Project Developer Forum statement on Article 6.4 draft Permanence Standard

Monday 6th October 2025: The Project Developer Forum (PD Forum) has expressed serious concerns to the Article 6.4 Supervisory Body about the draft permanence standard, warning that the current approach risks collapsing the market for nature-based solutions before it begins.

In our recent submission to the Supervisory Body, we highlighted that the consultation process for this critical standard was inadequate given its complexity and importance. Over 100 stakeholders responded to the consultation, with a majority supporting provisions that would enable naturebased projects. However, significant stakeholder input has not been fully reflected in the MEP’s response.

The proposed standard prioritises overly-conservative accounting to such an extreme degree that it threatens market viability. The narrow definition of “negligible” reversal risk, combined with potentially perpetual post-crediting monitoring requirements, creates legal uncertainties and prohibitive costs that will either heavily discount emission reductions or drive developers away entirely. What the PACM needs is accuracy in emissions accounting, not excessive conservativeness that prices nature-based projects out of existence.

We have urged the Supervisory Body to pause adoption until potential impacts can be properly assessed, and to launch a new consultation that allows adequate time for constructive stakeholder engagement. More broadly, we have requested that the SB and MEP increase timeframes for public input across all consultations in a manner proportional to the novelty and complexity of the issues at stake. Rushed consultations on complex technical matters prevent stakeholders from providing the informed, constructive feedback necessary for effective implementation. PD Forum has also requested the creation of specialised working groups to apply in-depth expertise to these implementation-critical issues.

PD Forum is deeply committed to developing global carbon markets that can scale meaningful mitigation and sustainable development impacts across the globe, in a manner that is accurate, transparent and reflecting best available scientific practices. Nature-based solutions deliver immediate, scalable, and cost-effective emissions reductions and removals alongside essential biodiversity and community co-benefits. A framework that effectively excludes such projects, against stakeholder consensus and without adequate consultation, undermines both the credibility of Article 6.4 and our collective climate goals. 

ENDS