Civil society groups call for suspension of first-ever Article 6.4 carbon credits

6 October 2026

At least 130 organisations urge UN carbon market Supervisory Body to suspend credits and independently investigate controversial Myanmar cookstove project

UTRECHT, 6 October, 2026 — At least 130 civil society organisations, networks and other stakeholders are calling on the Supervisory Body of the Paris Agreement Crediting Mechanism (PACM) to immediately suspend the first carbon credits issued under the UN’s new “high-integrity” Article 6.4 carbon market and commission an independent, comprehensive assessment of the project behind them.

The call comes as the Article 6.4 Supervisory Body meets in Bonn from 5–9 October for its 23rd meeting (SBM 023). At the centre of the controversy is PoA 10471, a Myanmar biomass cookstove programme backed by one of South Korea’s largest companies, which, in February 2026, became the first activity to receive credit issuance under Article 6.4. 

In an open letter signed by 130 civil society organisations, the groups call on the Supervisory Body to immediately suspend the project’s credits and undertake an independent assessment, citing serious concerns about environmental integrity, verification, human rights and other safeguards and stakeholder participation, particularly given the radically changed conditions in Myanmar following the February 2021 attempted military coup.

“The first project to receive credits under the UN’s new ‘high-integrity’ carbon market was implemented in communities experiencing war, displacement and grave human rights abuses, while independent analysis indicates that, even if the project had been implemented under ideal conditions, its claimed emissions reductions may still have been substantially overstated,” said Zaw Tuseng, foundation director of the Myanmar Policy Institute. “This is not simply a question of how many credits should be issued. It raises fundamental questions about whether carbon credits can represent genuine climate action when they are separated from the political and social realities in which projects operate.”

The concerns are wide-ranging. The June 2026 report Carbon Credits Under Fire: Myanmar, Crimes Against Humanity, and the Crisis of Credibility Facing the UN’s “High-Integrity” Carbon Markets documents serious concerns about the project’s operation amid conflict and human rights abuses, as well as safeguards, stakeholder participation and the wider conditions in which its claimed emissions reductions were generated. 

PoA 10471 was designed and registered before the February 2021 attempted military coup, but continued operating during all but one month of the monitoring period underlying the first Article 6.4 issuance, from January 2021 to May 2022. Its first six component activities covered 27 townships in Myanmar’s central Dry Zone, where communities experienced documented war crimes and crimes against humanity, including attacks on civilians, forced displacement, the burning of homes and public buildings, and conflict-related sexual and gender-based violence.

Project documentation identifies the Dry Zone Greening Department and other Myanmar government authorities in connection with implementation and data collection. The Dry Zone Greening Department operates under the Ministry of Natural Resources and Environmental Conservation, which came under military control following the takeover, and is a major income earner for the junta through gemstone mining and other resource exploitation. 

The project’s monitoring documentation does not acknowledge these fundamental changes in the political, administrative and security environment or consider how they may have affected implementation and the claimed mitigation outcomes. However, verification reports indicate that security conditions prevented the verification team from conducting the required on-site inspections of monitored households in any of the project’s implementation areas. Instead, the verification team was granted an exceptional exemption and permitted remote inspection. Instead of site visits, the verification team conducted video interviews through Zoom with just 22 end-users from an office in Yangon. Only two of the interviewees were women.

Meanwhile, two independent analyses of the project’s emissions reductions calculations have raised substantial concerns about the quantity of credits issued: an earlier analysis estimated that the project was over-credited by a factor of 14 under the CDM, while more recent analysis estimates that it is still likely to be over-credited by approximately a factor of seven under Article 6.4’s supposedly tougher rules. These findings further undermine the claim that the first credits issued under the new mechanism represent genuine and verifiable emissions reductions.

“Environmental integrity cannot be reduced to accounting methodology alone. Simply refining the methodology used to calculate emissions reductions and slapping on a “high integrity” label does not guarantee that the resulting credits represent genuine mitigation, especially when they are so completely separated from the political, social and environmental circumstances in which they are supposedly generated,” said Oli Munnion, Global Forest Coalition (GFC)’s Climate Justice and Forests Campaign Coordinator. “The Paris Agreement Crediting Mechanism has fallen at the first hurdle. The Supervisory Body must immediately suspend this credit issuance and investigate how on earth it was approved in the first place.”

The organisations also raise concerns about safeguards and participation. Women and girls are presented as important beneficiaries of the cookstove programme, yet women in the project areas have experienced displacement, severe restrictions on movement and conflict-related sexual and gender-based violence. Of the 231 households surveyed for monitoring purposes, 80% of recorded heads of household were men, raising questions about whether women—whose unpaid labour the project depends on—were adequately represented as decision-makers rather than primarily as beneficiaries.

The organisations are calling on the Supervisory Body to immediately suspend any further issuance, transfer or use of credits associated with PoA 10471 and to commission an independent, comprehensive assessment of the project and the process through which the credits were approved. The assessment should examine the project’s environmental integrity, monitoring and verification, safeguards and stakeholder participation, as well as the impact of Myanmar’s radically changed political, administrative and security circumstances. 

The organisations are also calling for the assessment to consider the best available evidence and real-world conditions, rather than treating formal methodological compliance or previous validation and verification as conclusive, and for its findings to be made public. Where the evidence shows that applicable requirements were not met or that the credits do not represent genuine and verifiable emissions reductions, the Supervisory Body should take appropriate corrective action, including revoking credits already issued and preventing the project from participating further in the mechanism.

In support of these calls, a Formal Stakeholder Communication was also submitted to the Article 6.4 Supervisory Body in response to its call for stakeholder input on matters before SBM 023. The submission sets out the concerns in detail and calls for PoA 10471 to be considered under the relevant agenda items, including Agenda item 4.3 on issuance.

PoA 10471 is the first activity to receive issuance under the Article 6.4 mechanism and therefore represents an early test of what the mechanism’s stated commitment to “high integrity” means in practice.

“Climate mitigation cannot be based on human rights abuses and questionable carbon accounting. If the Article 6.4 mechanism is to have credibility, its first project must be assessed against the realities in which the claimed emissions reductions were generated, not simply against calculations on paper,” said Sooyoun Han, Plan 1.5’s Policy Activist.

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