Event:16 September | Carbon Removal Policy Summit
Mechanisms for Enabling Corresponding AdjustmentsMarket Creation and Price Signals

MECHANISMS FOR ENABLING CORRESPONDING ADJUSTMENTS

Lever last updated: 8 September 2026

Accounting mechanisms preventing double-counting of removals across borders.

Cost

Low to Medium

Implementing corresponding adjustments requires registry infrastructure, specialist staff, cybersecurity, authorisation workflows, transaction reconciliation and ongoing UNFCCC reporting. Existing systems can be adapted, but governments building this capability from scratch face materially higher costs.

Complexity

High to Very high

Implementation requires national authorisation rules, registry and NDC-accounting infrastructure, reversal provisions, international reporting and coordination between transferring and acquiring countries. Supranational implementation also requires agreement and interoperability across multiple national systems.

Timeline

Medium to Long

Switzerland and Thailand began formal cooperation in May 2021, signed their implementation agreement in June 2022 and completed the first ITMO transfer in December 2023. This two-and-a-half-year process relied on registry infrastructure that Switzerland had operated since 2007 and Thailand had developed since 2013. Establishing the necessary legal, administrative and registry capacity without that foundation would take considerably longer.

Integrity, Transparency & MRV

3–4

Innovation & Cost Reduction

N/A

Social & Environmental Safeguards

N/A

Energy, Transport & Storage Infrastructure

N/A

Inputs & Capacity

N/A

Demand Formation

2

Bankability and Cost of Capital

2

Policy Architecture & Coordination

3–4

Overview

Corresponding adjustments are Article 6 accounting entries that prevent a mitigation outcome from being counted by both the host country and its international user. They do not alter national greenhouse-gas inventories; they adjust the emissions balance used to assess NDC achievement. This lever establishes the legal, administrative and registry mechanisms through which a host country authorises CDR units for use toward another NDC or another international mitigation purpose, including CORSIA or designated voluntary claims.

Key Considerations

Core design questions include eligible credit types and durability tiers, authorisation pathways and permitted claim types. Registry connectivity, unique serial numbers and authorisation markers can distinguish adjusted units and track their transfer, cancellation, retirement and use. CDR-specific rules need to address reversals after transfer. The framework also needs coherence with domestic NDCs, the national inventory systems feeding NDC accounting, VAT and tax treatment, and consumer-facing claims standards.

Opportunities

Enabling corresponding adjustments can unlock credible cross-border demand for removals, allowing governments and companies to finance CDR where it is most cost-effective without double counting. It can connect voluntary crediting actors with Article 6 and compliance markets, improve price discovery for adjusted durable removals and incentivise host countries to authorise high-quality projects while strengthening their domestic MRV systems.

Risks

Opaque or slow authorisation can stall markets and create arbitrage between adjusted and non-adjusted units, while over-authorisation can transfer mitigation outcomes that the host country later needs for its own NDC. Weak MRV or unclear reversal treatment can create liabilities for hosts and buyers, and poorly designed corporate claims may imply benefits the authorisation does not support. Complex registry requirements also raise cybersecurity and data-quality risks, inflate transaction costs and may exclude smaller host countries.

Monitoring and Evaluation

Monitoring & Evaluation By tracking authorisation volumes, processing times, the share of issued units subsequently authorised and first-transferred, and the premium paid for adjusted durable removals, policymakers can identify market bottlenecks. Registry reconciliation and audits of corporate claims can detect inconsistent accounting or claims. Comparing adjusted exports with host-country NDC progress can show whether transfers remain compatible with domestic mitigation needs.

Stakeholder Engagement

Coordination among environment ministries, national registries, inventory and statistics offices and tax authorities can connect authorisation decisions with NDC accounting and fiscal treatment. Engagement with developers, standards bodies and carbon exchanges can improve application and tracking systems. Consumer-protection authorities and NGOs can help align claims language with authorised uses, while MDBs and DFIs can support authorisation, digitisation and verification capacity in host countries.

Governance Levels

SupranationalNational

National governments are the primary implementing actors: the host country authorises the transfer and assumes the corresponding accounting obligation, while the acquiring country accounts for units used toward its NDC. The UNFCCC Article 6.2 Reference Manual provides the international rules for authorisation, reporting, review and corresponding adjustments, but international bodies cannot authorise units on behalf of a host country. At supranational level, the EU’s 2040 framework allows up to 5% of the target to be met through international carbon credits, which will require common rules for their quality, acquisition and accounting. This EU role is emerging rather than operational.

Implementation Strategies

  • By publishing national authorisation criteria, digital workflows and standardised Letters of Authorisation, governments can make the process more predictable and attach the authorisation status to each unit’s unique identifier.

  • Secure API links between national and crediting-programme registries can support reconciliation, while public records of authorisations, transfers and retirements can strengthen transparency.

  • Clear buffer, insurance, replacement or clawback provisions can allocate responsibility if an adjusted removal is subsequently reversed.

  • Aligning corporate claims guidance with each unit’s authorised use and running end-to-end pilots can test the complete issuance, authorisation, transfer and accounting process.

Case Studies

Switzerland–Thailand Bangkok E-Bus Programme

Switzerland and Thailand signed their Article 6 implementation agreement in June 2022. Thailand established national eligibility and authorisation procedures, issued Letters of Authorisation for the Bangkok E-Bus Programme and recorded the units through its carbon-credit registry. On 15 December 2023, 1,916 ITMOs were transferred into the Swiss Emissions Trading Registry. Thailand used cancellation and recreation rather than direct registry interoperability, demonstrating that transfers can proceed without fully connected systems. The programme concerns emissions reductions rather than CDR, so it provides an operational governance precedent rather than evidence on removal reversals.

KOKO Networks, Kenya

Kenya’s Carbon Markets Regulations, 2024 established a designated national authority and a legal process for corresponding adjustments. KOKO Networks nevertheless failed to obtain the Letters of Authorisation required for its cookstove credits to access CORSIA and other international compliance markets. Because carbon-credit revenues supported its subsidised bioethanol cooking model, the company entered an orderly wind-down in January 2026, affecting approximately 700 employees and 1.3 million customers. The case demonstrates that issuing credits and adopting regulations are insufficient without clear eligibility rules, national limits and an operational authorisation process. It concerns emissions reductions rather than CDR but directly illustrates the consequences when this lever fails.

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©2026 Alexander Mäkelä and Carbon Gap.
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