVB shall disclaim the issuance of an opinion in accordance with its accredited procedures and the applicable ICR report template.
The VVB shall communicate the disclaimer to ICR without undue delay.
### Verification Report
The VVB shall prepare a verification report using the applicable ICR verification report template, or the ICR validation and verification report template where verification is performed jointly with validation.
The verification report shall provide a transparent and traceable basis for the verification opinion. The report shall include, as applicable:
1. verification objectives, criteria, scope, level of assurance, and materiality threshold;
2. the verification team, including the team leader, team members and any technical experts used; the independent reviewer; their respective roles; the basis for the team competence determination; and any prior participation in project validation, including the roles performed, resulting impartiality risks and safeguards, and separation of responsibility for reassessment of prior work;
3. summary of strategic analysis, risk assessment, verification plan, and evidence-gathering activities;
4. monitoring period and GHG statement verified;
5. whether evidence-gathering activities were performed onsite, remotely, or through a hybrid approach, where this materially affects the verification approach;
6. assessment of project implementation against the validated project design;
7. assessment of monitoring plan implementation, data trail, GHG information system, controls, data quality, and QA/QC;
8. assessment of calculations, parameters, emission factors, models, uncertainty, and conservativeness;
9. assessment of deviations, design changes, baseline updates, data gaps, or changes from prior periods;
10. assessment of leakage and other secondary effects;
11. assessment of reversals, non-permanence events, storage losses, insurance, buffer, or adjustment arrangements, where applicable;
12. assessment of ex-post additionality reporting, including whether the reporting is complete and supported, any change in additionality status disclosed, and any information to be considered at crediting-period renewal;
13. assessment of ownership, title, double counting, and claims relevant to issuance or conversion;
14. assessment of safeguards, other benefits, SDG contributions, incidents, corrective actions, and related claims reported for the monitoring period, including any unresolved issues that may affect issuance eligibility, claims, or the verification opinion;
15. assessment of authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims, where included in the verification scope;
16. assessment of grouped or bundled project activities, including added project instances, where applicable;
17. findings raised and their resolution;
18. unresolved issues, limitations, qualifications, or conditions;
19. verified GHG emission mitigation quantity for the monitoring period; and
20. verification opinion.
The verification opinion shall state the volume of GHG emission mitigation outcomes verified for the monitoring period and eligible to be issued or converted, including any deductions, exclusions, reversals, leakage adjustments, or non-permanence adjustments relevant to the verified quantity.
The verification report shall clearly state the scope of the VVB’s assessment of safeguards, other benefits, and SDG contributions and shall avoid implying assurance over broader ESG or sustainable-development claims beyond the validated ESES-SD assessment, ESES-SD monitoring information, the monitoring report, PDDMR, and applicable ICR criteria.
Where Article 6.2, authorization, corresponding adjustment, or other international transfer-related claims are addressed in the verification report, the report shall clearly state that the VVB’s assessment supports the verification conclusion and does not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
The report shall be sufficiently detailed to support ICR review and intended-user understanding without requiring reproduction of all working papers.
## Validation
## Planning
### Strategic Analysis
The VVB shall conduct the validation strategic analysis in accordance with ISO 14064-3, Section 5 of this document, and the VVB’s accredited procedures.
For ICR project validation, the strategic analysis shall consider, as applicable:
1. the project type, sector, technology, scale, location, and implementation context;
2. the applicable validation criteria, including ISO 14064-2, the ICR Requirement Document, other applicable ICR Program requirements, the applied approved methodology, module, tool, or methodological guidance where applicable, and the PDD, PDDMR, or other project design documentation;
3. the intended use of the validation opinion under the ICR Program;
4. project eligibility and recognition under applicable ICR requirements;
5. the methodological pathway, including whether the project applies an approved methodology, module, tool, methodological guidance, or project-specific criteria and procedures;
6. the baseline scenario, additionality demonstration, project boundary, GHG SSR selection, quantification approach, monitoring plan, and data quality arrangements;
7. expected GHG emission reductions or removal enhancements and the assumptions, methods, parameters, models, and data sources supporting them;
8. uncertainty, conservativeness, sensitivity, leakage, secondary effects, non-permanence, reversals, and ongoing monitoring obligations, where applicable;
9. ownership, title, right to claim, double counting, and claims relevant to registration and future issuance;
10. safeguards, other benefits, SDG contributions, environmental and socio-economic matters, and related claims included in the PDD, PDDMR, ESES-SD assessment, or other ICR submission;
11. authorization, corresponding adjustment, Article 6.2 eligibility, authorized uses, vintages, quantity limits, or other international transfer-related claims, where included in the validation scope or ICR submission;
12. public stakeholder consultation comments, ICR clarification requests, registry information, media, or other public information relevant to the GHG statement or applicable criteria;
13. whether sufficient and appropriate evidence is expected to be available; and
14. whether onsite, remote, or hybrid evidence-gathering activities are expected to be necessary to assess the GHG-related activity characteristics and other material validation matters.
Where the VVB identifies, during strategic analysis, that the applied methodology, project-specific criteria, or proposed procedures may not be capable of supporting conformity with ISO 14064-2 or the ICR Requirement Document, the VVB shall consider the effect on the validation plan, evidence-gathering plan, and validation conclusion.
Where, during strategic analysis, the VVB identifies concerns that an applied methodology, project-specific procedure, data source, model, assumption, or scientific claim may not be scientifically credible, technically appropriate, or consistent with applicable ICR requirements, the VVB shall evaluate the effect on the validation conclusion and, where appropriate, communicate the matter to ICR.
The results of the strategic analysis shall be used in determining the validation plan and evidence-gathering plan.
### Materiality Thresholds
The VVB shall identify materiality thresholds in accordance with ISO 14064-3 and Section 5.1.7 of this document.
For validation, materiality shall include quantitative and qualitative considerations relevant to whether the project design, assumptions, methods, limitations, projected GHG emission mitigations, and disclosures provide a reasonable basis for the GHG statement and conform with applicable validation criteria.
The quantitative materiality thresholds specified for verification in Section 5.1.7 may inform validation planning and judgement, but they shall not be interpreted as reasonable assurance over future GHG emission mitigations.
Qualitative materiality may include matters affecting project eligibility, methodology applicability, baseline selection, additionality, ownership, double counting, authorization, corresponding adjustment claims, safeguards, non-permanence, monitoring feasibility, or the intended use of the validation opinion.
### Estimate Testing
The VVB shall evaluate estimates and assumptions in accordance with ISO 14064-3.
For ICR project validation, estimate testing shall address, as applicable:
1. ex-ante baseline emissions or removals;
2. ex-ante project emissions or removals;
3. expected leakage or other secondary effects;
4. expected net GHG emission reductions or removal enhancements;
5. activity levels, operating conditions, utilization rates, or production assumptions;
6. emission factors, default values, parameters, coefficients, models, and conversion factors;
7. dynamic baseline assumptions and update mechanisms, where applicable;
8. uncertainty and conservativeness;
9. assumptions used for permanence, reversal risk, storage, or durability, where applicable;
10. assumptions used in additionality demonstrations, including common practice, financial, barrier, policy, or statutory considerations, where applicable;
11. assumptions or limitations relevant to authorization, Article 6.2 eligibility, corresponding adjustment treatment, or other international transfer-related claims, where these matters affect the intended use of the GHG statement.
The VVB shall assess whether assumptions are appropriate for the project circumstances, supported by evidence, consistent with the applicable criteria, and conservative where uncertainty may materially affect the GHG statement.
Where project-specific criteria and procedures are used instead of an approved methodology, the VVB shall assess whether the estimation approach is sufficiently documented, justified, repeatable, conservative, and suitable for future verification.
### Assessment of GHG-Related Activity Characteristics
#### General
The VVB shall develop evidence-gathering activities to assess the GHG-related activity characteristics in accordance with ISO 14064-3, the validation plan, the evidence-gathering plan, this document, and its accredited procedures.
For ICR project validation, the VVB shall assess whether the project design provides a clear, complete, conservative, and verifiable basis for determining whether the project conforms with ISO 14064-2, the ICR Requirement Document, other applicable ICR Program requirements, and the applied approved methodology, module, tool, or methodological guidance, where applicable.
Where no approved methodology is applied, the VVB shall assess whether the project-specific criteria and procedures established by the project proponent are sufficient to support conformity with ISO 14064-2 and the ICR Requirement Document.
The VVB shall assess whether the criteria, procedures, assumptions, methods, data sources, models, parameters, equations, and conclusions used in the project are based on best available scientific knowledge, technically appropriate for the project context, transparently documented, supported by credible scientific or technical evidence, and applied without bias and with conservativeness where uncertainty is material.
This assessment is particularly relevant where the project relies on project-specific criteria and procedures, non-approved external methods, scientific literature, datasets, models, default values, assumptions, or other technical sources that are not established as approved ICR methodology criteria.
The VVB shall consider public stakeholder consultation comments where they are relevant to the GHG statement, validation criteria, safeguards, baseline, additionality, quantification, monitoring, ownership, leakage, non-permanence, or other material project design elements.
The VVB shall assess claimed safeguards, other benefits, SDG contributions, or environmental and socio-economic outcomes only to the extent they are included in the validation criteria or relied upon in the project’s ICR submission.
Where remote activities or techniques are used to assess GHG-related activity characteristics, the VVB shall consider ISO 14064-5 and determine whether the activities or techniques provide sufficient and appropriate evidence for the relevant characteristics.
#### Recognition
The VVB shall assess whether the project activity is eligible under the ICR Program and recognized for the intended use of the GHG statement.
The VVB shall assess, as applicable:
1. project type and eligibility under the ICR Requirement Document;
2. conformity with applicable geographic, temporal, sectoral, legal, or activity-specific restrictions;
3. applicability of the approved methodology, module, tool, or methodological guidance, where applicable;
4. adequacy of project-specific criteria and procedures where no approved methodology is applied;
5. crediting start date and crediting period;
6. whether the project activity is real, quantifiable, verifiable, additional, and capable of supporting future issuance;
7. whether any restriction, exclusion, or limitation under ICR requirements affects project eligibility; and
8. whether any Article 6.2, corresponding adjustment, authorization, or other international transfer-related claim is identified and supported where such recognition is sought under the ICR Program.
Additionality shall be considered as part of recognition and baseline scenario selection where relevant to the applicable criteria.
The VVB may seek clarification from ICR on the interpretation of ICR eligibility requirements. Such clarification shall not be treated as project approval or as a substitute for the VVB’s validation conclusion.
The VVB’s assessment of Article 6.2, authorization, corresponding adjustment, or other international transfer-related claims shall support the validation conclusion but shall not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
#### Ownership
The VVB shall assess whether the project proponent has demonstrated ownership, title, authorization, or right to claim the GHG emission reductions or removal enhancements expressed in the GHG statement.
The VVB shall assess, as applicable:
1. contractual, legal, regulatory, registry, or other evidence supporting ownership or right to claim;
2. whether multiple parties may have competing claims to the same GHG emission mitigations;
3. whether the project documentation identifies all relevant project proponents, landowners, operators, facility owners, technology owners, or other rights holders;
4. whether the ownership basis is sufficient for registration and future issuance under the ICR Program;
5. whether any limitations, encumbrances, benefit-sharing arrangements, or transfer restrictions may affect title or claims;
6. whether the project documentation identifies and addresses any other GHG program, registry, incentive, certificate, claim, or mitigation-use arrangement relating to the same activity or GHG emission mitigations; and
7. where applicable, host country authorization, attestation, authorized uses, vintages, quantity limits, corresponding adjustment treatment, or other international transfer-related documentation.
The VVB shall consider ownership, title, authorization, right to claim, and double counting as conformity matters relevant to registration and future issuance.
The VVB is not responsible for issuing a legal opinion on ownership, title, authorization, or right to claim. However, unresolved ownership, title, authorization, right-to-claim, double counting, or claim-related issues shall be evaluated for their effect on registration eligibility, future issuance, public claims, and the validation opinion.
#### GHG Boundary
The VVB shall assess whether the project boundary includes all relevant project, baseline, and affected GHG SSRs in accordance with ISO 14064-2, the ICR Requirement Document, and the applied approved methodology, where applicable.
The VVB shall assess whether:
1. project GHG SSRs are identified and justified;
2. baseline GHG SSRs are identified and justified;
3. affected GHG SSRs, including leakage sources, are identified and justified;
4. GHG SSRs identified for the project and baseline scenario are functionally comparable where required;
5. included and excluded GHG SSRs are treated consistently and conservatively;
6. exclusions are justified, documented, and not likely to result in overestimation;
7. the project and baseline boundaries are functionally comparable; and
8. the boundary is consistent with the quantification approach, monitoring plan, and future verification needs.
Where a methodology is applied, the VVB shall assess whether the methodology’s boundary requirements have been correctly applied.
Where project-specific criteria are used, the VVB shall assess whether the boundary determination is sufficiently justified, conservative, and auditable.
#### Baseline Selection
The VVB shall assess whether the baseline scenario is plausible, conservative, appropriately justified, and established in accordance with ISO 14064-2, the ICR Requirement Document, and the applied approved methodology, where applicable.
The VVB shall assess whether:
1. the baseline scenario represents what would reasonably occur in the absence of the project;
2. the baseline scenario is established using a credible, documented, transparent, and repeatable process;
3. the baseline scenario is appropriate for the project activity, location, crediting period, and intended use of the GHG statement;
4. the baseline scenario considers applicable legal requirements, common practice, technology trends, market conditions, policy context, barriers, host-country NDC context where relevant, and other operating conditions;
5. alternative baseline scenarios have been identified and assessed where required by the applicable criteria;
6. excluded alternative scenarios are justified;
7. assumptions, calculations, rationales, documents, and sources used to support the baseline scenario are credible, correctly interpreted, and applicable to the project context;
8. conservativeness and uncertainty have been appropriately considered;
9. baseline assumptions are consistent with the additionality demonstration; and
10. the baseline scenario can be monitored, updated, or verified where required by the applicable criteria.
Where a methodology prescribes the baseline scenario or baseline selection procedure, the VVB shall assess whether the prescribed procedure has been correctly applied. The VVB shall not require additional baseline analysis where the applicable methodology prescribes the baseline scenario and no project-specific evidence indicates that the prescribed approach is inapplicable or inconsistent with ICR requirements.
Where no approved methodology is applied, or where the baseline scenario is not prescribed by the applied criteria, the VVB shall assess whether the project-specific baseline criteria and procedures are sufficient to support conformity with ISO 14064-2 and the ICR Requirement Document.
For bundled projects consisting of the same project activity type, demonstration of the baseline scenario and additionality may be combined where this is justified and consistent with applicable criteria.
For bundled projects with different project activity types or different methodological pathways, the VVB shall assess baseline and additionality separately for each relevant project activity type unless the applicable criteria justify another approach.
Where dynamic baseline provisions apply, the VVB shall assess whether:
1. update triggers are clearly defined;
2. data sources are identified and verifiable;
3. update frequency and timing are specified;
4. calculation procedures are clear and repeatable;
5. responsibilities for baseline updates are defined;
6. uncertainty and conservativeness are addressed; and
7. the distinction between a baseline update, deviation, design change, and methodology revision is sufficiently clear for future verification.
Where a baseline update may affect Article 6.2, authorization, corresponding adjustment treatment, or other claims, the VVB shall assess whether the project documentation identifies the relevant implications and any matter requiring ICR determination.
**Additionality**
The VVB shall assess whether the project proponent has demonstrated additionality in accordance with ISO 14064-2, the ICR Requirement Document, the ICR Additionality Specifications, and the applied approved methodology, module, tool, or methodological guidance, where applicable.
The VVB shall assess additionality as part of validation of the baseline scenario, project eligibility, and reasonableness of the GHG statement.
The VVB shall determine whether the additionality demonstration:
1. is consistent with the selected baseline scenario;
2. demonstrates that the GHG emission mitigations are additional to what would occur in the absence of the project;
3. applies the required ICR additionality levels;
4. provides sufficient and appropriate evidence for each additionality level claimed;
5. is transparent, conservative, internally consistent, and appropriate to the project type, sector, scale, geography, technology, market, regulatory context, and implementation circumstances;
6. is not contradicted by evidence relating to legal requirements, enforcement practice, common practice, market penetration, financial viability, policy context, or other material circumstances; and
7. identifies assumptions and conditions that are relevant to ex-post additionality reporting and that shall be reported ex-post during monitoring, where required.
The VVB shall critically assess the reliability and credibility of the data, rationales, assumptions, justifications, and documentation used to support the additionality demonstration. The VVB shall apply appropriate local, sectoral, regulatory, technical, and financial competence, as applicable.
The VVB shall not accept unsupported assertions, generic statements, or unsubstantiated claims as sufficient evidence of additionality.
The VVB shall not issue an unmodified validation opinion where unresolved additionality issues materially affect project eligibility, baseline validity, or the reasonableness of the GHG statement.
Ex-post additionality reporting shall not be treated as affecting continued issuance eligibility within the crediting period unless specified by applicable ICR requirements.
**Level 1 — GHG Emissions Additionality**
The VVB shall assess whether the project proponent has demonstrated that the project results in GHG emission mitigations additional to the determined baseline scenario.
The VVB shall assess whether:
1. the baseline scenario is valid, credible, conservative, and appropriately justified;
2. the project scenario is clearly distinguished from the baseline scenario;
3. the claimed GHG emission reductions or removal enhancements result from implementation of the project activity;
4. the quantification approach demonstrates a net mitigation outcome compared with the baseline scenario;
5. the additionality demonstration is consistent with the project boundary, SSR selection, leakage treatment, monitoring plan, quantification approach, uncertainty treatment, and conservativeness; and
6. assumptions used to demonstrate Level 1 additionality are suitable for future monitoring and verification.
Where the VVB identifies a material weakness in the baseline scenario, the VVB shall evaluate whether that weakness affects the Level 1 additionality conclusion.
**Level 2 — Statutory Additionality**
The VVB shall assess whether the project demonstrates Level 2a or Level 2b.
For Level 2a, the VVB shall assess whether the project activity, or a measure resulting in materially the same mitigation outcome, is not required by applicable law, regulation, permit, standard, mandate, or other legally binding requirement.
The VVB shall consider, as applicable:
1. national, subnational, and local legal requirements;
2. requirements applicable to the project proponent, facility, land area, sector, technology, product, or activity;
3. whether similar measures are legally required, even if the exact project activity is not named;
4. whether applicable legal requirements had entered into force or were adopted but not yet effective at the time of validation; and
5. whether carbon finance or the ICR mechanism has been incorporated into the legal or regulatory framework.
For Level 2b, where the project relies on non-enforcement additionality, the VVB shall assess whether the project proponent has demonstrated that the relevant statutory requirement is systematically not enforced and that non-compliance is widespread without consequence.
The VVB shall assess evidence such as:
1. enforcement records;
2. official communications;
3. compliance data;
4. evidence of penalties or lack of penalties;
5. evidence of common non-compliance in the relevant sector and jurisdiction; and
6. independent legal or regulatory analysis, where appropriate.
The VVB shall not accept a general statement of weak enforcement as sufficient evidence.
The VVB is not required to issue a legal opinion. Where legal interpretation is material to the additionality conclusion, the VVB shall assess whether sufficient and appropriate legal or regulatory evidence has been provided.
**Level 3 — Technology, Institutional, Barrier, or Common Practice Additionality**
The VVB shall assess whether the project demonstrates Level 3 additionality through technology, institutional, barrier, or common-practice evidence, as applicable.
The VVB shall assess whether the project activity:
1. faces material barriers to implementation or continued operation;
2. accelerates deployment of a technology, practice, or measure that would otherwise face limited or slower adoption; or
3. is not common practice in the relevant geographic, sectoral, market, and technological context.
Where common practice analysis is used, the VVB shall assess whether:
1. the geographic boundary is justified;
2. the sectoral and technological scope is justified;
3. comparable activities are appropriately identified;
4. market penetration, adoption rate, or comparable benchmark data are credible, current, and sufficiently disaggregated;
5. exclusions from the comparison group are justified and conservative;
6. policies, subsidies, incentives, mandates, market developments, and technology maturity have been considered; and
7. the common-practice threshold or benchmark is transparent and consistently applied.
The VVB shall assess whether the evidence supports the conclusion that the project activity is not common practice.
Where barrier analysis is used, the VVB shall assess whether:
1. the barriers are real, material, and relevant to the project activity;
2. the barriers are supported by verifiable evidence;
3. the barriers are specific to the project type, geography, sector, or implementation context;
4. the barriers are not generic claims that could apply to any project in the sector;
5. the barriers would prevent, delay, or materially limit implementation or continued operation in the absence of carbon market incentives;
6. existing policies, subsidies, mandates, financing mechanisms, or market developments do not independently overcome the barriers; and
7. the project documentation explains how carbon market incentives contribute to overcoming the identified barriers.
The VVB shall require clarification, correction, or further evidence where the barrier analysis relies primarily on unsupported narrative claims.
**Level 4 — Financial Additionality**
Where Level 4 additionality is claimed, the VVB shall assess whether the project demonstrates Level 4a or Level 4b.
For Level 4a, the VVB shall assess whether the project faces financial limitations that can be mitigated by revenues from the sale of carbon credits.
For Level 4b, the VVB shall assess whether the project faces significant financial limitations that can be mitigated or avoided by revenues from the sale of carbon credits and whether carbon credit revenues are the major or only source of revenues or a precondition for implementation or continued operation.
Where Level 4 is claimed, the VVB shall assess, as applicable:
1. CAPEX, OPEX, non-carbon revenues, cost savings, subsidies, incentives, taxes, fees, financing costs, and transaction costs;
2. financial indicators such as NPV, IRR, payback period, levelized cost, or other appropriate metrics;
3. suitability of the financial benchmark or comparison scenario;
4. consistency of assumptions with evidence available at the time of the investment decision;
5. accuracy of formulas, calculations, and financial model logic;
6. whether assumptions are current, reasonable, traceable, and internally consistent;
7. sensitivity of results to material parameters;
8. whether the investment decision depends on expected ICC revenues;
9. whether signed statements or other supporting evidence from the financial decision-making authority are consistent with the financial analysis; and
10. whether the project remains not common practice in the relevant geographic area.
**Level 5 — Policy Additionality**
Where Level 5 additionality is claimed, the VVB shall assess whether the project activity:
1. lies outside the scope of the host country’s current climate action strategy toward its NDC; or
2. is not reflected in the host country’s national GHG inventory.
The VVB shall assess, as applicable:
1. the most recent host country NDC;
2. the most recent national GHG inventory;
3. sectoral, geographic, GHG, activity, and mitigation-measure scope of the NDC;
4. sectoral, geographic, GHG, activity, and source-category coverage of the national GHG inventory;
5. whether the project’s mitigation outcomes are covered by national mitigation measures, sectoral targets, or inventory categories;
6. whether host country authorization, attestation, corresponding adjustment procedures, or Article 6.2 arrangements affect the Level 5 claim; and
7. whether any policy, NDC, or inventory update before validation affects the conclusion.
The VVB’s assessment of host country authorization, attestation, corresponding adjustment procedures, or Article 6.2 arrangements shall support the additionality and validation conclusions but shall not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
**Methodology-level, Standardized, Positive-list, or Automatic Additionality**
Where the project applies an approved methodology, standardized test, activity method, performance method, benchmark, positive list, or methodology-level additionality demonstration, the VVB shall assess whether:
1. the approach is approved or accepted for use under the ICR Program;
2. the approach is applicable to the project;
3. all applicability conditions, thresholds, validity periods, geographic limits, technology limits, and evidence requirements are met;
4. the methodology or tool demonstrates the relevant ICR additionality level, or the project proponent demonstrates any remaining required level at project level; and
5. no project-specific facts contradict the standardized or methodology-level additionality conclusion.
The VVB shall not accept automatic additionality, positive-list eligibility, or standardized additionality as sufficient where the project does not meet all applicable conditions or where project-specific evidence undermines the additionality conclusion.
#### Activity Measurement
The VVB shall assess whether activity levels, operational conditions, and project activity measurements used in the GHG quantification are appropriate, conservative, and capable of supporting accurate and complete estimates.
The VVB shall assess, as applicable:
1. expected activity levels or production levels;
2. expected utilization rates, operating hours, throughput, area, biomass, storage volumes, or other project-specific activity data;
3. measurement methods and data sources;
4. consistency between project design assumptions and monitoring plan parameters;
5. whether operating conditions required by the methodology or project-specific criteria can reasonably be met;
6. whether activity measurements can support future verification;
7. whether material changes in activity levels could affect baseline, additionality, leakage, non-permanence, or quantification outcomes.
**Non-permanence**
Where the project includes GHG SSRs, carbon pools, GHG reservoirs, storage forms, emission sources, or other conditions that may result in reversal, storage loss, resumed emissions, leakage, non-performance, or loss of credited mitigation outcomes, the VVB shall assess whether the project proponent has identified and addressed non-permanence and reversal risk in accordance with the applicable criteria.
The VVB shall assess, as applicable:
1. the type, duration, and reversibility of the carbon storage, GHG reservoir, avoided extraction, containment, sealing, plugging, destruction, or other mitigation outcome;
2. risks of reversal, storage loss, resumed extraction, resumed emissions, failure of containment, failure of plugging or sealing, non-performance, or other loss of credited mitigation outcomes;
3. monitoring provisions for reversal risk, non-permanence events, materialized risks, resumed emissions, containment failure, leakage, or other events that may affect credited mitigation outcomes;
4. corrective action, remediation, replacement, compensation, buffer, insurance, or other risk mitigation arrangements, where applicable; and
5. whether the proposed treatment of non-permanence is consistent with the project type, mitigation mechanism, monitoring period, crediting period, applicable methodology, and ICR requirements.
GHG project activities that do not depend on continued carbon storage, reservoir integrity, avoided extraction, containment, sealing, plugging, destruction, or another reversible condition are not subject to non-permanence risk assessment unless required by the applicable criteria.
#### Secondary Effects
The VVB shall assess whether leakage and other secondary effects have been identified, assessed, and addressed in accordance with ISO 14064-2, the ICR Requirement Document, and the applied approved methodology, where applicable.
The VVB shall assess, as applicable:
1. activity-shifting leakage;
2. market leakage;
3. ecological or physical leakage;
4. economic or substitution effects;
5. upstream, downstream, or indirect effects where required by the applicable criteria;
6. whether excluded secondary effects are justified and conservative;
7. whether leakage quantification or deductions are appropriate;
8. whether monitoring provisions are sufficient to detect or quantify material leakage during verification.
#### Quantification Methodologies and Measurements
For avoidance of doubt, a GHG quantification methodology may refer to criteria and procedures applied for quantification under ISO 14064-2, including criteria and procedures for quantifying project emissions or removals, baseline emissions or removals, leakage, reversals, and net GHG emission mitigations.
The VVB shall assess whether the selected quantification methodologies, calculations, models, parameters, measurements, and monitoring approaches are acceptable for the intended use under the ICR Program.
The VVB shall assess, as applicable:
1. equations and calculation procedures;
2. emission factors, removal factors, default values, conversion factors, and GWP values;
3. models, mass-balance approaches, sampling approaches, scaling approaches, proxies, or indirect measurement methods;
4. parameter selection and parameter update procedures;
5. whether values are fixed ex ante, monitored ex post, updated periodically, or selected at project level;
6. whether assumptions and parameters are conservative where uncertainty or data limitations may materially affect outcomes;
7. whether the approach is consistent with the approved methodology or project-specific criteria; and
8. whether the approach can support future verification of GHG emission mitigations.
Where the project applies a methodology but deviates from prescribed criteria and procedures, the VVB shall assess whether the deviation affects conformity with applicable criteria and whether the deviation preserves conservativeness or results in greater accuracy without overestimation.
**Project-specific criteria and procedures**
Where a project does not apply an approved methodology, module, tool, or methodological guidance, and instead establishes project-specific criteria and procedures within the project documentation, the VVB shall assess whether those criteria and procedures are suitable for the specific project and sufficient to demonstrate conformity with ISO 14064-2, the ICR Requirement Document, and other applicable ICR requirements.
The assessment shall be limited to the project under validation. Validation of project-specific criteria and procedures shall not constitute approval of a methodology, module, tool, or methodological guidance for wider application under the ICR Program.
In assessing project-specific criteria and procedures, the VVB should consider the relevant methodology validation principles and assessment areas in Section 11 of this document, to the extent applicable and proportionate to the project-specific use. This may include consideration of scientific integrity, overestimation risk, alignment with best available science, quantification rigor, uncertainty management, sampling and scaling approaches, provenance of emission factors and parameters, conservativeness of default assumptions, constraints on project-level discretion, monitoring adequacy, and future verifiability.
The VVB shall assess whether the project-specific criteria and procedures:
1. are clearly defined, internally consistent, transparent, conservative where required, and capable of being validated and verified;
2. are appropriate to the project activity, project boundary, geographic context, technology, scale, sector, baseline scenario, monitoring arrangements, and intended GHG statement;
3. provide sufficient criteria and procedures for baseline scenario selection, GHG SSR identification, quantification, monitoring, uncertainty, conservativeness, leakage, non-permanence, reversals, data quality, and future verification;
4. identify material assumptions, parameters, emission factors, datasets, models, default values, measurement methods, sampling approaches, and calculation procedures;
5. justify the scientific and technical basis for material assumptions, methods, parameters, models, and data sources;
6. avoid systematic overestimation of projected GHG emission mitigations;
7. constrain project-level discretion sufficiently to support consistent implementation, monitoring, verification, and ICR review;
8. include monitoring and data quality provisions sufficient to support future verification;
9. identify limitations, exclusions, applicability boundaries, and circumstances that may require reassessment, design change validation, or ICR clarification.
Where project-specific criteria and procedures rely on external methods, scientific literature, datasets, models, tools, or guidance that are not approved as ICR methodologies, the VVB shall assess whether their use is appropriate for the project and whether they support conformity with ISO 14064-2 and the ICR Requirement Document. Such references may support the project-specific criteria and procedures but shall not be treated as approved ICR methodology criteria unless accepted by ICR for that purpose.
Consideration of Section 11 for project-specific criteria and procedures does not constitute methodology validation or ICR methodology approval. The VVB’s conclusion applies only to the project under validation and shall not be used to support wider application of the criteria and procedures under the ICR Program.
The VVB shall not issue an unmodified validation opinion where unresolved issues with project-specific criteria and procedures materially affect baseline validity, additionality, quantification, monitoring, uncertainty, conservativeness, project eligibility, or the reasonableness of the projected GHG statement.
#### GHG Information System and Controls
The VVB shall assess whether the planned GHG information system, monitoring arrangements, data controls, and record-keeping procedures are sufficient to support future verification.
The VVB shall assess, as applicable:
1. monitored parameters and data sources;
2. monitoring frequency;
3. measurement methods and instrumentation;
4. calibration and maintenance requirements;
5. QA/QC procedures;
6. treatment of missing data, data gaps, and outliers;
7. data aggregation and calculation controls;
8. record retention and traceability;
9. roles, responsibilities, and segregation of duties;
10. controls for project instances or multiple sites, where applicable;
11. controls for dynamic baseline updates, where applicable;
12. controls for reversal monitoring or long-term monitoring obligations, where applicable.
The VVB shall assess whether the monitoring plan is sufficiently detailed to allow a future verifier to obtain sufficient and appropriate evidence.
#### Functional Equivalence
The VVB shall assess, as applicable:
1. equivalence of service, output, function, activity level, product, land use, technology performance, or other relevant functional basis;
2. whether the functional unit is clearly defined and consistently applied;
3. whether differences between project and baseline conditions are appropriately accounted for;
4. whether any non-equivalence could materially affect the baseline, additionality, leakage, or quantification outcome.
#### Calculation of GHG Statement
The VVB shall confirm that the GHG statement calculations have been performed in accordance with the applicable validation criteria.
The VVB shall assess, as applicable:
1. correct application of equations and calculation procedures;
2. correct use of emission factors, removal factors, default values, conversion factors, and GWP values;
3. correct aggregation of project, baseline, leakage, reversal, and net mitigation calculations;
4. appropriate treatment of uncertainty and conservativeness;
5. correct application of deductions or discounts, where applicable;
6. consistency between the GHG statement, PDD/PDDMR, monitoring plan, spreadsheets, models, and supporting documents.
Where models are used to estimate GHG emission mitigations, the VVB shall assess whether the model is transparent, understandable, suitable for the project context, supported by appropriate parameters, and capable of supporting future verification.
Where the VVB identifies uncertainty associated with data, parameters, models, or monitoring procedures, the VVB shall assess whether conservativeness has been appropriately applied to manage the risk of overestimation.
#### Future Estimates
The VVB shall evaluate future estimates associated with the GHG statement, including whether projected emission reductions or removal enhancements are reasonable, conservative, and supported by evidence.
The VVB shall assess, as applicable:
1. projected baseline emissions or removals;
2. projected project emissions or removals;
3. projected leakage;
4. projected net GHG emission mitigations;
5. projected activity levels, operational conditions, and implementation schedule;
6. dynamic baseline projections and update procedures;
7. future monitoring requirements;
8. expected crediting-period performance;
9. long-term storage, durability, or reversal risk assumptions, where applicable.
The VVB shall assess whether future estimates are presented transparently and whether limitations or uncertainty are properly disclosed.
#### Uncertainty
The VVB shall assess whether uncertainty has been identified, characterized, reduced where practical, and conservatively addressed in accordance with the applicable criteria.
The VVB shall assess, as applicable:
1. uncertainty in baseline scenario selection;
2. uncertainty in project activity data;
3. uncertainty in emission factors, removal factors, parameters, models, and default values;
4. uncertainty in sampling, scaling, extrapolation, or indirect measurement;
5. uncertainty in leakage or secondary effects;
6. uncertainty in non-permanence or reversal risk assumptions;
7. whether uncertainty could result in systematic overestimation;
8. whether conservative assumptions, deductions, or procedures are appropriate.
Where quantitative uncertainty analysis is required by the applicable criteria, the VVB shall assess whether the analysis has been performed in accordance with those criteria and whether all material sources of uncertainty have been considered.
Where quantitative uncertainty analysis is not required, the VVB shall assess whether qualitative uncertainty treatment is sufficient for validation.
#### Sensitivity
The VVB shall assess whether material assumptions and variables have been evaluated for sensitivity where changes could materially affect the GHG statement, baseline, additionality, eligibility, or future verification.
The VVB shall consider sensitivities in, as applicable:
1. baseline assumptions;
2. additionality assumptions, including financial, common practice, barrier, policy, or statutory assumptions;
3. activity levels and utilization rates;
4. emission factors, parameters, and default values;
5. leakage and secondary effects;
6. dynamic baseline update variables;
7. reversal risk or permanence assumptions;
8. uncertainty deductions or conservative adjustments.
Where sensitivity analysis identifies assumptions or variables that could materially affect the GHG statement or future verification, the VVB shall ensure that these matters are disclosed in the validation report and, where appropriate, identified as matters for future verification.
#### Other Benefits and Safeguards
The ICR ESES-SD Tool is applicable to all ICR project validations as a required supporting tool for safeguards, other benefits, SDG contributions, and environmental or socio-economic risk disclosure.
The VVB shall assess the completed ESES-SD assessment together with the PDD, PDDMR, stakeholder consultation information, monitoring plan, and other relevant project documentation.
The VVB shall assess whether the project documentation and completed ESES-SD assessment:
1. identify safeguards, other benefits, SDG contributions, environmental or socio-economic risks, and related claims relevant to the project activity;
2. provide justification for matters classified as not relevant, not applicable, or not expected to result in an impact;
3. describe mitigation, safeguard, enhancement, monitoring, or corrective measures where negative or potential negative impacts are identified;
4. provide monitoring arrangements sufficient to support future verification of relevant safeguards, other benefits, SDG contributions, and related claims; and
5. support claimed safeguards, other benefits, SDG contributions, or sustainable-development outcomes with sufficient and appropriate evidence.
The VVB shall not validate broad environmental, social, economic, human-rights, or sustainable-development claims beyond the applicable ICR criteria, the ESES-SD Tool, and the claims included in the project documentation.
Where broader claims are presented, the VVB shall assess whether the claims are supported by sufficient evidence and monitoring arrangements, and whether unsupported claims have been corrected, qualified, or removed from the project documentation.
Where unresolved safeguard or sustainable-development issues may affect project eligibility, registration, stakeholder claims, environmental integrity, or conformity with ICR requirements, the VVB shall evaluate the effect on the validation conclusion and opinion.
### Validation Plan
The VVB shall develop a validation plan in accordance with ISO 14064-3 and its accredited procedures.
The validation plan shall address the validation objectives, criteria, scope, conformity matters, and significant risks identified during strategic analysis.
The validation plan shall state whether one or more site or facility visits are planned and shall document the basis for that determination.
The validation plan shall be sufficient to support conclusions on:
1. conformity with ISO 14064-2;
2. conformity with the ICR Requirement Document and other applicable ICR Program requirements;
3. correct application of the approved methodology, where applicable;
4. adequacy of project-specific criteria and procedures, where applicable;
5. baseline, additionality, boundary, quantification, monitoring, uncertainty, leakage, non-permanence, ownership, safeguards, and future verifiability, as applicable;
6. authorization, corresponding adjustment, Article 6.2 eligibility, other international transfer-related claims, and related monitoring or reporting obligations, where included in the validation scope; and
7. evidence-gathering activities needed to assess the GHG-related activity characteristics.
The VVB shall upload the final validation plan, and any revised validation plan required by ICR, to the ICR registry platform. The validation plan is not intended for public disclosure.
### Evidence-Gathering Plan
The VVB shall develop an evidence-gathering plan in accordance with ISO 14064-3 and its accredited procedures.
The evidence-gathering plan shall be sufficient to obtain evidence supporting the validation conclusion against the applicable criteria.
The plan shall address, as applicable:
1. project documentation and supporting evidence;
2. methodology applicability evidence;
3. legal, regulatory, contractual, or ownership evidence;
4. baseline and additionality evidence;
5. quantification data, calculations, models, and assumptions;
6. monitoring plan and data control evidence;
7. evidence supporting leakage, non-permanence, safeguards, other benefits, SDG contributions, ownership, double counting, and related claims;
8. evidence supporting authorization, corresponding adjustment, Article 6.2 eligibility, authorized uses, vintages, quantity limits, or other international transfer-related claims, where included in the validation scope;
9. stakeholder consultation comments relevant to validation criteria; and
10. interviews, site assessment, remote activities or techniques, or other evidence-gathering activities determined by the VVB.
Where remote activities or techniques are used for material evidence-gathering activities, the VVB shall consider ISO 14064-5 and assess whether the planned activities can provide sufficient and appropriate evidence for the identified risks and applicable criteria.
The evidence-gathering plan is not required to be uploaded to the ICR registry platform unless requested by ICR or required under another applicable ICR process.
#### Site and Facility Visits
The VVB shall determine whether one or more site or facility visits are necessary to obtain sufficient and appropriate evidence for the validation conclusion. The determination shall be risk-based and shall consider, as applicable:
1. the project type, scale, complexity, location and geographic dispersion;
2. whether the project includes land-based, grouped, multi-site or dispersed project activities or instances;
3. the implementation status of the project, including the existence of pre-existing or installed infrastructure and the evidence supporting the project start date;
4. the need to confirm project boundaries, project activity locations, physical conditions, technology, ownership, rights or operational control;
5. risks relating to the baseline scenario, additionality, leakage, non-permanence, safeguards, stakeholder consultation or proposed monitoring arrangements;
6. the availability, independence, reliability and limitations of documentary evidence, remote sensing, geospatial information, interviews and other remote activities or techniques; and
7. whether material inconsistencies or evidence gaps can be resolved without onsite observation or inspection.
A site or facility visit shall be performed where document review, remote activities or other evidence gathering activities are insufficient to address an identified risk or obtain sufficient and appropriate evidence for a material validation matter.
Circumstances that may indicate the need for a site or facility visit include the first validation of land-based, grouped, multi-site or dispersed activities; reliance on material physical conditions or pre-existing infrastructure; uncertainty concerning project boundaries or the start of implementation; material safeguard or stakeholder related risks; and limitations or inconsistencies in documentary or remote evidence.
Where the VVB determines that a site or facility visit is not necessary, it shall document the basis for that determination in the validation plan and retain the supporting assessment in its validation records.
### Approval of Validation and Evidence-Gathering Plans
The VVB shall approve the validation plan and evidence-gathering plan in accordance with ISO 14064-3 and the VVB’s accredited procedures.
Any plan submitted to ICR shall be the version approved under the VVB’s procedures.
### Amendments to Validation and Evidence-Gathering Plans
The VVB shall amend the validation plan or evidence-gathering plan where information obtained during validation indicates that the plan is no longer sufficient to support the validation conclusion.
Amendments may be necessary where the VVB identifies, as applicable:
1. changes in project design or methodological pathway;
2. uncertainty regarding methodology applicability;
3. material issues with baseline or additionality evidence;
4. omitted or incorrectly classified GHG SSRs;
5. material limitations in monitoring arrangements;
6. unresolved ownership, title, double counting, safeguard, or non-permanence issues;
7. unresolved authorization, Article 6.2, corresponding adjustment, or other international transfer-related issues;
8. new stakeholder comments or evidence relevant to the GHG statement;
9. project-specific criteria or procedures that are not sufficiently documented or auditable; or
10. remote activities or techniques that do not provide sufficient and appropriate evidence for the intended validation purpose.
Any revised validation plan required by ICR shall be uploaded to the ICR registry platform.
## Execution
### General
The VVB shall perform validation activities in accordance with ISO 14064-3, the approved validation plan, and the evidence-gathering plan, as amended where necessary.
During execution, the VVB shall evaluate whether sufficient and appropriate evidence supports the project proponent’s GHG statement and the project’s conformity with the applicable validation criteria.
Where remote activities or techniques are used during execution, the VVB shall evaluate whether they operate as planned and provide sufficient and appropriate evidence. Where remote activities or techniques are insufficient, the VVB shall amend the evidence-gathering plan, obtain additional evidence, perform onsite activities where necessary, or reflect the limitation in the validation conclusion and opinion.
The VVB shall raise findings, non-conformities, clarification requests, or other issues where evidence is insufficient, inconsistent, incomplete, or indicates possible non-conformity with ISO 14064-2, the ICR Requirement Document, or the applied approved methodology, where applicable.
The VVB shall classify and document findings raised during validation in accordance with Sections 3 and 5.4.1.
The VVB shall evaluate corrective actions and revised documentation before issuing the validation opinion.
### Evaluation of the GHG Statement
The VVB shall evaluate the GHG statement in accordance with ISO 14064-3.
For ICR project validation, the VVB shall assess whether the PDD, PDDMR, or other project design documentation presents the GHG statement fairly and transparently, including:
1. project description and implementation arrangements;
2. project eligibility and methodological basis;
3. baseline scenario and additionality;
4. project, baseline, and affected GHG SSRs;
5. quantification methods, calculations, assumptions, and uncertainty;
6. monitoring plan and data quality arrangements;
7. leakage and other secondary effects;
8. non-permanence and reversal risk, where applicable;
9. ownership, title, double counting, and claims;
10. safeguards, other benefits, SDG contributions, environmental or socio-economic matters, and related claims included in the project documentation;
11. authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims, where included in the validation scope; and
12. limitations, exclusions, or conditions relevant to future verification.
### Proper Disclosure
The VVB shall assess proper disclosure in accordance with ISO 14064-3.
The VVB shall assess whether the project documentation discloses information necessary for intended users, ICR, and future verifiers to understand the project design and the basis for the GHG statement.
Proper disclosure shall include, as applicable:
1. validation criteria and methodological pathway;
2. applied methodology, modules, tools, or project-specific criteria and procedures;
3. material assumptions, limitations, and exclusions;
4. baseline and additionality rationale;
5. uncertainty and conservative treatments;
6. monitoring limitations or data constraints;
7. leakage and non-permanence risks;
8. ownership, title, double counting, and claims;
9. safeguards, other benefits, SDG contributions, environmental or socio-economic matters, and related claims;
10. authorization, corresponding adjustment, Article 6.2 eligibility, authorized uses, vintages, quantity limits, or other international transfer-related claims, where included in the validation scope;
11. stakeholder consultation outcomes relevant to validation criteria;
12. conditions or matters requiring attention during future verification; and
13. consistency between information presented in the project documentation and information submitted or disclosed through the ICR registry platform.
The VVB shall require correction where inadequate disclosure may materially affect the validation conclusion, registration eligibility, or future verification.
## Completion
### General
The VVB shall complete validation in accordance with ISO 14064-3 and Section 5.4.5 of this document.
Before issuing the validation opinion, the VVB shall evaluate whether:
1. the project design conforms with ISO 14064-2;
2. the project design conforms with the ICR Requirement Document and other applicable ICR Program requirements;
3. the applied approved methodology, module, tool, or methodological guidance has been correctly applied, where applicable;
4. project-specific criteria and procedures are sufficient where no approved methodology is applied;
5. sufficient and appropriate evidence supports the validation conclusion;
6. material findings and non-conformities have been resolved or appropriately reflected in the opinion;
7. unresolved issues affect registration eligibility, future verification, or future issuance eligibility;
8. where remote or hybrid activities were used, any limitations affecting the sufficiency or appropriateness of evidence have been resolved or appropriately reflected in the validation report and opinion; and
9. where authorization, corresponding adjustment, Article 6.2 eligibility, safeguards, other benefits, SDG contributions, ownership, double counting, or other claim-related matters are included in the validation scope, unresolved issues have been evaluated for their effect on the validation report, opinion, and intended ICR Program decision.
The VVB shall not issue an unmodified validation opinion where unresolved material issues prevent a conclusion that the project conforms with the applicable validation criteria.
For bundled project activities, the VVB shall state its conclusion on conformity of the bundled project activities with the applicable criteria and describe the evidence-gathering activities performed to support that conclusion.
### Opinion
#### General
The VVB shall issue a validation opinion in accordance with ISO 14064-3, this document, the applicable ICR report template, and the VVB’s accredited procedures.
The validation opinion shall state whether, in the VVB’s opinion, the project design conforms with:
1. ISO 14064-2;
2. the ICR Requirement Document;
3. the applied approved methodology, module, tool, or methodological guidance, where applicable; and
4. other applicable ICR Program criteria included in the validation scope.
Where no approved methodology is applied, the validation opinion shall address whether the project-specific criteria and procedures are sufficient for the project to demonstrate conformity with ISO 14064-2 and the ICR Requirement Document.
The opinion shall identify any modification, qualification, limitation, or condition affecting the validation conclusion.
A validation opinion supporting registration shall not be issued while a corrective action request or clarification request remains open where its resolution is necessary to demonstrate conformity with the applicable validation criteria or to obtain sufficient and appropriate evidence.
The validation opinion shall not constitute ICR registration, issuance approval, conversion approval, methodology approval, acceptance of Article 6.2 eligibility, confirmation of corresponding adjustment application, or approval of future monitoring period results.
#### Unmodified Opinion
The VVB may issue an unmodified validation opinion only where sufficient and appropriate evidence supports the conclusion that:
1. the project design conforms with the applicable validation criteria;
2. the assumptions, methods, limitations, and projected GHG emission mitigations provide a reasonable basis for the GHG statement;
3. all material findings and non-conformities have been resolved, including closure of corrective action requests and clarification requests necessary to establish conformity or the sufficiency of evidence; and
4. any remaining finding or limitation is not material, individually or in aggregate, and does not affect registration eligibility or the feasibility of future verification.
Where claim-related matters are included in the validation scope, no unresolved material limitation shall affect the reliability of those claims for the intended use of the validation report.
The VVB shall use the applicable ICR report template and standard opinion wording, where required.
#### Modified Opinion
The VVB may issue a modified validation opinion only where the matter giving rise to the modification is confined and the VVB concludes that:
1. the project design does not materially fail to conform with the applicable validation criteria;
2. the assumptions, methods, limitations, and projected GHG emission mitigations continue to provide a reasonable basis for the GHG statement;
3. the matter does not render the GHG statement misleading; and
4. the matter does not prevent the VVB from concluding that the applicable criteria for registration have been met.
In determining whether a modified opinion is appropriate, the VVB shall consider the extent to which the matter impairs the usefulness of the GHG statement, whether its actual or possible effects can be determined, and whether those effects are material or pervasive.\[^4]
A modified opinion shall not be used as an alternative to resolving a corrective action request or clarification request necessary to establish conformity with the applicable validation criteria or to obtain sufficient and appropriate evidence.
Where the VVB issues a modified validation opinion, the opinion and validation report shall clearly describe:
1. the matter giving rise to the modification;
2. the affected criteria, project design elements, assumptions, methods, calculations, or limitations;
3. whether the matter affects the reasonableness of the GHG statement;
4. whether the matter affects registration eligibility or future issuance eligibility;
5. the extent to which the usefulness of the GHG statement is impaired; and
6. whether the matter affects authorization, corresponding adjustment, Article 6.2 eligibility, safeguards, other benefits, SDG contributions, ownership, double counting, or other claims included in the validation scope.
The VVB shall use the applicable ICR report template and standard opinion wording, where required, and shall adapt the wording only to the extent necessary to clearly describe the modification.
#### Adverse Opinion
Where the VVB concludes that the project design materially fails to conform with the applicable validation criteria, or that the GHG statement does not have a reasonable basis, or that the available evidence demonstrates that an applicable eligibility criterion has not been met, the VVB shall issue an adverse opinion in accordance with its accredited procedures and the applicable ICR report template.
A matter may be material because of its nature or relevance to registration eligibility irrespective of whether its estimated quantitative effect is below a materiality threshold referred to in Section 5.1.7.
The VVB shall communicate the adverse opinion to ICR without undue delay.
#### Disclaiming the Issuance of the Opinion
Where the VVB is unable to obtain sufficient and appropriate evidence to support a validation conclusion, including where the possible effects of an evidence limitation may be material and pervasive, the VVB shall disclaim the issuance of an opinion in accordance with its accredited procedures and the applicable ICR report template.
The VVB shall communicate the disclaimer to ICR without undue delay.
### Validation Report
The VVB shall prepare a validation report using the applicable ICR validation report template, or the ICR validation and verification report template where validation is performed jointly with verification.
The validation report shall provide a transparent and traceable basis for the validation opinion. The report shall include, as applicable:
1. validation objectives, criteria, scope, and materiality considerations;
2. validation team and competence, including use of technical experts where applicable;
3. summary of validation activities and evidence reviewed;
4. whether evidence-gathering activities were performed onsite, remotely, or through a hybrid approach, and, where no site or facility visit was performed, a summary of the basis for determining that sufficient and appropriate evidence was obtained through other means;
5. assessment of project eligibility and methodological basis;
6. assessment of baseline scenario, including dynamic baseline provisions where applicable;
7. assessment of additionality;
8. assessment of project boundary and GHG SSRs;
9. assessment of quantification methods, assumptions, calculations, uncertainty, and conservativeness;
10. assessment of monitoring plan and data quality arrangements;
11. assessment of leakage and secondary effects;
12. assessment of non-permanence, reversals, and ongoing obligations, where applicable;
13. assessment of ownership, title, double counting, and claims;
14. assessment of safeguards, other benefits, SDG contributions, environmental or socio-economic risks, and related claims, including consistency between the completed ESES-SD assessment and the project documentation, monitoring arrangements, findings raised, and unresolved issues;
15. assessment of authorization, corresponding adjustment, Article 6.2 eligibility, or other international transfer-related claims, where included in the validation scope;
16. treatment of public stakeholder consultation comments relevant to validation criteria;
17. findings raised and their resolution;
18. unresolved issues, limitations, qualifications, or conditions; and
19. validation opinion.
The validation report shall identify the validation team, including the team leader, team members and any technical experts used, and shall identify the independent reviewer separately. The report shall describe the relevant competence of the team at a level sufficient to demonstrate suitability for the validation scope, including sectoral, technical, methodological, jurisdictional, and ICR Program competence, as applicable.
Where the project applies project-specific criteria and procedures, the validation report shall clearly state that the VVB’s conclusion applies only to the project under validation and does not constitute approval of a methodology, module, tool, or methodological guidance for wider application under the ICR Program.
The report shall be sufficiently detailed to support ICR review and future verification without requiring reproduction of all working papers or internal evidence-gathering records.
The validation report shall clearly state the scope of the VVB’s assessment of safeguards, other benefits, and SDG contributions and shall avoid implying assurance over broader ESG or sustainable-development claims beyond the ESES-SD Tool, project documentation, and applicable ICR criteria.
Where Article 6.2, authorization, corresponding adjustment, or other international transfer-related claims are addressed in the validation report, the report shall clearly state that the VVB’s assessment supports the validation conclusion and does not constitute ICR designation of ICCs as Article 6.2 ICCs or confirmation that a corresponding adjustment has been applied.
Where the project does not meet the validation criteria, the VVB shall issue an adverse opinion or other appropriate opinion in accordance with its accredited procedures and the applicable ICR report template. The project shall not be eligible for registration until the relevant issues have been resolved and a validation opinion supporting registration has been issued.
## Independent Review
The VVB shall complete an independent review in accordance with ISO 14064-3, this document, and the VVB’s accredited procedures before issuing an opinion under the ICR Program.
The independent review shall be performed by competent personnel who were not involved in conducting the validation or verification activities under review, in accordance with the VVB’s accredited procedures.
For ICR engagements, the independent review shall determine whether the report and draft opinion are supported by sufficient and appropriate evidence and whether the VVB’s conclusions are consistent with the applicable criteria, including, as relevant:
1. ISO 14064-2;
2. the ICR Requirement Document;
3. other applicable ICR Program requirements;
4. the applied approved methodology, module, tool, or methodological guidance, where applicable;
5. the validated project design documentation, monitoring plan, monitoring report, or GHG statement, where applicable; and
6. any additional criteria accepted for the engagement.
The independent review shall consider whether:
1. the engagement objectives, criteria, scope, level of assurance where applicable, and materiality threshold where applicable have been appropriately addressed;
2. significant risks identified during planning have been addressed through sufficient and appropriate evidence-gathering activities;
3. findings, non-conformities, clarification requests, material misstatements, and limitations have been appropriately resolved or reflected in the report and opinion;
4. conclusions on conformity with applicable ICR criteria are supported by the evidence presented;
5. conclusions on safeguards, other benefits, SDG contributions, environmental or socio-economic matters, and related claims are supported by sufficient and appropriate evidence where these matters are included in the applicable criteria, project documentation, monitoring report, ESES-SD assessment, ESES-SD monitoring information, or engagement scope;
6. conclusions on authorization, corresponding adjustment, Article 6.2 eligibility, ownership, title, double counting, and other claim-related matters are supported by sufficient and appropriate evidence where these matters are included in the applicable criteria, ICR submission, or engagement scope;
7. unresolved issues have been appropriately evaluated for their effect on registration, issuance, conversion, methodology approval, future verification, or other intended ICR Program decision;
8. the report is sufficiently transparent and traceable to support ICR review and intended-user understanding;
9. the draft opinion is consistent with the evidence, findings, conclusions, and applicable ICR template requirements; and
10. where remote or hybrid activities were material to the engagement, any limitations affecting the sufficiency or appropriateness of evidence have been adequately evaluated and reflected in the report and opinion.
For project validation, the independent review shall consider whether the validation conclusion is supported against the applicable validation criteria, including project eligibility, baseline, additionality, boundary, quantification, monitoring, safeguards, ownership, non-permanence, and other relevant ICR requirements.
For project verification, the independent review shall consider whether the verification conclusion is supported against the applicable verification criteria, including monitored data, monitoring plan implementation, calculations, deviations, design changes, reversals, leakage, ownership, double counting, issuance or conversion eligibility, and other relevant ICR requirements.
For methodology validation, the independent review shall consider whether the methodology validation conclusion is supported against ISO 14064-2 applied at methodology level, the ICR Methodology Requirements, the ICR Methodology Approval Process, the ICR Requirement Document, and Section 11 of this document.
For joint validation and verification, the independent review shall confirm that validation and verification objectives, criteria, scopes, findings, conclusions, and opinions are separately supported and clearly distinguished.
The independent reviewer shall not have been involved in planning, performing, or deciding the validation or verification activities subject to the independent review.
For verification of the same project, the independent reviewer shall not act as independent reviewer for more than five consecutive verifications or for verifications covering, in aggregate, more than five years of monitoring, whichever occurs first, unless the VVB determines that continued involvement is necessary and documents the justification and how familiarity risks are identified and managed in accordance with its accredited procedures and applicable ICR requirements. The monitoring period for the first verification may exceed five years.
## Issuance of Opinion
### General
The VVB shall decide whether to issue an opinion or disclaim the issuance of an opinion. The decision shall be made only after completion of the validation or verification activities, evaluation of findings, completion of independent review, and consideration of the evidence obtained and any limitations on that evidence. Where the VVB decides to issue an opinion, it shall issue the validation or verification opinion in accordance with ISO 14064-3, this document, the applicable ICR reporting template, and the VVB’s accredited procedures.
An opinion issued by a VVB under the ICR Program supports ICR review but does not constitute ICR registration, issuance, conversion, methodology approval, acceptance of a design change, or any other ICR Program decision. ICR retains responsibility for program decisions under the applicable ICR procedures.
A VVB opinion also does not constitute ICR designation of ICCs as Article 6.2 ICCs, confirmation that a corresponding adjustment has been or will be applied or approval of future monitoring-period results.
### Types of Opinions
After deciding to issue an opinion, the VVB shall determine the appropriate opinion type in accordance with ISO 14064-3, this document, Section 6.3.2 or 7.3.2, as applicable, and the VVB’s accredited procedures. The VVB shall use the applicable ICR reporting template.
The following opinion types apply under the ICR Program:
1. unmodified opinion;
2. modified opinion; or
3. adverse opinion.
The VVB shall not issue an unmodified opinion where an unresolved material misstatement, material non-conformity, or limitation on evidence affects the GHG statement, conformity with applicable criteria, registration eligibility, issuance or conversion eligibility, methodology approval, or the intended use of the opinion.
Where an opinion is modified or adverse, the VVB shall clearly describe:
1. the matter giving rise to the opinion type;
2. the affected criteria;
3. the affected project, methodology, monitoring period, GHG statement, data, calculations, assumptions, or project elements;
4. the effect on the GHG statement, project eligibility, issuance or conversion eligibility, methodology approval process, or intended use of the opinion, as applicable; and
5. any unresolved limitation, qualification, condition, or matter requiring ICR review.
The VVB shall communicate any adverse opinion or decision to disclaim the issuance of an opinion to ICR without undue delay.
ICR shall determine the consequences of any modified or adverse opinion, or any decision to disclaim the issuance of an opinion, for registration, issuance, conversion, methodology approval, or other ICR Program decisions under the applicable ICR procedures.
### Contents of Opinion
For ICR engagements, the opinion shall identify, as applicable:
1. the project, methodology, module, tool, GHG statement, or monitoring period subject to validation or verification;
2. the responsible party;
3. the VVB;
4. the engagement type;
5. the applicable criteria;
6. the scope of the engagement;
7. the monitoring period, where applicable;
8. the level of assurance for verification;
9. the materiality threshold for verification;
10. the conclusion against the applicable criteria;
11. the verified GHG emission mitigation quantity, where applicable;
12. any modification, qualification, limitation, exclusion, or condition;
13. the date and authorization of the opinion; and
14. a statement that the opinion does not constitute ICR registration, issuance, conversion, methodology approval, acceptance of a design change, or any other ICR Program decision.
Where the VVB disclaims the issuance of an opinion, the applicable ICR report shall state the reasons for the decision and describe the evidence limitations and their possible effects on the GHG statement, conformity with the applicable criteria, and the intended use of the validation or verification.
For project validation, the opinion shall state whether the project design conforms with ISO 14064-2, the ICR Requirement Document, other applicable ICR Program requirements, and the applied approved methodology, module, tool, or methodological guidance, where applicable.
Where no approved methodology is applied, the project validation opinion shall state whether the project-specific criteria and procedures are sufficient for the project to demonstrate conformity with ISO 14064-2 and the ICR Requirement Document. The opinion shall not constitute approval of the project-specific criteria and procedures for use beyond the project under validation.
For project verification, the opinion shall state whether the project implementation and reported GHG emission mitigations conform with ISO 14064-2, the ICR Requirement Document, other applicable ICR Program requirements, the applied approved methodology, module, tool, or methodological guidance where applicable, and the validated project design documentation. The opinion shall state whether the verified quantity is materially correct and eligible for issuance or conversion, subject to ICR review.
For methodology validation, the opinion shall state whether the methodology conforms with ISO 14064-2 applied at methodology level, the ICR Methodology Requirements, the ICR Methodology Approval Process, the ICR Requirement Document, and Section 11 of this document, and whether it provides suitable criteria and procedures for project-level application under the ICR Program.
For joint validation and verification, the opinion or report shall clearly distinguish the validation conclusion from the verification conclusion. A verification conclusion shall not compensate for an unresolved validation issue, and a validation conclusion shall not compensate for insufficient verification evidence.
The opinion shall be consistent with the applicable ICR reporting template and shall be supported by the findings and conclusions presented in the validation report, verification report, validation and verification report, or methodology validation report, as applicable.
Where safeguards, other benefits, SDG contributions, environmental or socio-economic matters, or related claims are addressed in the report, the opinion shall not imply assurance over broader ESG or sustainable-development claims beyond the applicable ICR criteria and the engagement scope.
Where Article 6.2, authorization, corresponding adjustment, or other international transfer-related claims are addressed in the report or opinion, the opinion shall state, where relevant, that the VVB’s assessment supports the validation or verification conclusion and does not constitute ICR designation of ICCs as Article 6.2 ICCs, or confirmation that a corresponding adjustment has been or will be applied.
## Facts Discovered After the Verification/Validation
The VVB shall address facts discovered after validation or verification in accordance with ISO 14064-3, the VVB’s accredited procedures, this document, and applicable ICR Program requirements.
For ICR engagements, facts or new information may materially affect the validation or verification opinion where they indicate, as applicable:
1. material misstatement in the GHG statement;
2. material error in the validation report, verification report, validation and verification report, methodology validation report, or opinion;
3. material non-conformity with ISO 14064-2, the ICR Requirement Document, the ICR Methodology Requirements, the applied approved methodology, or other applicable criteria;
4. incorrect application of an approved methodology, module, tool, methodological guidance, or validated project-specific criteria and procedures;
5. material issue affecting baseline validity, additionality, methodology applicability, project boundary, GHG SSR selection, quantification, monitoring, uncertainty, leakage, non-permanence, or reversals;
6. material issues affecting ownership, title, right to claim, double counting, authorization, corresponding adjustment, or issuance eligibility;
7. material issue affecting safeguards, other benefits, or claims, SDG contributions, environmental or socio-economic matters, complaints, grievances, incidents, or corrective actions included in the validation or verification scope;
8. intentional misstatement, fraud, manipulation of data, omission of material information, or misrepresentation of evidence;
9. facts indicating that issued, converted, or to-be-issued ICCs may be based on materially misstated or ineligible GHG emission mitigations;
10. for methodology validation, material scientific, technical, methodological, or conformity information indicating that the methodology may not provide a scientifically credible, conservative, operational, or verifiable basis for project-level application;
11. suspension, withdrawal, supersession, or material revision of an applied methodology, module, tool, dataset, emission factor, default value, model, or external source relied upon in the opinion, where the matter affects the opinion issued; or
12. new information arising from ICR review, ICR oversight, public comments, stakeholder complaints, grievances, regulatory decisions, accreditation body decisions, or other credible sources.
The VVB shall assess whether the facts or new information:
1. existed at the opinion date but was not known to the VVB;
2. arose after the opinion date;
3. affects the basis for the opinion;
4. affects registration, issuance, conversion, methodology approval, continued eligibility, future verification, or any other intended ICR Program decision;
5. requires correction of the report or opinion;
6. requires withdrawal, revision, or reissuance of the report or opinion in accordance with the VVB’s procedures; or
7. requires communication with ICR, the responsible party, the client, the accreditation body, or other relevant parties in accordance with applicable requirements.
Where communication to an accreditation body may be required, the VVB shall determine such communication in accordance with its accredited procedures, accreditation obligations, contractual obligations, and applicable law. Nothing in this section constitutes ICR assessment or determination of conformity with ISO 14065, ISO 14064-3, ISO 14066, ISO 17029, or accreditation requirements.
Where the fact or new information could materially affect an ICR Program decision, the integrity of issued or to-be-issued ICCs, or the reliability of a validation or verification opinion submitted to ICR, the VVB shall communicate the matter to ICR without undue delay, in addition to any communication required to the responsible party, client, accreditation body, or other relevant party.
The VVB shall not independently reverse ICR registration, issuance, conversion, methodology approval, or other ICR Program decisions. ICR shall determine any program actions, including suspension, withholding of issuance, correction of registry records, request for revised documentation, requirement for re-validation or re-verification, methodology suspension or withdrawal, or other action under applicable ICR procedures.
Where the VVB revises, withdraws, or reissues a report or opinion, the VVB shall identify:
1. the original report or opinion affected;
2. the facts or new information giving rise to the action;
3. the affected criteria and monitoring period, validation scope, verification scope, or methodology validation scope;
4. the effect on the original conclusion;
5. any revised conclusion, limitation, qualification, or disclaimer; and
6. the date of revision, withdrawal, or reissuance.
Where the VVB determines that the fact or new information does not materially affect the report or opinion, the VVB shall document the basis for that determination in accordance with its procedures.
Where ICR identifies facts or new information that may materially affect a validation or verification opinion, ICR may request the VVB to assess the matter, provide clarification, revise the report, reissue the opinion, or perform additional validation or verification activities, as applicable. Such request does not predetermine the VVB’s conclusion or transfer responsibility for the opinion from the VVB to ICR.
## Methodology Validation
### General
Approved VVBs are eligible to conduct validation of methodologies, modules, and tools under the ICR Methodology Approval Process where they are approved by ICR and accredited for validation under ISO 14065 for the applicable sectoral scope or scopes.
This section applies only to the validation of methodologies, modules, and tools submitted under the ICR Methodology Approval Process. It does not apply to project specific criteria and procedures assessed as part of an individual project validation. Project specific criteria and procedures shall be assessed under Sections 5 and 7 and do not constitute an approved methodology, module, tool, or methodological guidance.
Where the methodology, module, or tool falls under more than one sectoral scope, the VVB shall hold accreditation and ICR approval for all relevant sectoral scopes, unless ICR has accepted another arrangement consistent with the VVB’s accreditation and applicable ICR requirements.
Methodology validation shall determine whether the proposed methodology, module, or tool provides a reasonable, scientifically credible, transparent, conservative, internally consistent, operational, and verifiable basis for project-level application under the ICR Program.
Methodology validation shall assess whether the methodology, if correctly applied, is capable of supporting a true and fair account of GHG emission reductions or removal enhancements in accordance with ISO 14064-2 and applicable ICR requirements.
Methodology validation shall include assessment of the scientific integrity of the methodology. Scientific integrity shall be assessed as part of the VVB’s validation engagement and not as a separate assurance engagement.
The VVB shall conduct methodology validation in accordance with ISO 14064-3, this document, the ICR Methodology Requirements, the ICR Methodology Approval Process, the ICR Requirement Document, the VVB’s accredited procedures, and other applicable ICR Program criteria.
The VVB shall retain responsibility for its validation conclusion and opinion. Where the VVB uses technical experts, such use shall be managed under the VVB’s accredited procedures and shall not transfer responsibility for the validation conclusion away from the VVB.
The VVB’s methodology validation opinion supports ICR review and the methodology approval process but does not constitute ICR approval of methodology, module, or tool. ICR retains responsibility for methodology approval, rejection, suspension, withdrawal, and other program decisions under the applicable ICR procedures.
### Validation Criteria
The VVB shall identify the applicable methodology validation criteria before performing the engagement and shall report the criteria applied in the methodology validation report.
The validation criteria shall include, as applicable:
1. ISO 14064-2, applied at methodology level *mutatis mutandis*;
2. the ICR Methodology Requirements;
3. the ICR Requirement Document;
4. applicable ICR-approved modules, tools, or methodological requirements referenced by the methodology; and
5. any other criteria accepted by ICR for the methodology validation.
The VVB shall assess whether the methodology establishes criteria and procedures that are scientifically credible, technically appropriate, conservative where uncertainty is material, transparent, auditable, and capable of supporting project-level conformity with ISO 14064-2 and applicable ICR requirements.
Where a methodology includes criteria or procedures derived from another GHG program, scientific source, technical standard, module, tool, dataset, model, or guidance document, the VVB shall assess whether such criteria or procedures are appropriately incorporated, suitable for the methodology’s intended use, and do not conflict with applicable ICR requirements.
External criteria, methods, tools, datasets, models, or guidance documents shall not reduce, override, or replace applicable ICR requirements unless ICR has expressly accepted such treatment.
### Validation objectives
The objectives of methodology validation are to determine whether the methodology:
1. conforms with the applicable validation criteria;
2. is capable of supporting project-level conformity with ISO 14064-2 and applicable ICR requirements;
3. provides clear, operational, and verifiable criteria and procedures for eligible project activities;
4. provides a scientifically credible and conservative basis for quantifying, monitoring, reporting, validating, and verifying GHG emission mitigations;
5. avoids systematic overestimation of GHG emission reductions or removal enhancements;
6. provides sufficient constraints on project-level discretion to support consistent project design, validation, monitoring, verification, and ICR review;
7. enables transparent and consistent application by project proponents and VVBs;
8. provides sufficient evidence requirements to support future project validation and verification; and
9. identifies the applicability conditions, limitations, assumptions, and circumstances under which the methodology may be applied.
### Scope of methodology validation
The scope of methodology validation shall include the methodology document and any associated modules, tools, equations, models, data sources, default values, parameter tables, monitoring procedures, demonstration PDD, existing project PDD, or other supporting documentation submitted for validation.
Where a PDD is submitted to demonstrate application of the methodology, the VVB shall assess whether the PDD demonstrates that the methodology can be applied in practice.
Where the PDD represents an actual project activity intended for registration under the ICR Program, the project shall be validated in accordance with the applicable ICR requirements for project validation.
Where the PDD is a hypothetical demonstration PDD, the VVB shall assess whether it sufficiently demonstrates practical application of the methodology but shall not treat the assessment as validation of a project.
Where demonstration documentation includes project-specific examples, the VVB shall distinguish between conclusions on the methodology’s operationality and conclusions on any actual project submitted for registration.
Where the validation concerns a methodology revision, the VVB shall determine whether the validation scope may be limited to the revised elements or whether the revision affects the methodology sufficiently to require complete methodology validation. The VVB shall consider the nature, materiality, and potential effect of the revision on applicability, baseline determination, additionality, boundary, quantification, leakage, non-permanence, monitoring, uncertainty, conservativeness, and future project-level verification.
Previous validation by a VVB of a methodology, module, or tool does not, in itself, preclude that VVB from subsequently validating or verifying a project applying it. The VVB shall assess and document any resulting impartiality risks in accordance with Section 5.1.1 and its accredited procedures and shall apply appropriate safeguards, which may include the use of different personnel or additional independent technical review.
Where the impartiality risks cannot be eliminated or reduced to an acceptable level, the VVB shall not accept or continue the project engagement.
### Competence and use of technical experts
The VVB shall ensure that the methodology validation team has the competence necessary to assess the methodology against the applicable validation criteria, including the scientific, technical, sectoral, methodological, and GHG accounting aspects of the methodology.
The validation team competence shall be sufficient to assess, as applicable:
1. the scientific basis of the methodology;
2. the relevant mitigation pathway, technology, practice, or activity type;
3. baseline determination and additionality;
4. GHG SSR identification and boundary setting;
5. quantification methods, equations, models, parameters, default values, emission factors, removal factors, and datasets;
6. sampling, scaling, extrapolation, indirect measurement, modelling, and monitoring approaches;
7. uncertainty, sensitivity, conservativeness, and overestimation risk;
8. leakage, secondary effects, non-permanence, reversals, and ongoing monitoring obligations;
9. safeguards, other benefits, and environmental or socio-economic requirements, where included in the methodology; and
10. applicable ICR Program criteria and methodology approval requirements.
Where the validation team does not itself possess the necessary scientific or technical competence, the VVB shall use technical experts in accordance with its accredited procedures.
Technical experts may support the validation team’s assessment of scientific integrity, technical appropriateness, methodology design, models, assumptions, data sources, or other specialist matters. Technical experts shall not make the validation decision or issue the validation opinion unless they are separately qualified and assigned to that role under the VVB’s accredited procedures.
The methodology validation report shall identify the validation team and any technical experts used, including the subject matter for which technical expert input was used and how that input was considered in reaching the validation conclusion.
### Scientific integrity of methodologies
The VVB shall assess the scientific integrity of the methodology as part of methodology validation.
For the purposes of methodology validation, scientific integrity means that the criteria, procedures, assumptions, methods, data sources, models, parameters, equations, and conclusions used in the methodology are based on best available scientific knowledge, technically appropriate for the relevant methodology context, transparently documented, supported by credible scientific or technical evidence, and applied objectively and with conservativeness where uncertainty is material.
The VVB shall determine whether the methodology provides a scientifically credible, transparent, conservative, and verifiable basis for quantifying, monitoring, reporting, validating, and verifying GHG emission mitigations under the ICR Program.
The VVB shall assess whether the methodology:
1. is based on scientific principles, data, methods, assumptions, models, and parameters that are appropriate for the intended project type, geographic scope, temporal scope, and conditions of application;
2. reflects best available science, relevant peer-reviewed literature, recognized good practice guidance, authoritative datasets, empirical evidence, and technical advancements applicable to the mitigation activity;
3. avoids systematic overestimation of GHG emission mitigations;
4. applies conservative assumptions, default values, emission factors, parameters, models, sampling approaches, scaling approaches, and uncertainty treatments where uncertainty or data limitations may materially affect quantified outcomes;
5. provides transparent justification for selected quantification methods, emission factors, parameters, models, default values, sampling approaches, scaling approaches, and uncertainty treatment;
6. identifies material sources of uncertainty and provides procedures to quantify, manage, reduce, or conservatively account for such uncertainty;
7. provides adequate scientific provenance for emission factors, parameters, coefficients, datasets, models, and other material inputs;
8. specifies whether values, factors, parameters, and datasets are fixed, monitored, updated, calculated, or selected at project level, and provides criteria for such use;
9. contains sufficient constraints on project-level discretion to support consistent application by project proponents and consistent validation and verification by VVBs;
10. provides criteria and procedures that are clear, complete, internally consistent, operational, and auditable; and
11. enables project-level application in conformity with ISO 14064-2, the ICR Requirement Document, the ICR Methodology Requirements, and other applicable ICR requirements.
The VVB shall not be required to conduct academic peer review or independently reproduce all underlying scientific research. However, the VVB shall obtain sufficient and appropriate evidence to support its conclusion that the methodology’s scientific and technical basis is adequate for its intended use as ICR Program criteria.
Where scientific or technical evidence is limited, emerging, proprietary, not peer-reviewed, or subject to material uncertainty, the VVB shall assess whether the methodology developer has justified its use and whether additional conservativeness, applicability limitations, monitoring requirements, uncertainty treatment, or other safeguards are needed.
Where unresolved scientific integrity issues may affect conformity with validation criteria, conservativeness, uncertainty, overestimation risk, or reliability of future project-level validation or verification, the VVB shall evaluate the effect of those issues on the validation conclusion and opinion.
### Risk assessment and evidence-gathering considerations
The VVB shall consider risks that may affect the methodology’s ability to support accurate, conservative, consistent, and verifiable GHG emission mitigation outcomes.
The VVB’s risk assessment shall consider, as applicable:
1. novelty or complexity of the mitigation activity;
2. maturity and scientific acceptance of the quantification approach;
3. potential for systematic overestimation;
4. baseline uncertainty and risk of inflated counterfactual scenarios;
5. additionality demonstration and risk of non-additional project activities being eligible;
6. omission or exclusion of material GHG SSRs;
7. leakage and secondary effects;
8. uncertainty in emission factors, parameters, models, sampling, and scaling;
9. reliance on project-level discretion;
10. data availability, data quality, and monitoring feasibility;
11. non-permanence, reversal risk, and post-crediting monitoring obligations, where applicable;
12. use of external methodologies, modules, tools, datasets, models, or scientific literature;
13. consistency between the methodology and accompanying demonstration or project documentation;
14. public consultation comments or stakeholder concerns relevant to validation criteria.
The VVB shall design evidence-gathering activities sufficient to support its validation conclusion. Evidence may include, as applicable, methodology documentation, referenced literature, datasets, models, demonstration calculations, PDD documentation, expert input used by the VVB, public consultation comments, responses from the methodology developer, and other relevant supporting information.
Where interviews, remote technical review, or other remote activities are used as part of methodology validation, the VVB shall assess whether the evidence obtained is sufficient and appropriate for the validation conclusion.
### Key Components
Methodologies establish criteria and procedures that project proponents apply when designing projects and that VVBs apply when validating and verifying projects. The VVB shall assess whether the methodology provides a sufficiently defined, transparent, and auditable framework to support consistent project-level application and to minimize subjective interpretation by project proponents and VVBs.
The VVB shall assess each methodology component against the applicable ICR Methodology Requirements and the intended use of the methodology under the ICR Program.
#### Methodologies, Sources, and References
The VVB shall assess whether the methodology developer has identified and considered relevant standards, methodologies, methodological tools, scientific literature, technical guidance, datasets, regulatory documents, and other sources relevant to the methodology.
The VVB shall assess whether:
1. relevant sources are current, credible, traceable, and appropriate for the intended methodology context;
2. exclusions of relevant methodologies, tools, literature, or data sources are justified;
3. external sources are correctly interpreted and incorporated;
4. reliance on non-peer-reviewed, proprietary, or emerging sources is justified;
5. references support the criteria and procedures established in the methodology; and
6. any incorporated external criteria or procedures are consistent with applicable ICR requirements.
#### Summary Description of the Methodology
The VVB shall assess whether the methodology summary accurately and transparently describes the mitigation activity, eligible project types, methodological approach, baseline approach, additionality approach, quantification approach, monitoring requirements, applicability conditions, and key limitations.
The summary shall be sufficiently clear for intended users to understand the purpose, scope, and intended application of the methodology.
#### Definitions
The VVB shall assess whether definitions in the methodology are clear, technically accurate, internally consistent, and consistent with ICR Definitions and applicable ISO terminology.
Definitions shall not introduce ambiguity, unsupported scientific claims, or project-level discretion that could materially affect applicability, baseline, additionality, quantification, monitoring, or verification.
#### Applicability Conditions
The VVB shall assess whether the methodology provides clear, objective, and verifiable applicability conditions.
Applicability conditions shall define the project activities, technologies, practices, geographic conditions, temporal conditions, legal conditions, data conditions, carbon pools, SSRs, and other circumstances under which the methodology may be applied.
The VVB shall assess whether applicability conditions are sufficiently specific to prevent application to project activities for which the methodology’s baseline, additionality, quantification, monitoring, leakage, or non-permanence provisions would not be appropriate.
Applicability conditions shall not be open-ended and shall not rely on undefined project-level judgement where such judgement may materially affect eligibility or quantified outcomes.
#### Boundary
The VVB shall assess whether the methodology provides criteria and procedures for identifying, selecting, justifying, and documenting project, baseline, and affected GHG SSRs.
The VVB shall assess whether the methodology requires inclusion of all material GHG SSRs controlled by, related to, or affected by the project activity, including leakage sources where applicable.
The VVB shall assess whether exclusions of GHG SSRs are justified and conservative, and whether the project and baseline SSRs are equivalent and consistently treated.
#### Baseline Scenario
The VVB shall assess whether the methodology provides criteria and procedures for identifying and substantiating the baseline scenario.
The VVB shall assess whether the baseline approach:
1. is suitable for the eligible project activities;
2. reflects relevant legal, technical, economic, environmental, social, sectoral, market, policy, and technologicalcircumstances;
3. avoids artificially elevated counterfactual scenarios;
4. accounts for relevant policies, common practice, barriers, and market conditions;
5. requires a credible, transparent, documented, and repeatable process for baseline selection;
6. provides procedures for baseline updates or dynamic baselines where applicable; and
7. is sufficiently constrained to support consistent project-level application and verification.
Where the methodology uses dynamic baselines, the VVB shall assess whether update triggers, data sources, calculation procedures, monitoring requirements, timing, responsibilities, conservativeness, and verification basis are clearly specified.
#### Additionality
The VVB shall assess whether the methodology provides clear, conservative, operational, and verifiable criteria and procedures for demonstrating additionality at project level.
The methodology shall enable project proponents and VVBs to demonstrate and assess additionality in accordance with the ICR Requirement Document, the ICR Additionality Specifications, and the additionality assessment specifications in Section 7 of this document.
The VVB shall assess whether the methodology specifies, as applicable:
1. which ICR additionality levels are addressed by the methodology;
2. whether any additionality level is demonstrated at methodology level or remains to be demonstrated at project level;
3. the applicability conditions under which any methodology-level additionality conclusion applies;
4. the evidence required at project level for each applicable additionality level;
5. how the additionality demonstration shall be linked to the baseline scenario;
6. how statutory additionality or non-enforcement additionality shall be demonstrated;
7. how technology, institutional, common practice, barrier, or accelerated deployment additionality shall be demonstrated;
8. whether financial additionality may be used and, if so, the required financial evidence, assumptions, sensitivity analysis, and decision-making evidence;
9. whether policy additionality may be used and, if so, the required NDC, national inventory, authorization, or other policy-related evidence;
10. any standardized tests, benchmarks, positive lists, thresholds, validity periods, geographic limits, sectoral limits, or technology limits used to support additionality;
11. the circumstances under which project-specific facts may override or invalidate a standardized or methodology-level additionality conclusion;
12. the additionality assumptions, conditions, or external factors that shall be monitored or reported ex-post;
13. whether design changes, deviations, baseline updates, or crediting period renewals require reassessment of additionality.
Where the methodology claims that additionality is demonstrated at methodology level, the VVB shall assess whether the methodology-level demonstration is sufficiently justified, conservative, transparent, and limited by clear applicability conditions. The VVB shall also assess whether the methodology identifies any residual project-level evidence required to confirm applicability of the methodology-level additionality conclusion.
Where the methodology uses a positive list, standardized test, performance method, activity method, or benchmark, the VVB shall assess whether the criteria are clearly defined, justified, conservative, time-bound where necessary, and capable of consistent project-level validation.
Where additionality remains to be demonstrated fully at project level, the VVB shall assess whether the methodology provides sufficient project-level criteria and evidence requirements to support consistent assessment by VVBs.
The VVB shall not validate a methodology as providing automatic additionality unless the methodology clearly defines the conditions, limitations, thresholds, validity period, and project-level evidence required to demonstrate that the automatic conclusion is applicable.
The VVB shall assess whether the methodology’s additionality approach is appropriate for the project type and prevents non-additional project activities from being eligible.
#### Quantification of GHG Emission Mitigations
The VVB shall assess whether the methodology provides clear, conservative, and verifiable criteria and procedures for quantifying baseline emissions or removals, project emissions or removals, leakage, reversals, and net GHG emission mitigations.
The VVB shall assess whether equations, variables, parameters, emission factors, default values, models, and calculation procedures are complete, traceable, internally consistent, and supported by appropriate evidence.
The VVB shall assess whether the methodology identifies which parameters are fixed at validation, monitored during the crediting period, updated periodically, or selected at project level.
Where the methodology uses models, proxies, indirect measurement, sampling, scaling, or extrapolation, the VVB shall assess whether the methodology provides sufficient procedures for calibration, validation, quality control, uncertainty treatment, and conservative application.
The VVB shall assess whether the methodology addresses leakage and secondary effects that may materially affect net GHG emission mitigations, including upstream, downstream, market, activity-shifting, ecological, economic, substitution, or other leakage pathways where applicable.
#### Uncertainty and conservativeness
The VVB shall assess whether the methodology identifies material sources of uncertainty and provides appropriate procedures to quantify, manage, reduce, or conservatively account for uncertainty.
The VVB shall assess whether the methodology applies conservative assumptions, parameters, default values, uncertainty deductions, discount factors, or other conservative treatments where uncertainty may materially affect quantified outcomes.
The VVB shall assess whether uncertainty treatment is applied consistently across baseline, project, leakage, reversals and net mitigation calculations.
Where the methodology requires quantitative uncertainty analysis, the VVB shall assess whether the methodology provides suitable procedures for combining and reporting uncertainty, such as error propagation, Monte Carlo analysis, or another justified approach appropriate to the methodology context.
#### Leakage, non-permanence, and reversals
The VVB shall assess whether the methodology identifies and addresses leakage and secondary effects that may materially affect net GHG emission mitigations.
Where the methodology applies to removals, storage, GHG reservoirs, avoided extraction, containment, sealing, plugging, destruction, AFOLU activities, carbon pools, or other activities subject to reversal risk, resumed emissions, containment failure, non-performance, or loss of credited mitigation outcomes, the VVB shall assess whether the methodology includes appropriate provisions for non-permanence, reversal risk assessment, reversal monitoring, reversal quantification, reporting, corrective action, compensation, and ongoing monitoring obligations in accordance with applicable ICR requirements.
#### Monitoring
The VVB shall assess whether the methodology provides criteria and procedures for obtaining, recording, compiling, analyzing, quality-assuring, and reporting monitored data and parameters.
The VVB shall assess whether monitoring provisions are sufficient to support future verification, including requirements for:
1. monitored parameters;
2. measurement methods;
3. data frequency;
4. data sources;
5. calibration and quality assurance;
6. data gaps;
7. record retention;
8. responsible parties;
9. evidence required at verification;
10. data aggregation and calculation controls;
11. project instance or multiple-site monitoring, where applicable;
12. dynamic baseline updates, where applicable; and
13. reversal, non-permanence, or long-term monitoring obligations, where applicable.
The VVB shall assess whether default factors, standards, datasets, or externally sourced parameters used for monitoring originate from credible, traceable, and appropriate sources and whether procedures are provided for selecting values where explicit data values are not prescribed.
Where the methodology selects less accurate monitoring approaches due to practicality, cost, or feasibility, the VVB shall assess whether the methodology includes procedures to ensure conservative outcomes and adequate future verification.
Where long-term monitoring, post-crediting monitoring, reversals, or non-permanence obligations apply, the VVB shall assess whether the methodology provides sufficient criteria and procedures to support those obligations.
#### Safeguards and other benefits
Where the methodology includes safeguards, other benefits, SDG contributions, or environmental and socio-economic requirements, the VVB shall assess whether the methodology provides clear criteria and evidence requirements for project-level assessment.
The VVB shall not validate broader claims unless they are included within the applicable validation criteria and methodology scope.
Where the methodology refers to the ICR ESES-SD Tool, the VVB shall assess consistency with the tool only to the extent necessary to determine whether the methodology provides suitable project-level criteria and procedures. The ESES-SD Tool remains a project-level supporting tool unless ICR expressly requires methodology-level safeguards criteria.
#### Article 6.2 and International Transfer Related Provisions
Where the methodology includes provisions, limitations, or claims relating to Article 6.2, host country authorization, corresponding adjustment, authorized uses, vintages, quantity limits, or other international transfer-related matters, the VVB shall assess whether those provisions are clear, consistent with applicable ICR requirements, and capable of project-level validation and verification.
The VVB’s assessment shall support the methodology validation conclusion but shall not constitute ICR designation of ICCs as Article 6.2 ICCs, host country authorization, or confirmation that a corresponding adjustment has been or will be applied.
### Public consultation comments
The VVB shall consider public consultation comments and the methodology developer’s responses where such comments are relevant to the validation criteria, methodology applicability, scientific integrity, environmental integrity, baseline, additionality, quantification, monitoring, uncertainty, leakage, non-permanence, safeguards, or other material aspects of the methodology.
The VVB shall assess whether material comments have been appropriately addressed through methodology revisions, justification, clarification, or other documented responses.
The methodology validation report shall summarize how material public consultation comments relevant to validation criteria were considered.
### Completion and validation conclusion
The VVB shall evaluate whether sufficient and appropriate evidence has been obtained to support the methodology validation conclusion.
The VVB shall evaluate whether identified non-conformities, material weaknesses, clarification requests, corrective action requests, or unresolved issues have been adequately resolved before issuing an unmodified validation opinion.
Where unresolved issues remain, the VVB shall evaluate their effect on the validation conclusion and opinion in accordance with the VVB’s accredited procedures and ICR opinion requirements.
The VVB shall not issue an unmodified validation opinion where the methodology contains unresolved material issues that may:
1. result in systematic overestimation of GHG emission mitigations;
2. prevent consistent project-level application;
3. prevent future verification of material parameters or outcomes;
4. create material inconsistency with ISO 14064-2 or applicable ICR requirements;
5. undermine scientific integrity, conservativeness, or technical appropriateness; or
6. impair the usefulness of the methodology for intended users.
### Methodology Validation Report
The VVB shall prepare a methodology validation report using the applicable ICR methodology validation report template.
The methodology validation report shall provide a transparent and traceable basis for the validation opinion and shall include, as applicable:
1. methodology title, version, date, developer, and scope of validation;
2. validation criteria;
3. validation objectives and scope;
4. validation team and competence, including use of technical experts where applicable;
5. summary of validation activities and evidence reviewed;
6. assessment of scientific integrity;
7. assessment of each key methodology component;
8. treatment of public consultation comments relevant to validation criteria;
9. findings raised and their resolution;
10. unresolved issues, limitations, qualifications, or conditions;
11. conclusion and validation opinion;
12. independent review information;
13. statement that the validation opinion does not constitute ICR approval of the methodology.
Where the methodology includes Article 6.2, authorization, corresponding adjustment, or other international transfer-related provisions, the report shall identify the scope of the VVB’s assessment and state that the validation opinion does not constitute ICR designation of ICCs as Article 6.2 ICCs, host country authorization, or confirmation that a corresponding adjustment has been or will be applied.
The report shall provide a traceable basis for the VVB’s conclusion on:
1. appropriateness of the scientific basis and data sources;
2. risk of overestimation;
3. treatment of uncertainty and conservativeness;
4. adequacy of baseline, additionality, boundary, leakage, quantification, monitoring, sampling, scaling, and parameter-selection procedures;
5. adequacy of constraints on project-level discretion;
6. whether the methodology provides clear and auditable criteria for project-level application.
The methodology validation report shall identify the methodology validation team, including the team leader, team members, and any technical experts used, and shall identify the independent reviewer separately. The report shall describe the relevant competence of the team at a level sufficient to demonstrate suitability for the methodology validation scope, including scientific, technical, sectoral, methodological, quantification, monitoring, uncertainty, additionality, conservativeness, and ICR Program competence, as applicable.
Where technical experts were used, the report shall identify the subject matter for which technical expert input was used and summarize how the input was considered in reaching the validation conclusion.
The methodology validation report shall be sufficiently transparent to support ICR review, program decision-making, and intended-user understanding of the basis for the methodology validation conclusion and any subsequent methodology approval decision.
### Facts discovered after methodology validation
Where facts or new information are discovered after issuance of the methodology validation opinion that could materially affect the validation conclusion, the VVB shall address the matter in accordance with Section 10 of this document and its accredited procedures.
Such information may include, as applicable:
1. material error in the methodology;
2. material error in the validation report;
3. new evidence indicating systematic overestimation;
4. material scientific or technical development affecting the methodology’s assumptions;
5. invalid or superseded emission factors, datasets, models, or default values;
6. material inconsistency with updated ICR requirements;
7. material issues affecting project-level applications or future verification; and
8. public comments, stakeholder complaints, regulatory decisions, or ICR review findings indicating a material issue with the methodology.
Where such information could materially affect the methodology validation conclusion, the VVB shall communicate the matter to the methodology developer and ICR without undue delay.
ICR may consider such information under its methodology review, revision, suspension, or withdrawal procedures.
## Other
### ICR Oversight of VVBs
ICR oversight is part of ICR’s role as scheme owner for the ICR Program. It is intended to support consistent application of ICR requirements, assess VVB performance under the ICR Program, identify recurring issues in validation and verification, and provide input to ICR’s approval, monitoring, and review of VVBs.
ICR oversight supplements, but does not replace, oversight by accreditation bodies. ICR oversight shall not be interpreted as accreditation assessment, accreditation decision-making, or determination of conformity with ISO 14065, ISO 14064-3, ISO 14066, ISO 17029, or other accreditation requirements. Assessment of conformity with accreditation and applicable ISO requirements remains the responsibility of the relevant accreditation body.
The VVB shall cooperate with ICR oversight activities in accordance with the VVB agreement, this document, and applicable ICR Program requirements.
ICR oversight activities may include, as applicable:
1. desk review of VVB work performed under the ICR Program;
2. review of validation reports, verification reports, validation and verification reports, methodology validation reports, opinions, and supporting documentation submitted to ICR;
3. review of VVB documentation relevant to the VVB’s application of ICR Program requirements, ICR report template instructions, and engagement-specific ICR criteria;
4. review of information and supplementary documentation relating to impartiality, conflict of interest determinations, competence, team selection, technical expert use, independent review, engagement acceptance, and engagement planning, where relevant to ICR approval, monitoring, or review of the VVB;
5. review of VVB responses to ICR clarification requests, project review findings, methodology review findings, or other ICR review outcomes;
6. visits to the VVB’s offices, where relevant to ICR oversight and permitted under applicable contractual, confidentiality, accreditation, and legal requirements;
7. witnessing or observation of validation or verification activities, including onsite, remote, or hybrid activities, where relevant to ICR oversight and permitted under applicable contractual, confidentiality, accreditation, and legal requirements;
8. in-person visits to project sites or facilities, or assessment of those sites or facilities using activities and techniques applied remotely, where relevant to ICR oversight;
9. participation in or observation of accreditation body assessments, witness assessments, or other assessments, where permitted by the accreditation body, the VVB, and applicable accreditation rules;
10. analysis of recurring findings, reporting quality, consistency of opinions, materiality treatment, assessment of ICR specific criteria, use of ICR templates, and responsiveness to ICR review processes; and
11. other oversight activities necessary to assess VVB performance under the ICR Program.
The VVB shall provide information reasonably necessary for ICR to assess performance under the ICR Program and conformity with ICR Program requirements.
Where ICR identifies concerns relating to VVB performance under the ICR Program, report quality, consistency, impartiality, competence, evidence sufficiency, or application of ICR requirements, ICR may request clarification, corrective action, additional information, revised reporting, targeted training, participation in technical exchange, or other action consistent with the ICR Program and the VVB agreement.
Where ICR identifies matters that may be relevant to accreditation, conformity with applicable ISO standards, or the VVB’s accredited procedures, ICR may communicate such matters to the relevant accreditation body in accordance with the VVB agreement, applicable ICR procedures, and applicable confidentiality and legal obligations.
ICR may consider IAF MD 25 or other scheme-owner good practice documents when maintaining the ICR Program and cooperating with accreditation bodies. Such documents do not create additional validation or verification criteria for VVB engagements unless expressly specified by ICR.
ICR oversight findings do not replace the VVB’s responsibility for validation or verification opinions and do not transfer responsibility for accreditation oversight from the accreditation body to ICR.
### VVB Approval Status, Suspension, and Scope of Services
A VVB shall perform ICR validation, verification, joint validation and verification, or methodology validation activities only during the period in which the VVB is approved by ICR and has an active VVB agreement for the relevant service.
The VVB shall perform ICR engagements only within the scope of its ISO 14065 accreditation and ICR approval, including the relevant validation or verification function, sectoral scope, activity type, geographic scope, and any limitations or exclusions specified by ICR or the accreditation body.
Where the VVB’s relevant accreditation expires, is withdrawn, suspended, cancelled, or otherwise ceases to cover the relevant service, the VVB shall immediately cease performing the affected ICR services unless ICR expressly permits completion of specified activities in accordance with the VVB agreement and applicable ICR requirements.
Where ICR suspends or terminates the VVB’s approval, the VVB shall not issue validation reports, verification reports, validation and verification reports, methodology validation reports, opinions, or other documentation for the suspended or terminated services, except where expressly permitted by ICR in accordance with the VVB agreement.
The VVB shall not represent itself as approved by ICR for services, scopes, sectors, geographies, or activities for which it is not approved or where the relevant approval is suspended, expired, withdrawn, or terminated.
ICR may publish, update, suspend, or remove information on the VVB’s approval status, scope, suspension, expiry, or termination through the ICR website, registry platform, or other appropriate means.
Suspension, limitation, expiry, withdrawal, or termination of ICR approval does not affect the validity of opinions already issued unless ICR, the VVB, or the relevant accreditation body determines that further action is required under applicable procedures.
### Training and Continuous Improvement
VVBs approved under the ICR Program shall maintain sufficient knowledge of current ICR Program requirements, templates, procedures, registry processes, and relevant updates to perform ICR validation and verification engagements competently and consistently.
Before performing ICR validation, verification, joint validation and verification, or methodology validation activities, the VVB shall ensure that relevant personnel have completed or otherwise obtained training, onboarding, or technical orientation on applicable ICR requirements as required by ICR and in accordance with the VVB’s competence procedures.
Approved VVBs shall participate in ICR technical exchange, performance review, continuous improvement processes, and periodic meetings organized by ICR.
ICR may use online seminars, performance review meetings, training sessions, and other technical exchange processes to:
1. communicate updates to ICR Program documents, templates, registry processes, and requirements;
2. discuss recurring issues identified through ICR project reviews, methodology reviews, completeness reviews, or oversight activities;
3. provide non-project-specific clarification on interpretation and application of ICR requirements;
4. support consistent reporting and assessment of ICR specific criteria;
5. identify training needs and areas for continuous improvement;
6. consult VVBs on proposed updates to ICR requirements, templates, or procedures;
7. review VVB performance and implementation experience under the ICR Program; and
8. share anonymized examples, lessons learned, or common issues where appropriate.
The VVB shall ensure that information received through ICR training, technical exchange, formal clarifications, or performance review meetings is considered in relevant ICR engagements and incorporated into the VVB’s internal knowledge management, training, and engagement planning processes as appropriate.
ICR may monitor VVB training status, performance review participation, and completion of required onboarding or technical exchange activities through the ICR registry platform or other ICR systems.
### Requests for ICR interpretation
Where a VVB requires clarification on the interpretation or application of ICR requirements, the VVB may submit a request for ICR interpretation to ICR through the ICR registry platform, designated forms on the ICR website, email, or another channel specified by ICR.
A request for ICR interpretation shall identify:
1. the ICR requirement, template instruction, methodology, tool, module, or procedure for which clarification is requested;
2. the specific issue requiring clarification;
3. relevant context and background information;
4. whether the matter relates to a specific project, methodology, monitoring period, report, or general interpretation issue;
5. any confidentiality, proprietary information, or commercial sensitivity concerns; and
6. the timeframe within which clarification is needed, where relevant.
Where the request for ICR interpretation relates to a specific engagement, the VVB shall retain responsibility for its validation or verification conclusion and shall not treat ICR clarification as a substitute for sufficient and appropriate evidence, professional judgement, or conformity assessment by the VVB.
Clarifications provided by ICR are intended to explain the interpretation or application of ICR requirements. Unless expressly stated by ICR, clarifications shall not be treated as approval, registration, issuance, conversion, methodology approval, acceptance of a design change, acceptance of a deviation, or approval of a specific project activity or methodology.
ICR may decline, limit, or defer a clarification response where the request would require ICR to make a project-specific decision outside the applicable ICR process, compromise the independence of validation or verification, or prejudge an ICR review outcome.
Where ICR provides clarification of general applicability concerning the ICR Program, ICR shall make such clarification available to relevant VVBs and, where appropriate, accreditation bodies involved in the ICR Program.
Where ICR issues a formal clarification, interpretation, or program instruction of general applicability, VVBs shall consider it in relevant current and future ICR engagements in accordance with any effective date or transition provision specified by ICR.
Where a request for ICR interpretation includes confidential, proprietary, or commercially sensitive information, the VVB shall identify the confidential information and submit the request through the channel specified by ICR for such matters.
ICR may publish anonymized or general clarifications where doing so supports consistent application of ICR requirements, provided that confidential, proprietary, or commercially sensitive information is protected.
### Confidentiality and Use of Information
The VVB shall handle confidential, proprietary, commercially sensitive, and non-public information obtained through ICR engagements, ICR oversight, clarification requests, or ICR registry processes in accordance with the VVB agreement, applicable confidentiality obligations, accreditation requirements, and applicable law.
The VVB shall not disclose confidential or commercially sensitive information obtained through ICR engagements except where permitted under the VVB agreement, required by law, required by accreditation or ICR procedures, authorized by the relevant party, or necessary for the performance of the VVB’s obligations under the ICR Program.
ICR may use information submitted by VVBs for ICR review, oversight, performance monitoring, program improvement, accreditation body referral, registry administration, and other ICR Program purposes, subject to applicable confidentiality, contractual, and legal obligations.
Where information is shared with ICR as part of oversight, clarification, project review, methodology review, or other ICR processes, the VVB shall identify any information that is confidential, proprietary, or commercially sensitive.
Information included in documents intended for publication under ICR requirements shall not be treated as confidential solely because it was reviewed during validation, verification, methodology validation, or ICR oversight.
### Referral to Accreditation Bodies
Where ICR identifies evidence that may be relevant to a VVB’s accreditation, the accreditation body’s assessment of conformity with applicable ISO standards, or the VVB’s accredited procedures, ICR may refer such evidence to the relevant accreditation body in accordance with the VVB agreement, applicable ICR procedures, and applicable confidentiality and legal obligations.
Such referral does not constitute ICR assessment or determination of conformity with ISO 14065, ISO 14064-3, ISO 14066, ISO 17029, or accreditation requirements. The accreditation body remains responsible for evaluating such matters under its accreditation procedures.
Referral to an accreditation body does not replace ICR’s right to take program actions under the ICR Program or the VVB agreement, including requests for clarification, corrective action, additional information, revised reporting, targeted training, suspension, limitation of scope, or termination of approval.
ICR may cooperate with accreditation bodies in relation to scheme specific requirements, VVB oversight, clarifications, witnessed assessments, performance concerns, or other matters relevant to the effective operation of the ICR Program, provided that such cooperation does not contradict ISO 17011, ISO 14065, IAF requirements, accreditation body procedures, or applicable confidentiality obligations.
### ICR Program Maintenance and Continuous Improvement
ICR maintains ICR Program requirements, including this document and related templates, in a manner that supports consistent application by VVBs and, where relevant, understanding by accreditation bodies.
ICR may periodically update this document, report templates, process requirements, methodology requirements, tools, guidance, and related program documents based on VVB feedback, ICR project reviews, methodology reviews, oversight outcomes, accreditation developments, regulatory developments, scientific or technical developments, or other program needs.
Where updates to this document affect validation, verification, joint validation and verification, methodology validation, report content, or VVB obligations, ICR may issue transition provisions, effective dates, grace periods, template updates, or other implementation instructions.
Where changes to ICR Program requirements materially affect conformity assessment outputs or VVB obligations under the ICR Program, ICR should consider whether review, consultation, accreditation body communication, transition provisions, or other implementation measures are needed before or during implementation.
VVBs shall use the version of this document, the applicable ICR Program documents, and the applicable report template required by ICR for the relevant engagement.
Where a VVB identifies ambiguity, inconsistency, impracticality, or recurring implementation issues in this document or related ICR templates, the VVB should notify ICR.
## 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. |
| 3.0 | 9.10.2026 | Comprehensive revision following targeted consultation with approved VVBs, ICR project and methodology review experience, updates to ICR Program documents, and practical implementation experience. The revision clarifies the treatment of ICR requirements as program criteria within ISO 14064-3 validation and verification engagements; strengthens accreditation and VVB eligibility provisions; clarifies pre-engagement requirements, validation and verification criteria, objectives, scope, materiality, evidence sufficiency, reporting expectations, independent review, and opinion issuance; expands provisions for additionality, dynamic baselines, post-registration changes, deviations, non-permanence, reversals, ownership, double counting, claims, safeguards, other benefits, and Article 6.2-related matters; incorporates the ICR Environmental and Socio-economic Safeguards and Sustainable Development Tool and Monitoring Tool; strengthens methodology validation specifications, including scientific integrity and future verifiability; adds provisions for facts discovered after validation or verification; and clarifies ICR oversight, clarification requests, technical exchange, confidentiality, and scheme maintenance. |
1. Section 4, ISO 14064-2 [↑](#footnote-ref-1)
2. Section 4, ISO 14064-3 [↑](#footnote-ref-2)
3. Preliminary discussions and non-binding quotations do not constitute acceptance of an engagement. Acceptance occurs when the VVB enters into an agreement or otherwise commits to perform validation or verification activities. The VVB shall not perform any validation or verification activities before the required project status has been obtained. [↑](#footnote-ref-3)
4. A modified opinion may, for example, be appropriate where a confined matter affects an ancillary claim included in the validation scope but does not affect conformity with the criteria for registration. [↑](#footnote-ref-4)
