Research8 Pacm

Paris Agreement Crediting Mechanism (Article 6.4): Operational Rollout Post-COP30

Research brief for LATAM carbon project developer software. Cut-off: 25 April 2026.


1. PACM operational status — April 2026

The Paris Agreement Crediting Mechanism (PACM, Article 6.4) is now legally and operationally live, but only barely. As of late April 2026, the Article 6.4 Supervisory Body (SBM) has the following infrastructure in place:

  • One approved methodology: A6.4-AMM-001 (“Flaring or use of landfill gas,” sectoral scopes 1 & 13), adopted at SBM-19 on 29–30 October 2025 and entered into force on 25 February 2026 alongside seven approved methodological tools (AMT-001 through AMT-007 covering common-practice analysis, investment analysis, SWDS emissions, project-emissions from flaring, GHG mass-flow, equipment lifetime, and grid-electricity emissions).¹
  • Interim mechanism registry launched at SBM-15 (Thimphu, Feb 2025) with the structural skeleton mandated by SBM-PROC-REGS-001 — pending account, holding accounts (one per Party plus authorized public/private entities), retirement account, cancellation account, OMGE auto-cancellation account, and Adaptation Fund SOP account.²
  • 15 accredited DOEs (UNFCCC counts that as “the first 10 + 5 follow-ons”; press still cites the legacy “10 accredited as of late 2025” figure from the CarbonGap PACM tracker).³
  • CDM transition extended to 30 June 2026 for host-Party approval and 31 December 2026 for full documentation; CDM itself ceases all operations end-2026 with USD 26.8 M from the CDM Trust Fund transferred to the PACM Trust Fund per COP30 decision.⁴
  • Removals confirmed eligible at COP30; permanence, monitoring, and reversal-handling rules adopted but operational guidance for non-permanence still being refined through 2026.⁵
  • Upcoming SBM meetings: SBM-021 (18–21 May 2026, Bonn), SBM-022 (27–30 July 2026), SBM-023 (5–8 October 2026). MEP (Methodologies Expert Panel) meetings: MEP-014 (27 April 2026), MEP-015 (13 July 2026), MEP-016 (5 October 2026).⁶

Critically, no A6.4 emission reductions (A6.4ERs) have been issued yet — the first issuance is now expected Q3–Q4 2026 from a transitioning CDM landfill-gas project. Net-new PACM project registrations under AMM-001 are realistic for Q1 2027.


2. Methodology pipeline — what’s queued

The SBM is “working on around 19 methodologies” (Argus, Nov 2025). The MEP work-plan splits these into top-down (developed by the MEP itself; AMM-001 was the first) and bottom-up (proponent-submitted Proposed Mechanism Methodologies — PMMs).⁷

Currently in the bottom-up pipeline (PMM track) as of MEP-013 / 25 April 2026:

RefTitleSectorStatus
PMM-001Production of ammonia through electrolysisChemicalsClarifications received Feb 2026
PMM-002N₂O abatement from nitric-acid productionChemicalsClarifications Aug 2025
PMM-003Pumped-hydro storage to gridEnergyClarifications Aug 2025
PMM-004CLEAR Methodology for cooking-energy transitionsEnergy demandClarifications Aug 2025
PMM-005Savanna fire managementAFOLUClarifications March 2026
PMM-006Fertilizer production with renewables-based ammoniaChemicalsClarifications March 2026
PMM-007Recovery and plasma destruction of HFCs in ISO tanksF-gasesPublic-input window closed March 2026

Five or six PACM methodologies expected to be adopted in Q2 2026 per SBM Chair Maria AlJishi at COP30. The fastest movers are PMM-004 (cookstoves, mass demand from CDM transition), PMM-002 (N₂O nitric acid, well-trodden CDM science), and PMM-005 (savanna-fire), with PMM-001 / PMM-006 (green ammonia) close behind because the EU CRCF and ICAO CORSIA Phase II are pulling.⁷

Nature-based PACM trajectory — the LATAM-critical question. As of April 2026 there is no PACM REDD+ methodology, no PACM ARR methodology, no PACM IFM methodology, and no PACM blue-carbon methodology anywhere on the docket. Top-down work on AFOLU is still scoping. The SBM has signalled that an A/R (afforestation/reforestation) transition track is being developed for legacy CDM A/R projects (separate from the regular CDM transition because of the unique permanence/monitoring needs), with additional documentation requirements published in 2026 for compliance with the removals standard.⁸ PMM-005 (savanna fire) is the only AFOLU candidate currently advancing. Realistic earliest dates:

  • CDM A/R transition first issuances: Q4 2026 / Q1 2027 (subject to host approval by 31 Dec 2026 deadline for A/R only).
  • PACM REDD+ methodology: not before late 2027; the SBM has explicitly said it will follow rather than lead the IPCC’s REDD+ guidance and the ART/TREES + Verra interactions.
  • PACM ARR top-down methodology: 2027 at the earliest, with methodological-tools work likely running through 2028.

Engineered removals: BECCS, DACCS, biochar are all being driven through the EU CRCF (Carbon Removals and Carbon Farming) framework first; the PACM SBM is monitoring CRCF rather than developing parallel methodologies. A bottom-up biochar PMM is rumoured for SBM-022 submission but not yet logged. The biochar methodology that “entered into force 25 February 2026” widely cited in trade press is the EU CRCF compliance methodology, not a PACM methodology — frequent source of confusion.⁹

Livestock methane (enteric fermentation, manure management): only at concept-note stage in the MEP. EU CRCF feasibility report due July 2026; PACM is again expected to follow.

Implication for LATAM developers: For 18+ months PACM is essentially a landfill-gas + (soon) cookstoves + (soon) N₂O nitric acid + (soon) savanna fire mechanism. Forestry, soil carbon, peatland, and engineered-removal projects in LATAM cannot route through PACM in 2026; they must use Article 6.2 bilaterals or stay in the voluntary market, with separate authorisation if they want corresponding-adjustment treatment.


3. DOE landscape

The full list of accredited DOEs from the UNFCCC Accreditation page (April 2026):³

DOECountrySectoral scopes accreditedValid until
Carbon Check (India)India1–5, 7–10, 13–1613 Feb 2030
SustainCERT S.A.Argentina/Luxembourg1, 3, 13–156 Aug 2030
China Quality Certification Centre (CQC)China1–166 Aug 2030
Japan Quality Assurance Organization (JQA)Japan1, 3, 4, 13, 146 Aug 2030
Earthood ServicesIndia1, 3–7, 9, 10, 13–166 Aug 2030
4K Earth Science (4KES)India1–159 Oct 2030
KBS Certification ServicesKenya1–5, 7–10, 12–166 Aug 2030
Ampere for Renewable EnergyIndia1–169 Oct 2030
TÜV SÜD South AsiaIndia (regional)1–7, 9, 10, 12–1619 Feb 2031
Korean Foundation for Quality (KFQ)South Korea1–5, 7, 9, 11, 13, 159 Oct 2030
Korean Standards Association (KSA)South Korea1, 3, 4, 13–169 Oct 2030
EcoLanceIndia1, 3–5, 7, 12–1519 Feb 2031
CTI CertificationTaiwan1–1519 Feb 2031
Enviance Services (Eviance)India1–16(under review)
VERIFIT LTDABrazil1, 3–5, 7, 9, 10, 13–1619 Feb 2031

LATAM picture: Two DOEs are LATAM-domiciled or have a strong LATAM operating base — SustainCERT (registered Luxembourg but with significant Argentina/Buenos Aires office serving as its primary LATAM hub) and VERIFIT LTDA (São Paulo, Brazil, accredited Feb 2026). DNV, SCS Global, SGS, TÜV Nord, TÜV Rheinland, RINA, EPIC, Aenor — all major CDM-era LATAM validators — are not yet accredited for PACM. DNV and SGS each have applications in the pipeline; based on SBM-19 minutes, DNV is expected to land Q3 2026.

Sectoral-scope mapping (relevant to LATAM):

  • Scope 1 — Energy (renewable) — covered by 13 of 15 DOEs
  • Scope 3 — Energy demand — covered by 12
  • Scope 13 — Waste handling and disposal (incl. landfill gas) — covered by 13
  • Scope 14 — Afforestation and reforestation — covered by 12 (but no methodology yet to validate against)
  • Scope 15 — Agriculture (incl. livestock, soil, savanna fire) — covered by 13 (again, no methodology)

Practical takeaway for LATAM project developers: validation/verification for AMM-001 landfill-gas projects can be done by SustainCERT (Buenos Aires, Spanish/Portuguese capacity), Earthood (already CDM-active across LATAM), TÜV SÜD South Asia, or VERIFIT (Brazil-domiciled, Portuguese native). For nature-based projects (when methodologies exist) Scope 14/15 coverage is broad on paper but the LATAM-cultural-fit shortlist is SustainCERT, VERIFIT, Earthood.


4. CDM transition status

The CDM-to-PACM transition is the single largest near-term supply event in the carbon market. Approved figures:⁴

  • ~980 million legacy CDM CERs are eligible for transition to A6.4ERs.
  • ~128 million (13%) had been approved as of February 2026 — overwhelmingly Indian and Chinese projects.
  • 287 LATAM projects have applied for transition (CCAP report, March 2026).
  • Brazil leads with 43% of all LATAM transition applications.
  • 8 LATAM CDM projects received host-country approval to transition by end-March 2026 — the first approvals in the region following the COP30 deadline extension. Country-level breakdown not yet publicly itemised but Brazil and Honduras dominate.

June 2026 cliff. Without host-country approval (Designated National Authority issues a transition LoA) by 30 June 2026, a CDM project loses its transition window. After that date the project must re-register from scratch under PACM — meaning AMM-001 / future-PMM compliance, full PACM PDD, modern additionality demonstration. Most LATAM CDM A/R projects (Mato Grosso reforestation portfolios, Honduras hydro, Nicaragua wind) have until 31 December 2026 for full documentation but still need host approval by 30 June 2026.

LATAM CDM projects most likely to transition successfully:

  • Brazil: Salvador da Bahia and other large landfill-gas projects (direct AMM-001 fit), and Brazilian wind/hydro PoAs (waiting on PMM for renewables).
  • Honduras: ~80 small-hydro CDM projects; many will likely lapse since renewables-grid baselines no longer pass PACM additionality.
  • Mexico: ~120 CDM projects; manure-management and landfill-gas concentrate the volume. Manure-management must wait for a livestock-sector methodology.
  • Chile: ~50 CDM projects. Most are renewables or industrial-energy-efficiency; transition success depends on baseline downward-adjustment passing.
  • Colombia, Peru: smaller portfolios, mixed.

Likely abandonment cliff: Of the 287 LATAM transition applicants, our directional estimate is that <40% will successfully clear the June 2026 deadline because: (i) hydro & wind projects fail downward-baseline-adjustment under PACM; (ii) the host-country DNA process is bureaucratically slow; (iii) project participants for many CDM-era projects have dissolved or are unwilling to fund verification. Argus and Carbon Pulse both estimate global transition success at ~30–35% of registered CERs.⁴


5. A6.4ER vs Mitigation Contribution Units (MCUs) — operational decomposition

This distinction is the most software-relevant and most poorly understood operational concept in PACM. Per A6.4-PROC-REGS-001 and A6.4-Glossary-GOV-001 (entered into force 20 Feb 2026):¹⁰

Issuance:

  • All emission reductions verified under PACM are first issued into the project participant’s holding account in the mechanism registry.
  • At issuance, each unit is tagged either as A6.4ER (authorized) or MCU (Mitigation Contribution Unit).
  • Authorization is determined by whether the host Party has issued a Letter of Authorization (LoA) covering that unit at issuance time.
  • 5% of the gross issuance is auto-routed to the Adaptation Fund Share-of-Proceeds account (the AF then sells these into the secondary market or retains).
  • 2% of the gross issuance is auto-cancelled to the OMGE account (Overall Mitigation in Global Emissions). This 2% is permanently removed from circulation — irreversible cancellation.
  • Therefore the project participant nets 93% of issued tonnes.

Authorized A6.4ERs (also called AERs):

  • Have a unique identifier flagging authorized status.
  • Are fungible into Party national registries — they can leave the mechanism registry and be transferred to a buyer Party’s holding account, where a corresponding adjustment is applied.
  • Eligible for use against a buyer’s NDC, against CORSIA (subject to CORSIA’s separate eligibility check), or against “other international mitigation purposes” specified in the LoA (e.g. corporate net-zero claims under a recognised standard).
  • Can be re-authorized (e.g. a unit issued unauthorized, then later authorized — but the corresponding adjustment is then triggered retroactively at the change-of-status event).

Mitigation Contribution Units (MCUs):

  • Cannot leave the mechanism registry — only transactable inside it.
  • Cannot be used for NDC compliance, cannot be used for CORSIA, cannot trigger a corresponding adjustment.
  • Use cases: voluntary corporate “contribution claims” (not offsetting), domestic mitigation outside NDC, contribution to Adaptation Fund.
  • Pricing implication: MCUs trade at a steep discount to A6.4ERs — typically 30–50% of the A6.4ER price. As of April 2026 OTC indications: MCUs at USD 4–7/t equivalent, A6.4ERs trading USD 12–25/t (early indication; first issuance not yet occurred so these are forward indicative).

Software implication: every issued unit must have an authorization_status: "AUTHORIZED" | "MCU" field, a loa_reference link, an authorization_purpose enum (NDC | CORSIA | OMI | NONE), and a corresponding_adjustment_applied: bool flag with a ca_event_timestamp. Status can change over a unit’s life (MCU → A6.4ER on subsequent authorization), so this needs to be a versioned event log, not a static field.


6. Authorisation workflow — LoA, corresponding-adjustment booking, BTR cadence

The Letter of Authorisation (LoA) is the central document binding a host Party’s NDC commitment to a specific PACM project. The UNFCCC published a non-mandatory template (FORM-AC-003) at SBM-15 that every host has converged toward.¹¹

LoA mandatory fields (per FORM-AC-003 v3.1):

  • Authorising Party
  • Authorised entity (project participant or trader)
  • Activity ID (PACM registry reference)
  • Volume authorised (in tonnes CO₂e, or “all units issued during vintage X–Y”)
  • Authorised purpose (NDC use | CORSIA | other international mitigation)
  • Vintage range
  • Authorising signature, date, expiry
  • Corresponding-adjustment commitment statement (mandatory)
  • Whether authorization is revocable, and conditions of revocation
  • Whether the authorization triggers a CA at issuance, transfer, first use, or cancellation

The four CA-trigger events (host Party can pick one in the LoA):

  1. At first transfer (most common — Switzerland’s preference in its bilaterals)
  2. At first use (used for some CORSIA-targeted units)
  3. At first authorization (rarer)
  4. At first cancellation (used for retirement-only credits)

Operational workflow:

  1. Project registered with SBM under approved PACM methodology.
  2. Validation by accredited DOE; SBM issues registration.
  3. Verification by DOE; SBM approves emission-reduction calculations.
  4. Pre-issuance: host Party DNA reviews against NDC; issues (or does not issue) LoA.
  5. Issuance to project participant’s holding account in the mechanism registry, with units flagged authorized or MCU per LoA.
  6. SOP (5%) and OMGE (2%) auto-deduct.
  7. If authorized and a CA-trigger event occurs (e.g. transfer to a foreign Party’s national registry), the host’s reporting obligation under A6.2/A6.4 kicks in.

BTR (Biennial Transparency Report) cadence:¹²

  • Every Party submits a BTR every two years; the inaugural BTRs were due 31 December 2024 and most LATAM Parties filed in early 2025.
  • Within the BTR, the Structured Summary chapter contains the Article 6 accounting tables. The first transfer of any ITMO/A6.4ER must be reported in the Annual Information submission (separate annual filing under the Article 6.2 Reference Manual); the corresponding adjustment must be booked in the next BTR after the trigger event.
  • This means: a project transferring an A6.4ER in March 2026 must be reflected in the host’s Annual Information for 2026 (filed early 2027) and the CA must appear in the BTR-2 due 31 December 2026 or BTR-3 due 31 December 2028 depending on host’s filing cycle.
  • Software implication: developers need to produce data in the formats expected by the host DNA’s BTR templates at least 12 months before the host’s BTR deadline, otherwise the host cannot book the CA on time.

7. Active LATAM 6.4 candidates

Public Article 6.4 candidates with disclosed activity in LATAM as of April 2026:

  • Brazil: 43% of regional CDM transition applicants (~123 projects). Brazil also published “new Prior Consideration Notifications” at COP30 for net-new PACM activities (numbers not yet public; Carbon Pulse / Argus reports indicate 5–10 net-new activities under prior-consideration). Sectors: landfill-gas, sugarcane-bagasse cogeneration, hydro PoAs, and nascent biochar pilots.
  • Honduras: ~50 CDM small-hydro and biomass projects in transition. New PACM activity centred around Tela / La Mosquitia REDD+ sub-national jurisdiction (Article 6.2 first, but with PACM methodology adoption pending).
  • Peru: Government-supported pipeline of 12 candidate net-new activities under the Sweden, Switzerland, and Singapore bilateral frameworks; mainly cookstoves, anaerobic digestion, and forest-protection. PACM eligibility waits on cookstoves PMM (PMM-004) Q2 2026.
  • Colombia: ProLATAM-Carbono initiative is staging 8 candidate Article 6 activities (mainly forestry + waste). Colombian DNA (MinAmbiente) issued draft national-LoA workflow in March 2026 — first LoAs expected late 2026.
  • Paraguay: National Cadastre of Mitigation Projects launched February 2026; CAPADECO chamber created. Targeting first PACM-aligned ITMO transactions in Q3–Q4 2026 under the Singapore-Paraguay Implementation Agreement (signed May 2025). Sectors: forestry, energy, agriculture.¹³
  • Mexico: ~120 CDM projects in transition (manure-management, landfill, energy efficiency). National-DNA leadership change post-October-2024 election has slowed issuance. New PACM activity is concentrated in landfill-gas in Jalisco and Nuevo León.
  • Costa Rica: JCM partner since 2013; 4 active JCM projects. Net-new PACM submissions limited.
  • Chile: ~50 CDM projects in transition; first authorized Article 6 LATAM activity (sugar-producer biomass, with KliK) is in operation but is technically an Article 6.2 ITMO transfer rather than a PACM credit.

Volume-wise the regional PACM supply for 2026–2027 is estimated to be ~30–60 MtCO₂e of A6.4ERs (transitioned CDM only) plus ~5 MtCO₂e of net-new 6.4 issuances — modest compared to the 685 MtCO₂e cumulative ITMO-demand projection cited by IETA / Nature Conservancy / South Pole through 2030.¹⁴


8. Active LATAM 6.2 bilaterals

For most LATAM developers, Article 6.2 bilaterals are the relevant operational layer in 2026 — they are running ahead of PACM by 18–24 months.

Switzerland (KliK Foundation):¹⁵

  • Peru: Bilateral signed October 2020 (the first under Article 6.2 anywhere). KliK Peru platform live since 2022; 4 activities authorized through Q1 2026 (sustainable-rice, e-bus, cookstoves, biochar). MOPAs run to 2030 at fixed prices ~CHF 27/t average.
  • Chile: Bilateral signed December 2023; first authorized LATAM Article 6 activity (sugar-producer biomass cogeneration) operational. ~3 additional activities in pipeline.
  • Uruguay: Bilateral; one waste-to-energy activity authorized.
  • Brazil: Mid-stage — letter of intent at COP30, paving way for a bilateral.

Singapore:¹⁶

  • Peru: Implementation Agreement signed 1 April 2025 — Singapore’s first LATAM IA. Procurement target: 2.175 Mt CO₂e for 2026–2030 at ~SGD 76 M (≈ USD 56 M). First two project authorizations: Kowen Antami REDD+, Together for Forests REDD+. Note these are Verra-VCS REDD+ projects “wrapped” in 6.2 authorization — using the Singapore/Verra/Gold Standard “Article 6.2 Crediting Protocol” published at COP30.
  • Paraguay: IA signed May 2025. Agriculture, forestry, energy targets.
  • Singapore typically applies a 5% adaptation contribution (financial, separate from the 5% AF SOP) and 2% first-issuance cancellation mirroring PACM. This is a software-relevant Singapore-specific rule.

Sweden (Swedish Energy Agency):¹⁷

  • Dominican Republic: Bilateral signed 30 June 2025 (facilitated by GGGI). MOPA negotiation ongoing; first authorizations expected late 2026.

Japan (JCM):¹⁸

  • Costa Rica: JCM partner since 2013. ~6 active project authorizations.
  • Chile: Partner since 2015. Mostly EE/RE projects.
  • Mexico: Partner since 2014. ~25 JCM projects, though only a handful are formally authorized as Article 6.2 ITMO-generators.
  • JCM is now formally Article 6.2-compliant; CA bookings have started for FY2025 issuances.

South Korea:

  • Bolivia: Article 6 cooperation agreement signed late 2025; specifics still being negotiated.

United Arab Emirates:

  • Numerous LATAM MOUs at COP28/COP29; one Honduras forestry MOU advanced to LoA stage in 2026.

ITMOs actually transferred (cumulative through Q1 2026, regional, all bilaterals): public registry data is sparse but A6 Implementation Partnership reports indicate approximately ~700,000 ITMOs transferred from LATAM in total — predominantly KliK-Switzerland from Chile (sugar-producer biomass) plus a small Peru tranche. Singapore-Peru first transfers expected H2 2026.


9. Bolivia sovereign-credit architecture

Bolivia’s pivot is among the most structurally interesting LATAM developments because it links a sovereign-bond model to Article 6 issuance.¹⁹

Sequence of events:

  • 2024: Constitutional Ruling 040/2024 legalised carbon markets in Bolivia (previously prohibited by the 2009 Mother-Earth law).
  • August 2024: Laconic / Bolivia announce a USD 5 billion sovereign carbon transaction (sovereign-debt instrument backed by future ITMO issuance).
  • October 2025: Centre-right government elected; signals support.
  • November 2025 (COP30): Bolivia commits to Article 6.2 + 6.4 alignment.
  • Q1 2026: Bolivia “obtains” first sovereign carbon credits.
  • April 2026: Bolivia confirms climate-finance regulation by May 2026; broader carbon-market regulation by mid-2027.

Structure: The Laconic-Bolivia transaction is a sovereign-issued, government-backed instrument — Bolivia issues “sovereign carbon securities” tokenizing future ITMO issuance from forest-protection (REDD+) activities concentrated on public-sector + indigenous-territory land. ITMOs are intended to be authorized under Article 6.2 (with a future PACM ARR/REDD+ migration when methodology exists). Volumes targeted: USD 5 B over the deal life, with Bolivia projecting USD 20 B by 2040.

PACM-alignment: presently Article 6.2 only, because no PACM REDD+ methodology exists. The Laconic structure pre-positions for migration: deal documents include an “Article 6.4 conversion” clause once a PACM REDD+ methodology is approved. Software implication: developer registry needs to support multi-track authorisation lineage — a project initially authorised under 6.2 but later additionally authorised (or transitioned) under 6.4.

Risk: Bolivia’s restructuring, debt distress, and the institutional fragility of the carbon-finance regulator means delivery against the USD 5 B headline is doubtful in 2026; probable actual issuance 2026 is <USD 100 M.


10. Demand-side forecast

OECD ITMO-demand modelling (cited in IETA’s COP30 / Brazil brief and adapted from South Pole) puts cumulative ITMO demand through 2030 at ~685 MtCO₂e.¹⁴ Major buckets:

BuyerMandate2024–2030 volume estimate
CORSIA (Phase I + first half of Phase II)Aviation offsetting 2024–2030146–246 Mt (Phase I); +200 Mt (early Phase II)
KliK Foundation / Swiss complianceCompensate Swiss CO₂ Act emitters~30–35 Mt by 2030
SingaporeInternational offset against 5% of taxable carbon emissions~25–30 Mt by 2030
SwedenVoluntary government procurement vs. NDC~5–10 Mt by 2030
Japan JCMNDC compliance~100 Mt by 2030
Korea ETS (under consideration)Compliance ETS offsetsup to ~30 Mt by 2030
UK ETS (under consideration)Compliance ETS offsetsup to ~20 Mt by 2030
Other compliance marketsTBD (ASEAN, possibly Brazilian SBCE)residual

Pricing indications for 2026:

  • Authorized A6.4ERs (clean LATAM nature-based): USD 18–35/t (early-mover premium); landfill-gas USD 8–15/t.
  • MCUs: USD 3–8/t.
  • Switzerland (KliK): CHF 27/t average through 2030.
  • CORSIA-eligible Phase I: USD 10–20/t (Guyana floor at ~USD 21/t).
  • Singapore-procured nature-based: ~USD 25/t imputed.

The supply-demand picture is structurally short through 2027–2028 — IATA estimates aviation alone needs 146–236 Mt EEUs Phase I but only ~16 Mt Guyana supply is approved as of late 2025. PACM A6.4ERs are not yet CORSIA-eligible (this is a separate ICAO TAB approval process; the formal Article 6 ↔ CORSIA bridge was only finalised at COP30 and ICAO is still working through TAB criteria).


11. Software implications — data model

For software serving LATAM PACM-pathway project developers, the data model must be richer than CDM-era and richer than VCM-only. The minimum viable PACM data model:

Project entity:

  • pacm_activity_id (UNFCCC ref, post-registration)
  • cdm_legacy_id (for transitioning projects)
  • host_party (ISO 3166)
  • dna_reference
  • methodology_id (e.g. AMM-001)
  • methodology_version
  • sectoral_scopes (multi)
  • gps_polygon (for AFOLU)
  • crediting_period_start, crediting_period_end (max 5y renewable)
  • baseline_methodology (incl. downward-adjustment terms)
  • additionality_demonstration (link to investment-analysis tool inputs per AMT-002)
  • prior_consideration_notification_date

Issuance event (per verification cycle):

  • verification_period_start, verification_period_end
  • gross_ers_calculated
  • sop_5pct_deduction (auto-routed to AF)
  • omge_2pct_cancellation (auto-routed to OMGE)
  • net_issued_to_participant
  • unit_serial_range_start, unit_serial_range_end
  • doe_id (verifying)
  • issuance_timestamp

Per-unit-or-batch authorization state:

  • authorization_status: AUTHORIZED | MCU
  • loa_id (if authorized)
  • authorized_purpose: NDC_HOST | NDC_BUYER | CORSIA | OMI | NONE
  • authorizing_party
  • authorization_vintage_range
  • ca_trigger_event: TRANSFER | USE | AUTHORIZATION | CANCELLATION
  • ca_applied: bool
  • ca_event_timestamp
  • ca_btr_reporting_year

LoA artefact (separate entity):

  • loa_id
  • template_version (FORM-AC-003 vX)
  • host_party
  • authorized_entity
  • volume_authorized
  • purpose
  • vintage_range
  • revocability
  • revocation_conditions
  • signed_pdf_uri
  • signature_date, expiry_date

BTR-pack export (host-DNA-facing):

  • Annual-Information artefact (for first-transfer year)
  • BTR Structured-Summary tables (CA bookings)
  • Aggregated CA balances per Party per vintage

Registry-interop — at minimum:

  • Outbound to PACM mechanism registry (UNFCCC API spec still in draft at SBM-19; expected GA Q3 2026).
  • Inbound from voluntary standards (Verra, Gold Standard, ART/TREES) for projects that may need to “wrap” into PACM or 6.2.
  • Inbound/outbound to national registries (Brazil’s SINARE in stand-up, Mexico’s Proenco, Colombia’s RENARE) — each will have its own JSON schema.
  • Reconciliation against the Centralized Accounting and Reporting Platform (CARP) for ITMO transfers.

Critical software features for LATAM PACM developers:

  1. LoA tracker — manage drafts, approvals, expirations, revocations, and vintage-range matching with issued units.
  2. Corresponding-adjustment booking event log — versioned, auditable, with explicit BTR-cycle attribution.
  3. BTR pack auto-generation — produce the host-DNA-formatted Annual-Information and Structured-Summary tables.
  4. Share-of-proceeds calculator — model 5% AF + 2% OMGE + any host-specific contribution (e.g. Singapore’s additional 5% adaptation contribution, Switzerland’s 2% optional cancellation).
  5. Authorization-status state machine — MCU ↔ A6.4ER transitions, partial-authorization (e.g. 60% of units authorized for NDC, 40% retained as MCU).
  6. Methodology-version migration — track which units were issued under which methodology version, especially relevant for AFOLU when a transitioned CDM A/R project must “uplift” to PACM removals standard.
  7. Multi-track authorisation lineage — a single project may be 6.2-authorised first, 6.4-authorised later, or both simultaneously.
  8. CDM-transition workflow — explicit checklist for the 30 June 2026 host-approval deadline, the 31 December 2026 documentation deadline, and the post-deadline re-registration fallback.

12. Strategic implication

Best-positioned LATAM project types for PACM in 2026–2027:

  1. Landfill-gas in Brazil, Mexico, Colombia — direct AMM-001 path. Lowest friction to first issuance.
  2. Improved cookstoves in Peru, Honduras, Guatemala — pending PMM-004 adoption Q2 2026; KliK / Sweden / Singapore demand strong.
  3. N₂O nitric-acid abatement at large LATAM industrial sites (Brazil, Argentina) — pending PMM-002 adoption.
  4. Savanna-fire management in Brazilian Cerrado / Colombian Llanos / Paraguayan Chaco — pending PMM-005 Q2–Q3 2026.

Worst-positioned (will need 6.2 only or stay voluntary in 2026):

  • REDD+ in Brazilian Amazon, Peru, Colombia — no PACM methodology before 2027.
  • ARR plantations in Brazil, Uruguay, Paraguay — no PACM methodology before 2027.
  • Soil-carbon, blue-carbon, mangroves — even later.
  • Most renewable-energy CDM projects in continental LATAM — likely fail downward-adjustment additionality.

Critical software product features for a LATAM-developer-focused tool:

  • LoA workflow (drafting, signature collection, revocation tracking, vintage-tagging) — most acute pain point.
  • CA booking + BTR-pack generation — sells to host-DNA / national-registry users as well as developers.
  • Share-of-proceeds calculator — embed in deal economics for prospective MOPA negotiation.
  • CDM-transition advisor — checklist + status against the 30 June and 31 December 2026 deadlines.
  • Methodology-version migration tool — for projects moving from voluntary VCS/CCB to PACM.
  • Multi-registry sync (mechanism-registry + national + voluntary) — table-stakes within 18 months.
  • Spanish/Portuguese localisation — non-negotiable for LATAM developer adoption.

Partnership opportunities:

  • SustainCERT / VERIFIT / Earthood as DOE partners (data-pipe integration for verification submission).
  • KliK Foundation Peru and Chile platforms as buyer-side integration targets.
  • Singapore NCCS (since they publish a public Article-6.2 protocol).
  • Designated National Authorities in Paraguay (CAPADECO), Honduras, Colombia (MinAmbiente) — early adopters of national-registry tooling.
  • Bolivia’s emerging carbon-finance regulator — greenfield jurisdiction, low entrenched competition.

13. Risks and open issues

  • Methodology-pipeline slippage: SBM has slipped Q1-2026 commitments before. The “5–6 methodologies in Q2 2026” promise is ambitious; realistic outcome is 2–3.
  • CDM-cliff risk: if major host countries fail to process LoAs by 30 June 2026, hundreds of millions of CERs become stranded. India and China dominate this risk; LATAM exposure is smaller but Brazil’s DNA processing speed is unproven.
  • REDD+ permanence and reversal-handling: COP30 only laid foundation; operational rules incomplete. A reversal event in 2027 in a transitioned A/R project could create a scandal that delays nature-based methodologies further.
  • CORSIA-PACM bridge: the Article 6 ↔ CORSIA bridge was finalised at COP30 but ICAO TAB approval of PACM as a CORSIA-eligible programme is not automatic; risk of 12-month delay before A6.4ERs are CORSIA-usable.
  • Host-country political risk: Mexico (administration change), Colombia (Petro government end-2026), Argentina (Milei administration’s variable carbon stance), and Bolivia (regulatory immaturity) all carry near-term execution risk.
  • Adaptation-Fund SOP secondary-market depression: 5% auto-issuance to the AF means ~5% of all PACM supply will come to market through AF auctions. If concentrated, this could push spot prices down in the early years.
  • Registry-interop spec drift: voluntary-standard registries (Verra, Gold Standard) and national registries are racing PACM. If interop spec arrives late, fragmentation entrenches.
  • COP31 venue (Australia/Türkiye) uncertainty: COP31 venue not confirmed as of April 2026; uncertainty over presidency could affect the political momentum needed to push PACM into operation.
  • Voluntary-market backlash: SBTi’s evolving stance on offsets (specifically whether A6.4ERs versus MCUs versus VCM credits qualify for corporate net-zero claims) is unsettled, with corporate demand-signal volatility through 2026.

Sources / citations

  1. UNFCCC, “Methodologies — Article 6.4,” methodology page (accessed Apr 2026).
  2. UNFCCC, A6.4-PROC-REGS-001 Procedure: Article 6.4 mechanism registry (SBM-15 adoption).
  3. UNFCCC, Accreditation page — Article 6.4 PACM (full DOE list, April 2026).
  4. Fastmarkets, “Article 6.4: a six-month deadline extension keeps PACM’s doors open to roughly 1bn CDM credits” (Dec 2025); Argus, “COP: Article 6 talks extend CDM-PACM transition period.”
  5. Sylvera, “COP30 Debrief: What Really Happened for Carbon Markets in Belém”; Morgan Lewis, “COP30: Key Outcomes for Carbon Markets” (Dec 2025); Carbon Market Watch, “COP30: Attempts to dilute inadequate carbon market rules thwarted.”
  6. UNFCCC, “Meetings of the Supervisory Body.”
  7. Argus, “COP: Article 6.4 body working on 19 PACM methodologies”; UNFCCC, Methodologies page.
  8. UNFCCC, PACM Master Class (21 March 2026); UNFCCC SBM transition standard updates.
  9. EU Commission CRCF biochar methodology entry-into-force 25 Feb 2026; Carbonherald, “UN Body Greenlights First Methodology For Global Carbon Market Under Article 6.4.”
  10. UNFCCC, A6.4-Glossary-GOV-001 (entered into force 20 Feb 2026); Gold Standard, “The Mitigation Contribution under Article 6.”
  11. UNFCCC, FORM-AC-003 template; Sylvera, “Article 6 Authorizations & Corresponding Adjustments: 10 FAQs.”
  12. UNFCCC, Article 6.2 Reference Manual; A6 Implementation Partnership, “Reporting under Article 6 and linkage with ETF.”
  13. Carbon Pulse, “Paraguay’s carbon project cadastre kicks Article 6 ambitions into high gear”; NCCS Singapore, Singapore-Paraguay IA press release.
  14. Nature Conservancy / South Pole / IETA, ITMO demand projection of ~685 MtCO₂e through 2030; IATA CORSIA Fact Sheet (Dec 2025).
  15. KliK Foundation, Peru and Chile country pages; Argus, “Switzerland expects falling costs for ITMOs.”
  16. NCCS Singapore, Singapore-Peru and Singapore-Paraguay implementation agreements; Carbon Pulse, “Singapore, Peru open applications for Article 6-aligned carbon credit projects.”
  17. Swedish Energy Agency / GGGI announcement, Sweden-Dominican Republic agreement (June 2025).
  18. JCM, partner-country list (32 countries) and JCM project database via IGES.
  19. Carbon Pulse, “Bolivia to issue sovereign credits in 2026, completing about-face on carbon markets”; Carbon Pulse, “COP30: Bolivia prepares new carbon market regulation”; Carbon Credits, “Laconic and the Plurinational State of Bolivia announce landmark $5 Billion Sovereign Carbon Transaction.”

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