Paris Agreement Crediting Mechanism Seeks Feedback on First Nature-Based Removal Methodology

The Paris Agreement Crediting Mechanism (PACM) opened its first-ever proposal for a nature-based carbon removal pathway on November 5, 2026 — a methodology for CO2 removal through afforestation and reforestation on non-wetland lands — and stakeholders have until November 26, 2026 to submit feedback.

The UNFCCC Secretariat runs the call on behalf of the Article 6.4 Supervisory Body or its supporting panels. Carbon market participants now get their first look at how the world's central UN-backed crediting system intends to treat forest-based removals — a category that private registries like Verra have dominated until now.

The deadline is tight: three weeks from launch to close, with no extension announced.

What does the methodology actually require?

The proposal covers tree planting or assisted natural regeneration on croplands, grasslands or other qualifying non-forest land categories. Wetlands sit outside its scope.

The PACM describes the framework as a "highly conservative" afforestation, reforestation and revegetation (ARR) approach. It combines three structural safeguards:

• Adjusted baselines for calculating credited removals
• A reversal-risk buffer to cover carbon that escapes back to the atmosphere
• A century of post-crediting monitoring — 100 years after credits are issued

That monitoring tail is the number that will draw the most attention. It commits project developers to a liability horizon longer than most corporate entities have existed, and longer than any voluntary-market ARR standard currently demands.

The takeaway: the PACM is pricing permanence at 100 years and treating leakage and reversal as core design problems, not afterthoughts.

Which land qualifies?

Eligibility rules are strict. A site must not have qualified as a "forest" under the applicable definition at any point in the 10 years before planting starts. The land must also show no trend toward reaching forest threshold values on its own — a test aimed squarely at blocking credits for regeneration that would have happened anyway.

That 10-year lookback plus the counterfactual trend test closes off two of the most common criticism points leveled at voluntary ARR credits in recent years: hidden baselines and inflated additionality.

In plain terms: if the trees were coming back anyway, the land doesn't qualify.

What conditions bind project developers?

The methodology attaches operational constraints to every credited hectare:

• No synthetic nitrogen fertilizer use
• Soil disturbance limited to no more than 10% of the activity area
• A minimum of three different tree species planted, unless a waiver is granted
• No machinery or equipment relocation that enables additional emissions-intensive land use outside the activity boundary

That last condition is a leakage clause. It targets the scenario where activity equipment and land pressure simply shift elsewhere and generate emissions the project's ledger never records.

The species floor, meanwhile, pushes against monoculture plantations — the fastest, cheapest ARR format and the one most frequently criticized for biodiversity and fire-risk outcomes.

What else is on the table?

The ARR methodology is not the only document open for comment. The PACM released two further proposals in parallel:

• A methodology for emission reductions through coal quality improvement
• A methodology for rewetting and fire prevention on drained temperate peatlands

All three run on the same November 26, 2026 feedback deadline through the UNFCCC process.

The peatland proposal is the natural sibling to the ARR document — both land-based, both carbon-intensive pathways, both testing how the Article 6.4 machinery handles biological carbon. The coal quality methodology, by contrast, tests the mechanism's appetite for industrial fuel-side reductions.

What happens next?

The supervisory body will review submissions after November 26 and move toward adoption or revision of the methodology. If it passes, the PACM gains its first nature-based removal pathway — and the first direct competitor to registry-run ARR standards operating under UN auspices.

The milestone to watch: the Article 6.4 Supervisory Body's decision on this draft, which will set the permanence and additionality bar for every forest-removal credit the PACM issues afterward.