UN reviews expose Article 6.2 carbon reporting gaps

All 15 UN Technical Expert Reviews published across 2025 and 2026 contain baseline-reporting failures, with every participating host and buyer country missing mandatory criteria for bilateral carbon-credit agreements.

Carbon Market Watch’s independent analysis of the complete review set found that each country “failed to satisfy mandatory reporting criteria.” The result covers both host and buyer governments and raises questions about the environmental integrity of credits generated through Paris Agreement Article 6.2 cooperative approaches.

What did the UN review cycle cover?

The cycle covers initial submissions from one buyer country and nine host nations:

• Buyer: Japan, across two reviewed reports.
• Hosts: Sri Lanka, Maldives, Mongolia, Palau, Tunisia, Cambodia, Malawi, Rwanda and Zimbabwe.

Japan is the only buyer in the set and appears across two reports; the host roster contains nine countries.

Designated Technical Expert Review Teams assess whether bilateral cooperative approaches meet reporting standards in the UN Article 6.2 rulebook. Carbon Market Watch found that foundational operating structures for international carbon-credit trading remain deficient across all evaluated submissions.

Why did the baseline and safeguard checks fail?

Every one of the 15 submissions contained inconsistencies in the rationale for preventing a net increase in global emissions under rule 18.H.1 and in establishing conservative baselines under 18.H.2.

The reviews also identified universal gaps in tracking infrastructure and governance. Carbon Market Watch described the pattern as reporting inconsistencies across those systems, global baselines, environmental integrity and the two Article 6.2 provisions.

Multiple host countries argued that applying corresponding adjustments was enough to ensure integrity. The technical teams rejected that position, saying corresponding adjustments “serve as accounting mechanisms rather than proof of baseline rigor or leakage mitigation.”

The distinction is central: the teams did not treat an accounting entry as a substitute for a transparent baseline rationale. Rule 18.H.1 still required the net-emissions safeguard, and rule 18.H.2 still required conservative baseline setting.

Nearly all reviewed countries also failed to document explicit human-rights protocols and social safeguards required under 18.I.2. Most cited general domestic laws or narrow gender guidelines instead of establishing monitoring protocols for Indigenous peoples, local communities, migrants and vulnerable populations.

The gap concerns monitoring, not merely recognition. General domestic laws or gender guidance did not substitute for explicit protocols covering the four named groups, according to the review analysis.

What changed at COP29?

None of the 10 countries audited during the 2026 cycle provided data on expanded reporting criteria adopted at COP29 in Baku. The criteria cover:

• avoiding emissions lock-in;
• shared mitigation outcomes; and
• public-participation frameworks.

None reported the new fields. The omission covers every audited country, rather than a limited group of submissions, leaving those newer integrity fields unverified in the published review record.

What must change before COP31?

The technical structure of the review documents complicates public scrutiny, according to the analysis. Potential shortfalls in UNFCCC administrative funding also threaten the scale and consistency of future reviews. The analysis links that risk directly to the reach and consistency of technical checks because predictable administrative funding supports comparable scrutiny across future submissions.

Correcting reporting discrepancies and establishing transparent tracking platforms will form key focal points for negotiators at COP31 in Antalya, according to Carbon Market Watch. That summit is the next checkpoint. Stable UNFCCC review funding and complete disclosures on baselines, safeguards and the COP29 criteria will determine whether the next submissions improve on the deficient first cycle.