The Project Developer Forum (PD Forum) has written to the Gold Standard Board of Directors expressing strong concern about the retroactive application of newly proposed Paris Agreement alignment requirements to projects already registered or in late stages of development.
The PD Forum, a global network of more than 65 carbon project developers, fully supports Paris Agreement alignment for new projects. However, it warns that applying the rules retroactively risks creating serious operational bottlenecks that could undermine investor confidence and disrupt climate and community outcomes.
The retroactive rule change
A new Gold Standard rule announced on 6 October requires all credits with 2026 vintages onward to be Paris-aligned, regardless of when the project was registered or whether investment decisions were made under previous rules. Many developers would need to revise methodologies, update Project Design Documents, and undergo quasi re-validation without clear timelines.
Currently, only two Paris-aligned methodologies are actually available, and while Gold Standard has set out its own alignment schedule, it remains unclear whether all clean development mechanism (CDM) methodologies currently permitted under Gold Standard will be updated, or on what timeline. This leaves projects such as solar lighting or building efficiency with no clarity on if or when they could transition to an Article 6.4-aligned methodology.
Market and project impacts
The Forum warns this approach could recreate the system-wide backlog seen in 2020-2021 when project reviews stalled across the market. The rule change introduces a “double layer” of uncertainty: new requirements mid-crediting period, plus the signal of potential future methodology changes.
This uncertainty is already affecting real projects. Some developers have projects in validation under methodologies unlikely to be revised soon, leaving no practical pathway forward. With rising revalidation costs and potentially reduced credit volumes, certain high-integrity, community-focused projects could become economically unviable.
Host government concerns
The PD Forum highlighted significant implications for host governments. Many are now issuing Letters of Approval authorising emissions reductions for corresponding adjustments under Article 6, with far more in the pipeline than have been formally granted, and with some volumes already integrated into national Biennial Transparency Reports. Retroactive changes could disrupt national accounting and jeopardise planned climate contributions.
Nature-based projects also affected
The updated alignment schedule brings land-use methodologies, including afforestation and reforestation, rice water management, and soil organic carbon, into scope from 2026. Without grandfathering or phased transition, high-integrity nature-based portfolios could face the same disruption, affecting long-term delivery commitments and local benefit-sharing.
Ayse Frey, Co-Vice-Chair of the Project Developer Forum, said:
“Project developers fully support Paris Agreement alignment and welcome efforts to strengthen integrity. Our concern is the retroactive application of new rules to projects where investment decisions have already been made in good faith under an approved rulebook.
“Changing rules for new projects is how you raise integrity. Applying them retroactively undermines the predictability that long-term carbon finance is built on. In a market that demands clarity, persistent retroactive changes will inevitably divert investment and projects to frameworks with more stable rules. Our shared objective must be to strengthen Gold Standard as the preferred home for high-integrity climate action, not introduce risks that drive it away.
“Without clear grandfathering or transition provisions, we risk stranding high-integrity projects, damaging trust in the standard and slowing climate action at a time when the world cannot afford delays.”
The Forum reiterated its commitment to working constructively with Gold Standard to deliver Paris-aligned climate action, stressing that alignment must be implemented in a way that strengthens, not destabilises, the credibility and investability of the voluntary carbon market.
ENDS
Issued by Frame on behalf of the Project Developer Forum
For further information, please contact:
Rob Hanley, Senior Account Manager
Rob.Hanley@frame.agency | (+44) 7446 169213
About the Project Developer Forum
The Project Developer Forum is a global network and collective voice of over 65 companies and practitioners dedicated to developing and financing greenhouse gas emission reduction and removal projects.
With a diverse membership that spans all regions, we bring together in-depth technical expertise and practical experience with international carbon markets.
Our members have an extensive track record within the voluntary carbon markets and under Article 6 of the Paris Agreement, in addition to historical mechanisms such as the Clean Development Mechanism, Joint Implementation, and country-specific initiatives like Nationally Appropriate Mitigation Actions.
The Project Developer Forum plays a pivotal role in advancing the technical knowledge and credibility of carbon project development, actively engaging with global regulatory bodies to influence standards and policies. By shaping the future of emission reduction mechanisms, we ensure the continued integrity and effectiveness of carbon projects, driving progress in the global effort to mitigate climate change.
