Civil society organisations call for suspension and independent investigation into first-ever Article 6.4 carbon credits
BONN 11 June, 2026—The first carbon credits issued under the Paris Agreement’s flagship international carbon market mechanism are linked to a project implemented through institutions controlled by Myanmar’s military junta, according to a new report released today by a number of organisations including the Myanmar Policy Institute, Global Forest Coalition, and South Korean NGO Plan 1.5.
The report, Carbon Credits Under Fire: Myanmar, Crimes Against Humanity, and the Crisis of Credibility Facing the UN’s “High-Integrity Carbon Markets, raises serious concerns about human rights, governance failures, monitoring and verification practices, and the credibility of emissions reductions claimed by the project. The project distributes “improved” cookstoves in Myanmar and is coordinated by the South Korean NGO Climate Change Center (CCC) in partnership with Myanmar’s Ministry of Natural Resources and Environmental Conservation (MONREC), which has been under the control of the military junta since the February 2021 attempted coup.
“The UN has presented Article 6.4 as a new generation of high-integrity carbon markets,” said Oli Munnion, GFC Climate Justice and Forests Campaign Coordinator. “If the very first project approved under the mechanism raises this many questions about human rights, governance, monitoring and emissions accounting, then the credibility of the entire system is at stake.”
Article 6.4 is the Paris Agreement’s flagship UN-supervised international carbon market mechanism, designed to generate so-called “high-integrity” carbon credits that governments and corporations can use to offset their emissions. In February 2026, the Myanmar cookstove project became the first project anywhere in the world to issue credits under the mechanism.
The report argues that the UN’s first “high-integrity” carbon credits were issued despite a catalogue of red flags. These include the project’s implementation through institutions controlled by Myanmar’s military junta, its operation in conflict-affected regions where civilians have faced airstrikes, displacement and other grave human rights abuses, evidence that the project may have been substantially over-credited, and verification processes that were unable to conduct site visits because of security concerns.
According to the report’s authors, the case exposes a profound gap between the promises of Article 6.4 and the realities on the ground, raising fundamental questions about the credibility of the UN’s new carbon market mechanism.
Particular concern is raised about the project’s implementation in Myanmar’s central Dry Zone, including Sagaing Region, which has become the epicentre of resistance to military rule and one of the regions most heavily affected by violence since the 2021 coup. According to the report, the townships where the project was implemented experienced thousands of conflict-related incidents during the project’s crediting period, including airstrikes, artillery attacks, attacks on schools and health facilities, and widespread displacement. Sagaing alone now accounts for more than a third of Myanmar’s internally displaced population, while women and girls in the region have faced alarming levels of conflict-related sexual violence. The report argues that these realities are largely absent from project documentation and raise serious questions about how the project could be effectively implemented, monitored and verified under such conditions.
In light of the report’s findings, the organisations behind it are calling on the Supervisory Body of the Paris Agreement Crediting Mechanism (PACM) to immediately suspend any further issuance, transfer or use of credits associated with the project and launch an independent investigation into its compliance with human rights, environmental, social and methodological requirements. They are also urging the Supervisory Body to make the findings of any investigation public and, should it conclude that the project has failed to comply with PACM requirements or that the credits do not represent genuine and verifiable emissions reductions, to revoke all credits already issued and disqualify the project from future participation in the mechanism.
“Due to ongoing armed conflict on the ground, the data currently used to justify carbon credit issuance in Sagaing by the Burmese military junta is unverifiable and highly likely fraudulent,” said Zaw Tuseng, foundation director of the Myanmar Policy Institute. “This demands an immediate suspension of credit transfers until a neutral, conflict-sensitive audit can be conducted; one that redirects climate finance toward actual humanitarian and locally-led environmental initiatives.”
Ma Nini Win, also representing the Myanmar Policy Institute, added: “As someone who grew up in Sagaing, I believe that climate accountability and climate justice are critically important. Ahnyar [the Dry Zone] is facing a genuine and growing environmental crisis. Ahnyar communities are increasingly experiencing drought, irregular rainfall, flooding, water insecurity, and environmental degradation, while continuing to endure the impacts of conflict and displacement. The question is not whether climate interventions are needed. The real question is whether these interventions are designed and implemented in ways that are locally accountable, conflict-sensitive, and responsive to community realities.”
The report is being released as governments gather in Bonn for the UN climate negotiations, where discussions on the future implementation of Article 6 carbon markets are expected to continue. It also comes days after the UN Human Rights Office for Asia and the Pacific called for climate action to be grounded in legal obligations, human rights accountability and meaningful participation by affected communities.
The report documents how the project continued operating after Myanmar’s military seized power in February 2021 and through institutions controlled by the junta, despite widespread documentation of atrocities, attacks on civilians, forced displacement, conflict-related sexual violence and other serious human rights abuses.
MONREC, the project’s principal implementation partner, remained responsible for project activities after the attempted coup. For most of the project’s implementation period, the ministry was headed by Colonel Khin Maung Yi, who was sanctioned by the European Union in June 2021 for actions that contributed to the funding and support of the military regime. The report also notes that the International Criminal Court has sought an arrest warrant for junta leader Min Aung Hlaing for crimes against humanity against the Rohingya, while proceedings concerning allegations of genocide remain before the International Court of Justice.
The report further raises serious concerns about whether the carbon credits represent genuine emissions reductions relating to monitoring methodologies, assumptions about stove use, verification procedures and the inability of auditors to conduct required site visits in project areas because of security risks, relying instead on remote interviews.
Independent analysis previously undertaken by Plan 1.5, Carbon Market Watch and researchers at the University of California, Berkeley, concluded that the project may have been over-credited by more than fourteen times under the previous Clean Development Mechanism. More recent analysis by Carbon Market Watch shows that even with the supposedly more robust emissions calculations applied under Article 6.4, the project will still likely be over-credited by a factor of seven.
The new report also raises concerns about the role of South Korea in supporting and using the project. Credits generated by the cookstove programme have previously been traded through South Korea’s Emissions Trading System (K-ETS), while major Korean corporations have publicly identified the project as part of their climate strategies. The authors argue that concerns about the integrity of the credits therefore extend beyond Myanmar and the UN carbon market, raising broader questions about the standards applied within South Korea’s domestic climate policies and emissions trading system.
“From the perspectives of human rights, gender equality and environmental integrity, this cannot credibly be described as a ‘high-integrity’ carbon project,” said Sooyoun Han, Policy Activist at Plan 1.5. “Although the UN reduced credit issuance by 40 percent compared with the previous CDM methodology, the volume of credits issued still appears to be significantly overestimated. The decision to approve this project under Article 6.4 should be fundamentally reconsidered. South Korea must also adopt stronger safeguards to ensure that low-integrity credits are not used through the K-ETS or counted toward the country’s climate commitments.”
More broadly, the project exposes wider questions about climate justice and the role of carbon offsetting in global climate policy. It highlights concerns that women and girls are presented as beneficiaries of the project while continuing to bear the disproportionate impacts of conflict, displacement, food insecurity and gender-based violence.
“This does not bode well for the future of international carbon offset markets. The Paris Agreement Crediting Mechanism was supposed to be different from past market failures, and move away from scandal-hit forest offset certification schemes and the Clean Development Mechanism,” said Oli Munnion, GFC Climate Justice and Forests Campaign Coordinator. “But what does “high integrity” actually mean if the very first project to be credited is not only fundamentally flawed from an emissions reduction perspective, but is actually being implemented by a department under the control of a military junta that has been accused of crimes against humanity and is responsible for inflicting untold suffering on civilian populations? These credits must be revoked immediately, and the UN needs to seriously reassess its reliance on offsetting to meet climate goals.”
