Summary of the Public Consultation Report of 

May 21st, 2021

Taskforce on

Scaling Voluntary 

Carbon Markets

Presented to the CFTC’s Energy and Environmental Markets Advisory 

Committee June 3

rd, 2021
2

All consultation documents were developed 

through engagement with TSVCM Members 

Consultation documents were informed by extensive 

engagement with TSVCM Members

The TSVCM 

continues to grow

250+ 

institutions 

represented

400+ 

TSVCM members

100+ Subgroup or one-to-ones meetings with all Members who 

requested them on deep-dive topics

Documentation was 

shared respectively 

with the TSVCM 

Plenary, Advisory 

Board and Working 

Groups the day 

before each meeting 

and feedback was 

requested with every 

new iteration

1. Three already held, one more to come

4

Legal Principles & 

Contracts Working 

Group meetings 

4

Governance 

Working Group 

meetings 

Credit-level Integrity 

Working Group 4 meetings

3

TSVCM 

plenaries

Opportunity for all TSVCM members to 

review work across working groups

3

Advisory Board 

meetings

Opportunity for Advisory Board Members 

to review WG content and give feedback

Working Group members developed 

content and provided feedback to 

shape the next iteration of the 

document

1

2

2. Three already held, two more to come
3

The Taskforce on Scaling Voluntary Carbon Markets is a private sector-led initiative working to scale 

an effective and efficient voluntary carbon market to help meet the goals of the Paris Agreement. 

The Taskforce was initiated by Mark Carney, UN Special Envoy for Climate Action and Finance; is 

chaired by Bill Winters, Group Chief Executive, Standard Chartered; and is sponsored by the 

Institute of International Finance (IIF) under the leadership of IIF President and CEO, Tim Adams. 

Annette Nazareth, senior counsel at Davis Polk and former Commissioner of the US Securities and 

Exchange Commission, serves as the Operating Lead for the Taskforce. McKinsey & Company 

provides knowledge and advisory support. 

The TSVCM’s over 250 member institutions1, represent buyers and sellers of carbon credits, 

standard setters, the financial sector, market infrastructure providers, civil society, international 

organizations and academics. An advisory board of 20 environmental NGOs, investor alliances, 

academics and international organizations provide guidance on TSVCM recommendations. 

The Taskforce’s unique value proposition has been to bring all parts of the value chain to work 

intensively together and to provide recommended actions for the most pressing pain-points facing 

voluntary carbon markets. 

About the Taskforce

Full list of involved individuals and institutions can be found on the TSVCM website: https://www.iif.com/tsvcm

1. 53 Taskforce member institutions and 211 Consultation group member institutions
4

The Taskforce Phase II is composed of an advisory board and Working 

Groups with TSVCM members

Demand and supply 

engines

Traded volume & market 

infrastructure 

Corresponding 

Adjustments

Participant level integrity

Private Market 

Initiatives

Independent efforts

F

G

H

Taskforce Governance

Operating 

Team

Sponsor organization

Timothy Adams, CEO, Institute of International Finance (IIF)

Taskforce

Philanthropic foundations dedicated to 

making a positive difference by 

contributing to initiatives that help the 

world reach net zero

Chair Donors

Bill Winters,

CEO, Standard 

Chartered

Operating Lead

Annette Nazareth, 

Senior Counsel, Davis Polk; 

former SEC Commissioner

Taskforce & Consultation 

Group Members

~150-200 subject matter experts across the 

carbon market value chain (e.g., buyers, 

suppliers, financial intermediaries)

Stakeholder 

engagement

Narrative on the value and 

objectives of the TSVCM

Operating team led, with 

support as needed from 

Taskforce members

Cross-cutting advisory board (eNGOs, investor alliances, academics, 

international organizations) 

Newly assembled expert 

group, supported by the 

operating team

Governance Credit level integrity

Newly assembled expert 

group, supported by the 

operating team. 

Legal principles & 

contracts

Newly assembled expert 

group, supported by the 

operating team

B C D

A

Private Finance 

Hub (observer)

E

Taskforce-driven Independent, with 

input from the Taskforce 

Independent, sharing 

information with Taskforce

x Working groups Operating teamdriven

Taskforce plenary

New collaboration between EDF / 

Trove to be set up
5

The final report with Phase II recommendations will be published in July

2021

Legal 

principles & 

contracts 

Working Group

Governance 

Working Group 

Credit level 

integrity 

Working Group 

C

B

D

Cross-Cutting 

Advisory Board

Milestones

Feb Mar Apr May Jun Jul

Fri, 21 May

Start 

consultation 

phase

Mon, 21 Jun

Deadline 

consultation 

phase

Mid July

Publication of 

report

TSVCM 

Plenaries

Kick-off

Tue, 02 Mar

Tue, 09 Mar

Wed, 10 Mar

Thu, 11 Mar

Wed, 17 Mar

Tue, 23 Mar

Wed, 24 Mar

Thu, 25 Mar

Wed, 31 Mar

Tue, 13 Apr

Wed, 14 Apr

Thu, 15 Apr

Wed, 21 Apr

Tue, 27 Apr

Wed, 28 Apr

Thu, 29 Apr

pre-final version

Mon, 04 May

Thu, 06 May

Wed, 12 May

Wed, 19 May

embargoed 

version

End

Jun

pre-final 

version

Fri, 25 Jun

Mid 

July

Embargoed 

version

Tue, 02 Mar

Assemble cross-cutting 

advisory board

Public 

consultation on 

deliverables

TSVCM members 

may also fill 

public 

consultation

Provide written 

feedback by 

May 11

Provide written 

feedback by 

May 11

Provide written 

feedback by 

May 11

Provide final 

feedback by 

Jun 30 

Provide final 

feedback by 

Jun 30 

Provide final 

feedback by 

Jun 30 

Wed, 23 June Thu, 1 July

Kick-off

Tue, 02 Mar

Assemble sub-working groups 

of experts

Phase 2
6

This document is structured across four chapters

Legal principles 

& contracts

C

B Governance D Credit level integrity 

Objectives and 

focus of the TSVCM

Defined use cases to drive 

awareness of potential ways to 

use the market

Developed operational 

requirements for Standards’ 

Terms of Use

Developed general trading 

terms clauses 

Blueprint for a future governance 

body specifying its mandate, 

organizational structure, sources 

of funding and a process for its 

setup

Engagement with key stakeholders 

to drive demand and supply in 

VCMs

Draft assessment Framework for 

Standards

Analysis of credit eligibility criteria

Proposal for a taxonomy of 

additional attributes

Taskforce 

contribution

Standardizing legal framework 

underpinning credit issuance and 

trading contracts with common 

language on liability, ownership, 

delivery etc. 

A future umbrella body with a 

mandate to implement, host and 

curate a set of Core Carbon 

Principles, provide oversight over 

standard setters and coordinate 

interlinkages between 

individual bodies

Public awareness of the climate 

and co-benefits that Voluntary 

Carbon Markets can drive as an 

important complement to own-firm 

emissions reductions

Core Carbon Principle threshold 

standard that does not exclude 

credits from the market but marks 

out those that satisfy a high quality 

standard

Ambition

x Chapters in the report

A

Public consultation survey questions across topics can be found at the end of this report
7

A: Objectives and 

focus of the TSVCM

The Taskforce: Composition and activities

Credit Level Integrity: Core Carbon Principles and Additional 

Attributes

Conclusion: A historic effort

Difficulties faced by the market today

Introduction: A global issue

Legal Principles & Contracts: Harmonization and liquidity

Article 6: The Taskforce’s position

Governance: Addressing the oversight needs for an at-scale 

market

A dual ambition: High-integrity carbon credits and robust, 

transparent and liquid markets
8

A. Objectives and focus of the TSVCM (1/4)

Voluntary carbon markets began trading before the most recent international climate change agreements had been put in place. Over the last years, standard 

setters, verifiers, project developers and other market participants and associations have developed and continuously improved theses markets in the face of 

significant uncertainty. However, today’s markets remain highly fragmented and face ongoing NGO and press criticism regarding the quality of credits. The 

combination of real and perceived issues within the voluntary carbon market creates difficulties in scaling them in line with the demands of Paris.

To support the investment required to deliver the 1.5-degree pathway, the TSVCM estimates that voluntary carbon credit volume would need to grow by up to 15 

times by 2030 – while simultaneously increasing the integrity of the underlying carbon credits. This can drive billions of dollars from those emitting carbon to those 

removing carbon or preventing its emission over the next 30 years. For finance to flow to the right projects, a well-functioning voluntary carbon market with high 

integrity quality standards and robust governance is needed.

Difficulties faced by the market today

To achieve the Paris ambition of limiting the average temperature rise in this century to 1.5° Celsius, the global community needs to reach net zero emissions by no 

later than 2050. To credibly hit that target, we all need to act now, not in 2040. 

This net zero challenge requires the entire economy to change; every company, bank and investor will have to adjust their business models, develop credible plans 

for their transition, and implement them as rapidly as possible. Many countries and companies are rising to this challenge, not least by making net zero commitments 

and communicating their plans. In addition to corporates’ primary obligation to decarbonize, additional compensation and neutralization have an important role to 

play to achieve a 1.5° pathway. It is essential that any use of carbon credits which forms part of corporate climate commitments is done through high integrity and 

quality projects.

Introduction: A global issue

The TSVCM was initially convened in September 2020. A report, with 20 recommendations identifying the solutions necessary to scale voluntary carbon markets, 

was issued on January 27th 2021. TSVCM membership has continued to grow and now includes experts from across the carbon markets value chain, from more 

than 250+ organizations, 20 sectors of the economy and from six continents. To ensure the highest level of rigor and challenge, we have increased engagement and 

participation from civil society, particularly in the form of an Advisory Board, whose remit spans across all topics.

The work is not done. Between March 3rd 2021 (when the Development & Implementation phase kicked off)) and summer 2021, the Taskforce and Consultation 

Group is supporting three core topics: A) Governance, B) Legal principles & contracts, and C) Credit level integrity. This consultation document represents the 

synthesized output of this phase, to solicit input.

The Taskforce: Composition and activities
9

A. Objectives and focus of the TSVCM (2/4)

The Taskforce knows that we cannot sacrifice quality and integrity. The existing voluntary carbon market does not operate effectively due to difficulties (both real and 

perceived) in quality and integrity of the credits. The Taskforce aims to remedy this through the development of Core Carbon Principles (CCPs), a threshold standard 

for defining high quality.

The Taskforce envisions a future governance body with the mandate implement, host and curate the CCPs by evaluating which Standards and methodology types 

may issue CCP-labelled credits. The CCPs will set a new high quality benchmark surpassing existing certification.

The full definition of the CCPs will be carried out by the future governance body’s expert panel building on the Assessment Framework and the set of key 

considerations to address provided by the TSVCM. The creation of a CCP threshold standard will not exclude any credits from the market but will introduce new high 

quality removal CCP credits and high quality avoidance and reduction CCP credits that will be fungible and backed by accredited Standards.

Some corporate participants today have large teams dedicated to independent verification and purchasing of these carbon credits. While highly commendable in the 

current market context, this is inefficient and must become unnecessary as the market scales and CCP credits provide a standardized alternative.

Separate from integrity there is the question on harmonization of credits. For the voluntary carbon market to scale & operate effectively, there will need to be a core 

reference contract (similar to the one that exists for electricity in the Nordic power markets). We understand that there is concern that harmonizing carbon credits 

might reduce their quality. We believe the opposite is likely to occur. When a product follows a set of widely interrogated and codified standards, quality usually 

improves as producers are motivated to meet those standards. The Taskforce is also recommending a rigorous convergence around general trading terms, terms of 

use and high-integrity core carbon principles. 

Through “additional attributes”, we will codify attributes that all Standards that issue credits in line with Core Carbon Principles will have to specify going forward. 

These additional attributes are integral parts of what defines the carbon credits, but are not always specified today. A key example is removal vs. avoidance / 

reduction credits. This is not always specified in registries today, but will need to be included in new “additional attribute” columns in registries going forward. 

Removals vs. reductions / avoidance will be a key differentiator for corporate claims going forward. Other critical “additional attributes” that the Taskforce 

recommends include: removal/reduction method (tech vs. nature), storage method, co-benefits and corresponding adjustments

A dual ambition: High-integrity carbon credits and robust, transparent and liquid markets
10

A. Objectives and focus of the TSVCM (3/4)

Currently, voluntary carbon markets are highly complex and fragmented. On the one hand, uncoordinated Terms of Use across Standards (different onboarding 

requirements and rules of dispute resolution; uncertainty over limitation of liability and indemnity clauses) stand in the way of creating, and thereby trading, a truly 

fungible product. On the other hand, an ambiguous and uncertain legal landscape – differences across geographies, heterogenous supply chains, unclear liabilities, 

and diverging risks including fraud – create a significant burden for market participants and limits access to carbon credit trading. The Working Group on Legal 

principles and contracts seeks to contribute to streamlining the legal landscape for Standards’ Terms of Use and for trading of CCPs, by providing clarity over use 

cases, operational requirements for Standards terms of use, as well as develop general trading terms. 

Legal Principles & Contracts: Harmonization and liquidity

Governance: Addressing the oversight needs for an at-scale market

A large majority of participants in the TSVCM have emphasized that further step-changes in oversight are required, to increase the quality of credits to a level where 

buyers have the confidence to enter the market at scale. Hence the TSVCM Phase I report from January 2021 called for the development of an umbrella governance 

body with the mission to promote the integrity, liquidity and growth of the global voluntary carbon market. The need for this umbrella governance body was 

reconfirmed by an expert Governance Working Group, which consequently developed a set of concrete recommendations for the mandate, organizational design 

and implementation path for this body. The mandate is to:

i) Establish, host, and curate: a) CCP eligibility guidelines and additional attributes; b) CCP assessment framework for standard setters; c) Eligibility principles for 

suppliers and VVBs.

ii) Provide oversight over standard setting organizations on adherence to CCPs and participant eligibility / oversight.

iii) Coordinate work of, and manage interlinkages between, individual bodies. Serve as the steward for the Voluntary Carbon Market and endeavor to foster its 

responsible growth by defining a roadmap for success.

This mandate will be carried out by the four key parts of the governance body: Board of Directors (consisting of Founding Sponsor representatives and Independent 

Board Members); Expert Panel; Executive Secretariat (hosted by the Executive Secretariat Host); and member consultation group
11

A. Objectives and focus of the TSVCM (4/4)

A historic effort

This is truly a historic opportunity to contribute to getting the world to net zero, and we encourage continued participation to ensure that future initiatives set out a 

pathway toward real growth of the voluntary carbon market

The Taskforce’s position on Article 6

The Taskforce cannot deliver policy guidance on issues currently subject to international negotiations, such as the rules underpinning Article 6 of the Paris 

Agreement and ‘corresponding adjustments’. Once rules are negotiated, the voluntary market should comply with the rules of the Paris Agreement and Article 6. 

Further work will need to be done to determine how to proceed as the outcomes of the Article 6 negotiations become clearer. 

Credit Level Integrity: Core Carbon Principles and Additional Attributes

The Credit-level Integrity Working Group was established to support the future governance body, by providing input on the key documentation this governance body 

will need. In particular the governance body will need to develop the Core Carbon Principles (CCPs) which define high-quality standards as well as high-quality 

carbon credits. This will be operationalized through an assessment framework for standards as well as a set of credit eligibility guidelines. Furthermore, to enable 

trading at scale, exchanges need to be able to identify key attributes of carbon credits which they would use to develop a small set of reference contracts. Hence the 

working group has develop a set of Additional Attributes that need to be identified for each CCP credit (e.g. whether the credit is an avoidance / reduction or removal 

credit).
12

B | The Governance chapter contains two 

parts...

Call for initial engagement from (potentially) interested parties

to become a Founding Sponsor, Independent Board Member, Expert Panel Member 

and Executive Secretariat Host

Terms of Reference (ToR) for the new umbrella body

Critical governance needs for the Voluntary Carbon Market

Timeline for the implementation of the governance body

Questions for public consultation

Mission and mandate of the new umbrella governance body

Recommendation guidelines

Questions for interested parties to consider in preparation for a potential 

submission of interest

Organizational design

Funding

Operating principles, transparency and grievance mechanisms

The detailed Terms of Reference 

for the new governance body and 

a call for initial engagement from 

(potentially) interested parties 

can be found in a separate text 

document1

Please find an executive 

summary on the following pages

...which are detailed in 

a separate document

1. File name: Governance ToR & call for initial engagement from 

interested parties, can be accessed at www.iif.com/tsvcm

I

II
13

C | The Legal Working Group 

produced recommendations 

gathered in this report...

Overview and rationale of key general trading terms

which the TSVCM proposes

Additional use cases, covering a broader range of potential 

buyer needs I

II

III

... and in its technical appendix

The full language on key general trading terms which can be 

adapted to Parties’ needs and readily integrated into OTC and 

Exchange trading contracts

The full language on operational requirements for 

Standards to include in their Terms of Use in order to to issue 

CCPs 

Example use cases illustrating how standard clauses and 

procedures can help scale the market

Overview of pain points associated with the current lack 

of standardization; overview and rationale of operational 

requirements for Standards’ Terms of Use
14

D | Credit-level Integrity – Executive summary

Introduction

The Taskforce for Scaling Voluntary Carbon Markets has the mission of creating a market for high-quality carbon credits traded in robust, transparent and liquid markets. The 

consultation survey at the end of Phase I showed that credit quality was at the heart of buyers’ hesitancy in carbon markets, with 45% of buyers surveyed identifying it as a pain point. 

The Credit-level Integrity Working Group was established to support the future governance body, by providing input on the key documentation this governance body will need. In particular 

the governance body will need to develop the Core Carbon Principles (CCPs) which define high-quality Standards as well as high-quality carbon credits. 

This will be operationalized through an assessment framework for Standards as well as a set of credit eligibility guidelines. Furthermore, to enable trading at scale, exchanges need to 

be able to identify key attributes of carbon credits which they would use to develop a small set of reference contracts. Hence the working group has developed a set of Additional Attributes 

that need to be identified for each CCP credit (e.g. whether the credit is an avoidance / reduction or removal credit).

The Assessment Framework for Standards will be used by the Future Governance Body to evaluate whether Standards may issue CCP credits. It will cover both creditlevel principles (e.g. additionality) and Standard-level principles (e.g. governance). In this second phase, the Working Group has built on the high-level CCPs from Phase I to 

define the next level of detail for each CCP.

In preparing the Assessment Framework we have sought to surpass quality standards currently in the market. Among other principles, the TSVCM recommends the 

obligation to demonstrate financial additionality through profitability or return on capital considerations, the requirement to adopt baselines set by third parties and the 

requirement for Standards to maintain collective buffer pools in line with their project-portfolio risk.

Additional attributes are mandatory tags with which all registries must list CCP credits so buyers and sellers can distinguish between different types of CCP 

credits (e.g. removal and avoidance/reduction credits). Additional attributes boost the liquidity of the market by providing exchanges with a standard list of labels that is 

common to CCP credits from all registries. By distinguishing credits, additional attributes enable price differentiation for CCP credits with specific characteristics.

The current proposal for a standard taxonomy of additional attributes includes credit type (removal or avoidance/reduction), removal/avoidance/reduction method, type 

of storage (or no storage), co-benefits and a corresponding adjustments tag whose implementation will depend on the outcome of this November’s COP26. 

The Future Governance Body will be tasked with revising and updating the standard taxonomy of additional attributes; exchanges in turn will be able to base 

reference contracts for CCP credits on categories it includes.

Assessment 

Framework 

for 

Standards

Current 

eligibility 

guidelines 

analysis

Additional 

attributes

The TSVCM envisions a future governance body with the mandate to set credit-eligibility guidelines (e.g. by defining guardrails and exclusion rules) at a 

methodology type level. In order to facilitate this task, the TSVCM will handover to the future governance body an analysis of the current credit eligibility guidelines utilized 

by some of the key Standards in the market. In addition, reference points from academic literature have been included for key methodology types. 

The analysis focuses on the CCPs that are most relevant to key methodology types. We have selected the methodology types to evaluate based on the volume of 

credits in the market today and based on the future relevance of the methodology types. For the most relevant CCPs and methodology types, we have identified 

suggested questions regarding the eligibility of carbon credits that the Future Governance Body would answer.

I

II

III
15

D | Setting Core Carbon Principles is key to driving the Taskforce’s dual 

ambition

Dual ambition for 

the TSVCM 

Companies’ internal decarbonization and emissions reporting remain the 

priority with offsetting playing an important but complementary role 

...Traded in robust, 

transparent and 

liquid markets

Catalyze market players to develop 

infrastructure and solutions that promote 

data transparency, funding availability, 

ease of access and price transparency 

High-integrity carbon 

credits...

Develop core carbon principle threshold 

standard for what constitutes a high-integrity 

credit and ensure robust governance for 

overseeing it

Allowing companies to pursue corporate 

claims that require specific credit types e.g. 

removals

The Taskforce will not exclude any credits 

from the market and simply label high-quality 

CCP credits
16

D | The consultation input of the Credit-level 

Integrity Group contains 3 key parts...

Draft Assessment Framework for Standards

Questions for public consultation

... with the current 

practices analysis 

detailed in a separate 

document

Analysis of current credit eligibility criteria enforced by Standards

Initial Standard taxonomy of additional attributes

 Detailed first proposal of Standard-level CCPs

 Further operational considerations 

 Five initial additional attribute types to be refined by the 

governance body 

 Analysis of current Standard guardrails by methodology type

 Academic review of quality concerns for existing 

methodology types 

 Suggested questions to the future governance body

The analysis of current Standard 

guardrails and the academic 

review of quality concerns by 

methodology type can be found in 

the technical appendix to this 

document 

Technical Appendix can be accessed at iif.com/tsvcm

I

II

III
17

D.III | Additional Attributes can enable price differentiation for CCP 

credits with specific benefits, and drive liquidity through standardization 

Two objectives for the standard taxonomy of additional attributes

Enable a price differential for CCP credits 

with specific benefits

Drive scale and liquidity through 

standardization 

Buyers can use CCP credits with 

additional attributes to pursue specific 

claims

 Carbon neutral / Net Zero claims 

 Individual corporate claims 

(offsetting within your value chain, 

supporting a specific region)

Suppliers are incentivized to develop 

projects with specific benefits (e.g. 

removal tech)

Create contracts that utilize the same 

underlying additional attributes and 

hence drive liquidity and allow a clear 

price signal

Facilitate exchanges’ creation of 

CCP contracts by standardizing the 

attributes Standards use on CCP 

credits
18

D.III | The Credit-level Integrity Working Group proposes a 

first standard taxonomy of additional attributes 

Attribute type Attribute options

Standards already include the first crediting period start date / issuance date in credit data – but the Taskforce will 

recommend that it be included also as an attribute so that buyers can select credits based on the project’s first 

crediting period

Whether a CCP represents a 

ton of CO2e avoided/reduced or 

removed is an integral 

characteristic of the CCP that 

must be labelled by Standards 

on all CCPs. 

Standards are expected to 

increasingly tag credits within a 

methodology into removal and

avoidance/reduction 

Where not possible, credits 

would automatically belong to 

the “avoidance/reduction or 

mixed” category

Rationale

 Removal

 Avoidance /reduction or mixed

Type Distinguishing removal credits enables claims that only 

allow removal credits (e.g. SBTi Net Zero)

 Nature-based

 Tech-based

Removal/reduction 

method

There is buyer demand for credits from nature-based 

and tech-based methodology types 

 Biological

 Geological

 Products (e.g. building materials)

 No storage

Storage method Different storage methods carry different levels of 

reversal risk that buyers should be able to select for 

The combination of removal/reduction method and 

storage method creates broad categories that describe 

the type of credit without introducing a new structure of 

methodology types that would add complexity and limit 

liquidity

 Co-benefits associated (e.g. one or 

more of: tech catalyst benefits, 

SDGs, CBB or other accredited 

label etc.)

 None

Co-benefits Standards already distinguish credits with SDG benefits 

and there is demand for both ESG-tagged credits and 

credits that boost innovation in climate technology

 Letter of Authorization 

 CAs associated

 None

Corresponding 

Adjustments 

Buyers may in the future require credits with associated 

CAs or letters of Authorization

Existing credible ESG and 

social benefits certifications can 

be tagged in this attribute, for 

example, GoldStandard allows 

for up to 6 SDGs to be certified 

and VERRA tags its credits with 

a CCB standard based on 

benefits to Climate, Community 

and Biodiversity

Preliminary pending guidance 

from COP

Preliminary proposal for the future 

governance body to refine into a Standard 

Taxonomy of Additional Attributes