A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure 2 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure CMIWG.ORG Acknowledgements Rights and attributions Attribution This roadmap has been prepared by the Carbon © 2024 International Bank for Reconstruction and Please cite the work as follows: The World Bank; Markets Infrastructure Working Group (CMI WG) Development / The World Bank Carbon Markets Infrastructure Working Group. 2024. convened by the World Bank. The CMI WG members “A Roadmap for Safe, Efficient, and Interoperable include: Air Carbon Exchange, B3 – Brazilian Stock 1818 H Street NW, Washington, DC 20433 Carbon Markets Infrastructure,” Washington, DC. 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Design: Simpelplus (www.simpelplus.de) Copyediting: EpsteinWords (www.epsteinwords.com) Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 3 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Table of Contents Foreword Executive Carbon Markets summary Infrastructure Working Group 6 7 8 Priority area I Priority area II Priority area III Conclusion Ecosystem Information Interoperability governance security and of data and transaction systems integrity 13 20 25 29 Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 4 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure List of Figures List of Tables Figure 1 Key challenges and recommendations to strengthen Table 1 CMI WG member organizations 8 carbon market infrastructure 7 Table 2 Identified bottlenecks in ecosystem governance Figure 2 Scope of the Carbon Markets Infrastructure within carbon markets infrastructure 18 Working Group 10 Table 3 Key concepts within information security 20 Figure 3 Priority areas identified by the Carbon Markets Infrastructure Working Group 11 Table 4 Key elements of transaction integrity 21 Figure 4 Preliminary framework for ecosystem mapping 14 Table 5 Identified bottlenecks in information security and transaction integrity 23 Figure 5 Connecting key data initiatives in carbon markets 28 Table 6 Identified bottlenecks in data and systems interoperability 27 Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 5 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Abbreviations and acronyms ABC Anti-bribery and corruption MFA Multi-factor authentication AML Anti-money laundering MRV Monitoring, reporting, verification CAD Trust Climate Action Data Trust SBSTA The Subsidiary Body for Scientific and Technological Advice, a subsidiary of the United Nations Framework Convention on CFTC Commodity Futures Trading Commission Climate Change CMI WG Carbon Markets Infrastructure Working Group TC Technical committee COP28 28th annual Conference of the Parties of the TSVCM Taskforce on Scaling Voluntary Carbon Markets United Nations Framework Convention on Climate Change UNFCCC United Nations Framework Convention on Climate Change COP29 29th annual Conference of the Parties of the United Nations Framework Convention on Climate Change VVBs Validation and verification bodies ICVCM Integrity Council for the Voluntary Carbon Market IIF Institute of International Finance IOSCO International Organization of Securities Commissions ISO International Organization for Standardization IT Information technology KYC Know your customer Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 6 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Foreword Carbon markets can be a crucial channel for climate finance in developing Building safe, efficient, and interoperable systems requires collaboration among countries, where resource needs far exceed available funding. High integrity governments, regulators, standards bodies, infrastructure providers, philanthropies, carbon markets help mobilize capital, deliver measurable emissions reductions, and nonprofit organizations. Following the roadmap launch, the World Bank and bridge investment gaps. Beyond environmental benefits, these markets enable convened the Carbon Markets Infrastructure Working Group (CMI WG) to bring projects that generate jobs and direct financial flows to communities. diverse stakeholders together, identify critical bottlenecks, prioritize actions, and develop guidelines to inform the creation of safe, efficient, and interoperable At COP28, the World Bank released its carbon markets engagement roadmap, High carbon markets infrastructure. The inaugural output from this initiative is the Integrity, High Impact: The World Bank Engagement Roadmap for Carbon Markets. Roadmap for a Safe, Efficient, and Interoperable Carbon Markets Infrastructure. This roadmap outlines our ambition to unlock the potential of high-integrity carbon markets by supporting countries in generating carbon credits and by deepening The recent UN climate negotiations in Bonn (SB60) laid the groundwork for partnerships to address key barriers to market expansion. advancing Article 6 discussions at COP29 in Baku, with parties signaling readiness to engage constructively. COP29 presents a vital opportunity to resolve remaining To scale effectively, carbon markets need safe, efficient, and interoperable issues, including decisions on the international registry systems interoperability, infrastructure. This entails (1) defining the roles and responsibilities of market and related technical, functional, and data requirements—key elements for infrastructure players—from registries to trading venues and exchanges, (2) operationalizing Article 6 under the Paris Agreement. implementing robust systems to ensure information security and transaction integrity, thereby preventing fraud, money-laundering and double counting, and Addressing bottlenecks in carbon market infrastructure is one piece of a broader (3) establishing common data frameworks and systems interoperability to enable a landscape that includes environmental, financial, and social integrity. However, globally connected market. carbon market infrastructure is the backbone and arteries of market activity. Tackling these bottlenecks head-on and early on is essential for the market to This nascent market is evolving rapidly and organically. The Paris Agreement gives develop on strong foundations. Decisions made today will shape our capacity to countries flexibility in structuring their national carbon market infrastructure. What scale these markets, mobilize climate finance, and achieve impactful emissions has emerged as a result is an agile yet fragmented landscape with inconsistent reductions. terminology and unclear governance over roles and responsibilities. Hania Dawood Practice Manager, Climate Finance and Economics, World Bank Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 7 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure FIGURE 1 Executive summary Key challenges and recommendations to strengthen carbon market infrastructure A well-structured and high-integrity carbon market has the potential to mobilize essential financing for climate Clarify ecosystem Develop an inventory and action, especially in developing countries. Achieving governance—covering recommendations for scale will require secure, efficient, and interoperable terminologies, roles, and implementing robust functions—to identify standards and infrastructure that fosters the growth and reliability of gaps, including best practices in these markets. blurred liability and Lack of clarity Insufficient information security accountability in terminologies and documentation of and transaction chains governance structures standards and practices integrity This Roadmap for a Safe, Efficient, and Interoperable   across the carbon markets related to information infrastructure security and Carbon Market Infrastructure 2024 identifies ecosystem   transaction critical bottlenecks relating to market infrastructure. integrity   Left unaddressed, these bottlenecks will impede ? scalability. These consist of i) lack of clarity in ecosystem governance structures emerging out of ambiguity in roles, liabilities, and governance structures, which may cause confusion and inefficiencies, ii) lack Insufficient of documentation of current standards and market knowledge, capacity, and practices related to information security and transaction Develop Lack of resources in Provide targeted interoperability integrity measures, which undermines stakeholder trust recommendations emerging economies capacity-building of data and for the adoption of to develop and deploy and resources in the market, and iii) insufficient data and systems standardized data systems carbon markets to countries for interoperability, which hinders exchange of information. taxonomies aligned infrastructure the development with global policies;   and deployment and stocktake of carbon market This roadmap outlines the bottlenecks and priority action and consolidate infrastructure ongoing initiatives for areas identified by the CMI WG. These action areas will a unified approach be developed into three guidance notes and released to interoperability across carbon by June 2025 to coincide with the 62nd sessions of markets Challenges United Nations Framework Convention on Climate Change (UNFCCC) Subsidiary Body for Scientific and Recommendations Technological Advice (SBSTA). Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 8 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure TABLE 1 Carbon Markets CMI WG Member Organizations Infrastructure Working Group CMI WG Member Organizations International Swaps and Derivatives Air Carbon Exchange Association (ISDA) Objectives and members B3 – Brazilian Stock Exchange International Standards Organization (ISO) For carbon markets to be effective in increasing decarbonization, they must operate with transparency, integrity, stability, accountability, and principles Climate Action Data Trust (CAD Trust) Johannesburg Stock Exchange (JSE) of orderly functioning. High Integrity, High Impact: The World Bank Engagement Roadmap for Carbon Markets released by the World Bank in December 2023 CME Group Nasdaq called for common frameworks shaping governance across the ecosystem of principles-setters, independent standards, registries, validation and verification Climate Market Strategy & Philip Lee LLP bodies (VVBs), and rating agencies; connecting markets through interoperability Infrastructure group (CMSI) between different registries and trading platforms along with transparent and Ecoregistry Puro Earth integrated market-level data; harnessing digital technologies and scaling their use, for example in measuring, reporting, and verifying emissions and reductions, which could provide a much-needed boost to the market; and building capacity through Global Carbon Council (GCC) S&P Global robust policy frameworks for carbon market infrastructure which in turn are matched with better technical and institutional capacity at the country level.1 Global Carbon Market Utility (GCMU) Sylvera The CMI WG was established to address these goals: to identify key Gold Standard US Treasury bottlenecks that hinder the security, efficiency, and interoperability of carbon market infrastructure, as well as outlining priority areas for action to address Indian Energy Exchange (IEX) Verra these challenges in the medium and long term. The entities listed in Table 1 participated in the series of meetings and consultations beginning in June 2024, Integrity Council for the Voluntary which contributed to the development of this report; the CMI WG welcomes World Bank Carbon Market (ICVCM) new members who wish to join and contribute to the ongoing discussions and workstreams. Intercontinental Exchange Xpansiv Observer: International Organization of Securities Commissions (IOSCO) Secretariat Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 9 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Scope of work CMI WG discussions and contributions draw on key principles and standards These existing initiatives are foundational to the work of the CMI WG. from leading reports and frameworks—such as those produced by ICVCM, Further, the CMI WG recognizes that public policy is crucial in defining the IOSCO, the Commodity Futures Trading Commission (CFTC), and the Institute market architecture of carbon markets and therefore CMI WG aims to cover of International Finance (IIF). For instance, the report of the IIF’s Taskforce on developments across both compliance and voluntary carbon markets. The CMI Scaling Voluntary Carbon Markets (TSVCM) called for robust data infrastructure WG has engaged and continues to have planned engagements with relevant to scale voluntary markets, prevent double counting, and ensure seamless data government counterparts across several emerging economies to capture the exchange, particularly by achieving interoperability between carbon registries challenges and necessary solutions to strengthen infrastructure across national and trading platforms.2 The IOSCO Consultation Report 2023 (CR0623) outlines carbon markets. These considerations ensure that the group’s efforts build on and crucial considerations for building resilient voluntary carbon markets, focusing align with other efforts to establish best practices and support the creation of a on open access, market integrity, transparency through publicly available data, secure, transparent, and efficient carbon market infrastructure ecosystem through interoperability, and strong governance frameworks.3 Additionally, the CFTC’s multistakeholder dialogue and collaboration. Call for Inputs 2024 (RIN 3038-AF40) proposes standards for voluntary carbon credit derivative contracts, aimed at establishing a regulated market with clear requirements for transparency and market integrity.4 CMI WG discussions and contributions draw on key guidelines and standards such as those developed by ICVCM, IOSCO, CFTC, and IIF. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 10 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure FIGURE 2 Scope of the Carbon Markets Infrastructure Working Group Carbon Markets Infrastructure Working Group Standardization, efficiency, and Enhance access to streamlined Increase capacity-building and Elevate investor confidence Objectives of Working Group unification of market infrastructure solutions for market infrastructure technical assistance support and mobilize private sector Identified Bottlenecks and Priority Areas of Action Priority Area II Priority Area I Priority Area III Priority Areas Information Security and Ecosystem Governance Data and Systems Interoperability Transaction Integrity Poor documentation and inadequate knowledge of Lack of interoperability of data and systems across Overarching Conflicting roles, responsibilities, and functions across current standards and practices related to information carbon markets value chain, combined with the absence Bottlenecks the carbon market infrastructure ecosystem security and transaction integrity of a well-defined integrated marketplace architecture Potential Asymmetry of Risks of Inconsistent Lack of robust Overlapping conflict of information inadequate Fragmented Incompatible Limited Underlying terminologies safeguards for roles and interests and and knowledge information data formats and system cross-platform Issues and technical transaction responsibilities weak incentive between market security standards architecture communication definitions  integrity structures actors measures Guidance Note on Ecosystem Governance for Carbon Guidance Note on Information Security and Guidance Note on Data and Systems Interoperability Outputs Markets Infrastructure Transaction Integrity for Carbon Markets for Carbon Markets Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 11 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure FIGURE 3 Priority areas identified by the Carbon Markets Infrastructure Working Group The CMI WG identified and prioritized three critical A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure  areas for action, targeting key bottlenecks across the carbon market value chain: Priority Area I Priority Area II Priority Area III Priority Area I: Ecosystem Governance Information Security and Data and Systems Transaction Integrity Interoperability Ecosystem Governance Establish clear, consistent terminol- Strengthen the security of infor- Enhance data harmonization and Priority Area II: ogies and frameworks; identify the mation systems and ensure the systems integration, enabling seam- roles and responsibilities of entities integrity of transactions, reducing less exchange of information across Information Security and across value chain stages to ensure the risks of fraud and enhancing platforms to enhance interopera- Transaction Integrity accountability, transparency, and trust through robust standards bility, transparency, and scalability effective coordination among all such as MFA and KYC/AML/ABC within the carbon markets market participants programs Priority Area III: Data and Systems Interoperability These three priority action areas are closely interwoven, targeting systemic bottlenecks within the carbon markets infrastructure ecosystem, including fragmentation, information asymmetry, and unclear accountability. Progress in these areas hinges on effective collaboration and alignment among stakeholders to develop a resilient and robust market infrastructure essential for sustainable carbon markets. MFA-multifactor authentication; KYC-know your customer; AML-anti-money laundering; ABC-anti-bribery and corruption Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 12 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Outputs and outcomes This roadmap is the first output of the CMI WG. It lays out the critical bottlenecks and priority areas and recommendations for building safe, efficient, and interoperable carbon market infrastructure identified in discussions. It also features The CMI WG seeks to offer practical, a dynamic, evolving mapping of the carbon markets ecosystem, which will be actionable guidance to accelerate progress in updated throughout the work on priority area I. building a reliable, high-impact carbon market The bottlenecks outlined in this roadmap focus on highlighting priority infrastructure capable of delivering meaningful areas that demand the stakeholder community’s attention within the market climate outcomes. infrastructure space. It establishes a foundation for the CMI WG’s future agenda, which consists of developing comprehensive guidance notes that delve deeper into each identified priority area. These detailed guidance notes are scheduled for release in June 2025, when the 62nd sessions of the UNFCCC SBSTA will occur. • Guidance Note on Ecosystem Governance for Carbon Markets Infrastructure • Guidance Note on Transaction Integrity and Information Security for Carbon Markets • Guidance Note on Interoperability of Data and Systems for Carbon Markets Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 13 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Priority area I Ecosystem governance Scope Priority area I of the CMI WG centers on mapping and clarifying current The CMI WG conducted a preliminary ecosystem mapping, which can be ecosystem governance within carbon markets, with an emphasis on identifying found here as a living and evolving resource. It includes a comprehensive list key entities and functions within market infrastructure. of terminologies, technical definitions, functionalities, and entities, covering all stages of the carbon cycle process (both pre- and post-issuance). This mapping The bottom-up nature of carbon markets under the Paris Agreement has effort is a first step to establishing a common understanding of the components created complexity and allowed for a diverse set of requirements for policy of the carbon market infrastructure ecosystem, and will it help stakeholders assess and regulatory frameworks and carbon market infrastructure at both national potential inconsistencies, overlaps, and conflicts of interest across the value chain. and international levels. This has led to a fragmented ecosystem, marked by Figure 4 provides a visual representation of the framework and mapping. inconsistencies in terminologies and ambiguous governance over stakeholder roles, responsibilities, and functions. As a result, the chain of liability and The following infographic (Figure 4) maps the main entities in the carbon markets accountability across the carbon market value chain has become unclear. infrastructure and their respective functionalities. Entities are categorized by their Additionally, the growing number of participants has heightened the risk of errors roles in pre-issuance, post-issuance, and regulatory and governance functions. The and fraud, underscoring the urgent need for transparent, reliable infrastructure top row of the infographic displays a sequential list of functionalities progressing and standardized digital systems to support the effective functioning of carbon from pre-issuance to post-issuance. Each functionality is associated with a set markets. of entities classified by their roles and degree of involvement, whether direct or indirect, in implementing each function. For detailed information and specific examples, please refer to the aforementioned preliminary ecosystem mapping. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 14 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure FIGURE 4 Preliminary framework for ecosystem mapping Clustering Functionalities and Entities Functionalities Entities Functionalities: Pre-issuance/primary Entities: Pre-issuance Entities: Post-issuance Methodology creation 1. Project developer 9. Data aggregation Project design and development 2. Register/Accounting and tracking registry 10. Data reconciliation/mapping Validation 3. Registry with transaction functionality 11. Data analytics Due diligence/KYC & AML verification 4. Infrastructure providers 12. Traders Information security 5. Multilateral organizations 13. Primary market trading infrastructure: Auction platforms Registration 6. Carbon crediting program/standard setters 14. End user Project implementation Verification and validation body/certification bodies/ 15. Brokers 7. third party auditors Measurement, reporting, and verification 16. Retail aggregators/traders 8. Methodology validator Third-party verification/review 17. Secondary market trading infrastructure: Exchange Certification Secondary market trading infrastructure: 18. Entities: Regulatory/governance Over the counter market 19. Post trade infrastructure: Clearing house 25. Standardized contract hosts Functionalities: Post-issuance/post-trade/secondary 20. Trade repository 26. Demand-side integrity standards Issuance 21. Carbon credit rating 27. Supply-side integrity standards Authorization 22. Carbon insurance 28. Carbon accounting standard setters Labeling 23. Disclosure regulation 29. Financial regulators First transfer 24. Web3 platform 30. Market regulators Trading 31. Financial accounting standard setters Settlement/clearing/fulfilment 32. UNFCCC Retirement/cancellation 33. UNFCCC 33. National governments Reporting Post trade infrastructure Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 15 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Mapping Functionalities (Pre-Issuance) to Entities Due diligence/ Measurement, Functionality Methodology Project design Information Project Third-party Validation KYC & AML Registration reporting, and Certification creation and development security implementation verification/review verification verification 2. Register/ 2. Register/ 2. Register/ 6. Carbon crediting accounting and 1. Project developer accounting and accounting and program/standard tracking registry 5. Multilateral 7. Verification tracking registry tracking registry 7. Verification 7. Verification Pre-issuance setters 3. Registry with 6. Carbon organizations and validation body 3. Registry with 3. Registry with and validation body and validation body entity 7. Verification and (VVB) transaction transaction transaction 1. Project developer (VVB) (VVB) crediting program/ validation body (VVB) 6. Carbon crediting functionality standard setters program/standard functionality functionality 8. Methodology 6. Carbon setters 4. Infrastructure 4. Infrastructure validator crediting program/ providers providers standard setters 6. Carbon crediting 6. Carbon crediting 6. Carbon crediting Regulatory/ 29. Financial 6. Carbon crediting 27. Supply-side program/standard program/ program/ 27. Supply-side regulators 33. National program/standard 33. National governance integrity standards integrity standards setters governments setters governments Standard setters Standard setters 32. UNFCCC 33. National Entity 33. UNFCCC 33. National governments 32. UNFCCC 33. National 33. National governments governments governments UNFCCC to play a role where applicable. May not have a role to play in case of certification under VCM​ Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 16 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Mapping Functionalities (Post-Issuance) to Entities Settlement/ Retirement and Post-trade Issuance Authorization Labelling First transfer Trading Reporting clearing/fulfilment cancellation infrastructure 1. Project developer 1. Project developer 1. Project developer 2. Register/Accounting 3. Registry with 4. Infrastructure and tracking registry 2. Register/accounting 3. Registry with providers 4. Infrastructure transaction 6. Carbon crediting Pre-issuance and tracking registry transaction functionality providers 3. Registry with 4. Infrastructure functionality program/ 6. Carbon crediting 1. Project developer transaction providers entity 6. Carbon crediting 3. Registry with standard setters 6. Carbon crediting program/ functionality transaction program/ standard setters program/ functionality standard setters standard setters 12. Traders 13. Primary market trading infrastructure: 12. Traders Auction platforms 13. Primary market 14. End user 14. End user 9. Data aggregation 13. Auction trading infrastructure: 15. Brokers 14. End user 23. Disclosure 10. Data reconciliation/ Post- platforms Auction platforms 21. Carbon credit rating 13. Primary market 14. End user regulation mapping issuance trading infrastructure: 16. Retail aggregators/ 19. Post trade 14. End user 23. Disclosure 11. Data analytics 23. Disclosure 22. Carbon insurance traders infrastructure: 33. National entity regulation Auction platforms Clearing house regulation governments 15. Brokers 17. Exchange 21. Carbon credit rating 16. Retail aggregators/ 18. Over the Counter 22. Carbon insurance traders market 20. Trade repository 24. Web3 platform 28. Carbon accounting 24. Standardized standard setters contract hosts 29. Financial 27. Supply-side 26. Demand-side 26. Demand-side 29. Financial regulators 25. Demand-side 24. Standardized regulators Regulatory/ integrity standards integrity standards 27. Supply-side 32. UNFCCC integrity standards Integrity standards 30. Market regulators contract hosts 30. Market regulators governance 32. UNFCCC 32. UNFCCC integrity standards 33. National 28. Financial regulators 32. UNFCCC 31. Financial accounting 28. Financial 32. UNFCCC Entity 33. National 33. National 32. UNFCCC governments regulators 33. National standard setters 29. Market regulators 33. National governments governments governments 32. UNFCCC 32. National governments governments 33. National governments Role of actors will change as negotiations around ‘first transfer’ are finalised. The stage at which the first transfer takes place will affect the entities involved See Legend here Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 17 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure State of play The CMI WG’s ecosystem mapping builds on and is informed by prior efforts. The ecosystem mapping effort by the CMI WG takes a step further, offering a These include the 2021 TSVCM report and the World Economic Forum’s 2023 more granular and comprehensive scope by delving into detailed entities and report Scaling Voluntary Carbon Markets. TSCVM’s map categorized participants functionalities with laid-down definitions. Further, this effort goes beyond the into three main groups: supply-side actors, demand-side actors, and market core stages of the carbon asset creation process, encompassing sub-stages intermediaries.5 The World Economic Forum identified key players and their of both pre- and post-issuance phases, establishing a foundational analytical roles within the voluntary carbon market and highlighted the core functionalities framework. It also includes an assessment of potential bottlenecks (Table 2) across the market, focusing on the interconnectedness of entities and their in the carbon market infrastructure ecosystem, providing a basis for assessing contributions to scaling the market.6 The CMI WG has also drawn on the growing potential overlaps, gaps, and conflicts of interest. This will enable stakeholders to body of work that provides technical definitions of processes and functionalities better understand and address inefficiencies within the current carbon markets related to carbon asset creation, thereby clarifying and formalizing the processes infrastructure. that underlie carbon asset creation and trading. These include IOSCO’s analyses offering standardized definitions and frameworks for understanding how voluntary and compliance carbon markets operate, which address critical components like market oversight, transparency, and integrity.7 As well a recent ICVCM report introduces widely accepted definitions for key market functions, establishing essential criteria for carbon credits.8 The ecosystem mapping effort by the CMI WG takes a step further, offering a more granular and comprehensive scope by delving into detailed entities and functionalities with laid- down definitions. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 18 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure TABLE 2 Identified bottlenecks in ecosystem governance within carbon markets infrastructure A lack of consistent terminologies and definitions is creating confusion. For instance, a carbon crediting registry might be referred to as the “register,” “issuance registry,” Inconsistent or “transaction registry,” leading to ambiguity about its specific functions. Similarly, the term “monitoring, reporting, and verification (MRV) system” is applied to systems terminologies and encompassing various standards and processes across both national and project levels. There is a need for more standardized and precise terminology to reduce confusion technical definitions and enhance clarity. Roles and responsibilities within carbon market infrastructure often overlap significantly among entities, leading to potential inefficiencies. For instance, registries may Overlapping roles and be managed at the national level by individual countries, centralized under the UNFCCC, or operated by independent standard bodies, exchanges, and other infrastructure responsibilities providers. Additionally, multiple actors frequently perform similar functions—such as issuance, tracking, verification, certification, and retirement of credits—resulting in redundancy and blurred lines of accountability. Conflicts of interest and weak incentive structures pose significant challenges to the carbon market’s integrity and credibility. Without the right safeguards, financial motivations and misaligned responsibilities could undermine the rigor of project validation, risking environmental outcomes. For instance, if project developers select and pay Potential conflicts VVBs, these bodies may feel pressured to deliver favorable assessments to secure repeat business. Similarly, fee structures based on credit volume could incentivize quantity of interest and weak over quality, potentially allowing projects to pass with insufficient scrutiny if robust safeguards are lacking. Limited accreditation and enforcement for VVBs could also lead to incentive structures inconsistent validations if weak oversight allows underperforming VVBs to operate without consequence, eroding trust and threatening the market’s long-term sustainability. While some standards bodies and market actors have implemented mitigation measures, universal adoption across all standards operating in the market is necessary to ensure consistency and integrity. Roles and responsibilities within carbon market infrastructure often overlap significantly among entities, leading to potential inefficiencies and blurred lines of accountability Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 19 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Way forward The next stage of the CMI WG’s work in this priority area is to develop a detailed • Incorporation of technical deep dives and stakeholder consultations: guidance note to enhance clarity and foster a common understanding of The guidance note will be shaped by comprehensive technical deep dives ecosystem governance within the carbon market infrastructure. This guidance and consultations with CMI WG members, subject-matter experts, and note will build upon initial ecosystem mapping efforts, offering a comprehensive practitioners, ensuring a well-rounded and evidence-based approach. assessment and laid-down technical definitions for entities and functionalities across the lifecycle from pre-issuance to post-issuance. The guidance note will be • Integrating findings into capacity-building and technical assistance for based primarily on three efforts: countries: Findings from this workstream will inform the development of capacity-building and technical assistance activities, tailored to address the • Diagnostic assessment of governance structures: Building on the framework diverse capacities and requirements across different markets. This targeted established in the preliminary ecosystem mapping (Figure 4), the guidance note support will contribute to a cohesive and resilient carbon market infrastructure. will present a diagnostic assessment of roles and responsibilities, identifying potential overlaps, gaps, conflicts of interest, and issues within accountability and liability chains. Based on these findings, it will provide actionable recommendations to address identified challenges. Building on the framework established in the preliminary ecosystem mapping, the guidance note will present a diagnostic assessment, identifying potential overlaps, gaps, and conflicts of interest. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 20 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure TABLE 3 Priority area II Key concepts within information security Information security and transaction integrity Safeguarding information from unauthorized access, disclosure, Data protection alteration, or destruction. Scope Encryption Protecting the confidentiality of data both in storage and during transmission. Priority area II of the CMI WG consists of strengthening information security Conducing authentication (verifying identity) and authorization and transaction integrity in carbon markets. As with any nascent market, carbon Access control (granting/restricting permissions based on roles or needs). markets depend on robust information security and transaction integrity to build trust, ensure reliability, and establish credibility. Policies and procedures for secure storage, archiving, and/or Data retention deleting data in compliance with legal, regulatory, or business requirements. Ensuring information security in carbon markets involves safeguarding data associated with carbon credits and transactions from unauthorized Continuous oversight and improvement regarding security related Monitoring systems access, manipulation, or breaches. This entails implementing comprehensive security to activities/systems deployed to detect, prevent, and respond to cybersecurity measures, governed by well-defined policies and standards, to security incidents to identify potential threats or breaches. protect sensitive information and uphold market integrity. Additionally, it requires Recording and preserving logs of all significant actions or events Maintaining audit a commitment to continually advancing the maturity of security controls, adapting within an information system which can be used for compliance, trails to evolving threats, and ensuring resilience across the market infrastructure. forensic investigations, and ensuring accountability. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 21 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure TABLE 4 Transaction integrity in carbon markets refers to ensuring that transactions Key elements of transaction integrity between buyers, sellers, and intermediaries occur within a trusted, secure, and compliant carbon markets infrastructure environment. This involves strict adherence to regulatory standards such as KYC, AML, and ABC programs, which KYC processes are designed to 1) verify the identities of their clients and individuals with significant control (e.g., beneficial owners and help verify the legitimacy of market participants and prevent illegal activities. Know your directors) and 2) assess the risk associated with clients. These Transaction integrity requires clearly defined roles and responsibilities for all parties customer processes help prevent fraud and financial crimes, ensuring that only involved, establishing accountability across the transaction process. It also entails legitimate participants engage in carbon market transactions. ensuring the authenticity of carbon credits and the validity of each transaction, preventing issues like fraud or double counting, which could undermine the credibility of the market. AML procedures and regulations are designed to prevent criminals from Anti-money disguising illegally obtained money as legitimate. This requires financial laundering institutions to monitor and report suspicious activities. As with any nascent market, carbon markets Anti-bribery and ABC policies and practices prevent bribery, corruption, and fraud within organizations. They ensure that business dealings are conducted corruption depend on robust information security and ethically and in compliance with anti-corruption laws. transaction integrity to build trust, ensure reliability, and establish credibility. Given that countries are at different stages in developing their carbon market infrastructure, information security and transaction integrity measures must be tailored to specific needs, capacities, and regulatory environments. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 22 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure State of play As carbon markets face increasing scrutiny from regulators and stakeholders, both In connection with Priority Area I – Ecosystem governance, as the carbon information security and transaction integrity have become crucial components for market scales and stakeholder roles and responsibilities become more defined, ensuring compliance, mitigating risks, and maintaining trust in the market. establishing clear lines of accountability for information security and transaction integrity will be essential. Clearly identifying those responsible for safeguarding Currently, there is limited information and documentation on existing standards data and ensuring secure transactions is crucial to upholding market integrity and and market practices for information security within carbon markets. In this fostering participant confidence. context, information security means protecting sensitive data related to carbon credits and transactions from unauthorized access, tampering, or misuse. This includes ensuring that information about who owns carbon credits, how they are traded, and the details of each transaction are kept secure and private. Robust information security helps prevent fraud and builds trust among participants, making the carbon market a safer and more reliable place for buying and selling As carbon markets face increasing scrutiny from carbon credits. regulators and stakeholders, both information security and transaction integrity have become There are two primary frameworks that organizations have begun to adopt to navigate regulatory demands and build trust in the rapidly evolving carbon crucial components for ensuring compliance, market. These frameworks are the CIS Controls (formerly the SANS Top 20 Critical mitigating risks, and maintaining trust in the Security Controls) and the US National Institute of Standards and Technology market. (NIST) Cybersecurity Framework.  9 Both provide a structured approach to assessing cybersecurity maturity and identifying critical gaps, aligning with industry best practices and effectively mitigating cybersecurity risks. These frameworks are often incorporated into broader audits, such as Service and Organization Controls 2 (SOC 2) audits, which emphasize information security, confidentiality, and privacy. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 23 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure TABLE 5 Identified bottlenecks in information security and transaction integrity Knowledge gaps in current Poor documentation on current security and regulatory standards and market practices in carbon markets hampers efforts to prevent fraud, ensure standards and practices related transparency, and build trust. Adopting frameworks such as the International Organization for Standardization/International Electrotechnical Commission (ISO/ to information security and IEC) 27001 for information security, complying with the EU’s General Data Protection Regulation (GDPR), and following IOSCO and CFTC guidelines can address transaction integrity these gaps by improving data security, risk management, and overall confidence in the carbon market‘s infrastructure. Governments, business actors, and infrastructure providers often lack equal access to information regarding robust standards and best practices for Asymmetry of information implementing information security and transaction integrity measures effectively. This uneven distribution of knowledge can lead to inconsistencies in and knowledge between actors security practices, increased vulnerability to cyber threats, and challenges in establishing trust across the carbon market ecosystem. As a result, misaligned expectations and gaps in compliance may arise, complicating efforts to achieve cohesive, secure, and transparent market operations. The lack of transaction integrity safeguards in carbon markets poses a serious challenge, enabling fraudulent activities—such as issuing fake credits or Lack of robust safeguards double counting—to go unchecked. For instance, without identity verification (e.g., KYC), unauthorized or fraudulent actors can participate in the market, for transaction integrity while insufficient AML measures allow illicit funds to flow through carbon credit transactions. Additionally, weak anti-corruption controls (e.g., ABC) can lead to compromised project validations, where validators might be incentivized to issue credits for projects with questionable environmental impact. Inadequate information security in carbon markets exposes specific vulnerabilities in key activities, such as credit issuance, transaction tracking, and verification processes. For example, if security measures are weak, unauthorized parties could manipulate or falsify data in carbon credit registries, potentially Risks of inadequate information resulting in fraudulent credits entering the market. Additionally, during transactions, cyberattacks targeting trading platforms could lead to data breaches or security measures financial theft, undermining confidence in the market’s reliability. In verification stages, insecure handling of project data might allow tampering with emissions data or validation reports, compromising the integrity of carbon credits. Such security lapses not only pose financial and reputational risks but also erode the environmental impact and credibility of carbon markets. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 24 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Way forward The next stage of the CMI WG’s work in this priority area is to develop a detailed • Integrating findings into capacity-building and technical assistance for guidance note aimed at enhancing the understanding of robust standards and best countries: Findings from this workstream will inform the development of practices related to information security and transaction integrity within carbon capacity-building and technical assistance activities, tailored to address the markets infrastructure. It will document current standards and market practices— diverse capacities and requirements across different markets. This targeted specific areas such as information security and data protection as well as MFA, support will contribute to a cohesive and resilient carbon market infrastructure. KYC, AML, and ABC standards will be addressed. It will be based primarily on three efforts: • Actionable recommendations for implementing robust information security and transaction integrity measures: The guidance note will deliver comprehensive recommendations to establish robust safeguards for information security and transaction integrity. The CMI WG’s guidance note will deliver guidance on implementing robust safeguards • Incorporation of technical deep dives and stakeholder consultations: for information security and transaction The guidance note will be shaped by comprehensive technical deep dives integrity. and consultations with CMI WG members, subject-matter experts, and practitioners, ensuring a well-rounded and evidence-based approach. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 25 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Priority area III In the pre-issuance phase, data fragmentation and interoperability issues arise due to inconsistent standards for primary data provision across project registries. Interoperability of data and systems Diverse validation and verification protocols, along with varying data collection methods (e.g., satellite imagery vs. ground-based measurements), hinder data alignment and make it challenging to aggregate information across projects. This lack of standardization limits stakeholders’ ability to assess project quality Scope uniformly and complicates scaling across regions. In the post-issuance phase, fragmentation impacts the tracking and transfer of carbon credits across multiple registries. Incompatible registry systems, where credits issued in one registry Priority area III of the CMI WG is based on the recognition that data and systems cannot be seamlessly tracked in another, create transparency and traceability interoperability in carbon markets is critical to building cohesive and efficient issues. This makes it difficult to link voluntary and compliance markets, among market infrastructure. As highlighted by IOSCO and ICVCM, 10 interoperability other issues. Further, limited real-time data integration affects market participants, within carbon markets requires unified data protocols and compatible systems as delays between registries and trading platforms impact data on credit across registries to support transparent transactions and seamless data flow across availability, ownership, and use, reducing market liquidity. Disparate reporting platforms and jurisdictions. Effective interoperability is essential for transparent standards also complicate oversight, as varying timelines across registries impede and efficient data sharing among registries, tracking and reporting platforms, and consistent performance assessment. verification bodies, ensuring accurate information is accessible across the market. ICVCM, IOSCO, TSVCM,3 the World Bank, and other key entities have issued Carbon markets currently face significant data fragmentation, with recommendations to enhance interoperability across both pre- and post- inconsistencies across data sources, registries, and reporting standards. This issuance stages. Recommendations for the pre-issuance phase emphasize the fragmentation—resulting from diverse methodologies, incompatible systems, need for standardized data collection and verification through digital monitoring, and varying levels of technology adoption—often isolates essential data, such as reporting, and verification tools and unified metadata standards to ensure accuracy verification of mitigation outcomes, ownership, and emissions reductions. This from the start. For the post-issuance phase, recommendations focus on creating siloed information complicates efforts to ensure transparency and accuracy in a metadata layer to integrate registry data and prevent double counting, alongside tracking carbon credits. establishing universal tracking infrastructure supported by open application programming interface (APIs) and industry-wide data standards to enable seamless data exchange. Enhanced cybersecurity measures are also recommended to maintain data integrity across platforms. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 26 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure State of play In recent years, several multi-stakeholder initiatives have emerged to address • Carbon Data Open Protocol was launched in September 2024 by Sylvera. This different aspects of interoperability, focusing on common taxonomies, initiative aims to develop an open-source data protocol for carbon credits. It infrastructure linkages, and preventing potential risk of double counting. Several will be overseen by an independent industry committee featuring principles and examples include: policy as well as technical working groups, and it is intended to promote greater transparency and accessibility within the carbon market. • Climate Action Data Trust is a not-for-profit initiative that operates a decen­ tralized metadata platform that links, aggregates, and harmonizes carbon credit • Integrity Council for the Voluntary Carbon Market is a not-for-profit, registry data to enhance transparent accounting in alignment with Article 6 independent governance body dedicated to establishing and upholding global of the Paris Agreement. Founded in 2022 by the World Bank, the International standards for high integrity in the voluntary carbon market. Beginning in late Emissions Trading Association, and the government of Singapore, CAD Trust 2024, the ICVCM launched its Continuous Improvement Work Program to builds on the World Bank’s Climate Warehouse program. Its data model and drive advancements in market transparency, standardization, and scalability, work program are governed through a collaborative structure involving both strengthening the voluntary carbon market’s credibility and accessibility.15 governments and the private sector.11 • Emerging guidance on the Centralized Accounting and Reporting Platform • A data model for carbon markets has been submitted to ISO/Technical and Agreed Electronic Format for reporting Article 6 transactions, and the Committee (TC) 322/ad-hoc group (AHG) 3 on Sustainable Finance using the development of an International Registry under the UNFCCC are shaping a CAD Trust data model as a foundation.12 This proposed ISO standard seeks global framework for transparency. These advancements establish standardized to harmonize data fields, formats, and models across different registries. If processes for data exchange, with significant impacts on infrastructure approved, the project will be developed in close collaboration with ISO TC operators worldwide. 68 (Financial Services)13 and the Financial Information Exchange (FIX) Trading Protocol to facilitate accurate financial transaction data transfer within the • Science Based Targets Initiative and the Voluntary Carbon Markets Integrity global financial markets’ ecosystem,14 including links to data interchange Initiative are independent initiatives designed to promote best practices for standards like ISO 20022, which provides a unified framework for financial carbon credit use and support the harmonization of carbon credit data. transactions, and the draft ISO working draft (WD) 14060 Net Zero Draft Standard. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 27 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure TABLE 6 Identified bottlenecks in data and systems interoperability Lack of common Absence of universally accepted data frameworks, leading to fragmented data exchange data frameworks and reduced transparency. Incompatible data formats Diverse data formats and standards across platforms make integration and data comparison and inconsistent standards difficult, causing inefficiencies. Fragmentation due to disparate Independent registry and MRV systems create data fragmentation, complicating data registry and MRV systems alignment and leading to information gaps. Lack of data standardization Lack of standardized data management reduces fungibility across systems, complicating and fungibility the transfer and integration of credits. Without unified tracking mechanisms, there’s a high risk of credits being double counted, Double counting risks impacting market credibility. Diverse validation and verification protocols and data collection methods pre-issuance Inconsistent pre-issuance standards hinder data alignment across projects. Carbon markets currently Incompatible post-issuance tracking systems Credits issued in one registry may not track seamlessly in another, causing transparency and traceability challenges. face significant data fragmentation, with Limited real-time data integration Delays in data synchronization between registries and trading platforms limit real-time inconsistencies across data access to credit availability and ownership. sources, registries, and Varying reporting timelines and standards across registries impede consistent oversight reporting standards. Disparate reporting standards and accurate performance assessment. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 28 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure FIGURE 5 Way forward Connecting key data initiatives in carbon markets The next stage of the CMI WG’s work in this priority area is to develop a detailed guidance note aimed at strengthening the interoperability of data and systems within carbon markets. The guidance note will deliver actionable recommendations Other data initiatives to encourage the adoption of standardized data taxonomies and frameworks. This ICVCM WP7 (e.g., Sylvera, BeZero guidance will provide strategies for aligning data and systems interoperability Carbon) efforts with global policies, including Article 6 of the Paris Agreement, to ensure that reporting processes meet international standards. It will be based primarily on two efforts: • Stocktaking and coordination of existing initiatives: To avoid duplication and fragmentation, the guidance note will stocktake and consolidate current initiatives addressing data and systems interoperability. This will ensure that all efforts are strategically coordinated, supporting a unified approach to CAD Trust interoperability across carbon markets (Figure 5). • Technical deep dives and stakeholder consultations: The CMI WG will conduct technical deep dives and consultations with members, subject-matter experts, and practitioners to understand and address challenges in data use and accounting. Insights from these discussions will inform the guidance ISO/TC 322/AHG 3 note, ensuring it reflects a balanced and expert-informed perspective on interoperability. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 29 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Conclusion This roadmap and the forthcoming guidance notes aim to provide practical, • Enhancing capacity building and technical assistance: Strengthening actionable guidance to stakeholders navigating the complex challenges and stakeholders’ skills and knowledge will equip them to develop and deploy opportunities currently facing carbon market infrastructure. Their objective systems aligned with international standards, promoting smooth operations and is to accelerate progress in developing a reliable, high-impact carbon market greater transparency within carbon markets. infrastructure that delivers meaningful climate outcomes. • Elevating investor confidence and mobilizing the private sector: Through Long term, the objective of these workstreams is to enhance carbon markets standardized processes, data accuracy, and secure, interoperable systems, infrastructure, ensuring its scalability and effectiveness through achieving the these efforts will reduce market risks, build trust, and foster a stable following goals: environment, encouraging active private sector participation. • Accelerating standardization, efficiency, and unification of digitally enabled market infrastructure: This effort aims to establish minimum service standards and common frameworks that improve interoperability and support seamless transactions, ultimately strengthening trust and participation across the carbon The objective is to accelerate progress in market ecosystem. developing a reliable, high-impact carbon • Increasing access to secure, robust, and harmonized market infrastructure markets infrastructure that delivers meaningful solutions: By providing streamlined, reliable solutions, this approach will enable climate outcomes. better management of carbon assets and facilitate broader engagement in carbon markets, mobilizing essential financial resources. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III 30 A Roadmap for Safe, Efficient, and Interoperable Carbon Markets Infrastructure Endnotes 1 World Bank, High Integrity, High Impact: The World Bank Engagement Roadmap for 10 The Integrity Council for the Voluntary Carbon Market, Core Carbon Principles, Carbon Markets, 2024. License: CC BY-NC 3.0 IGO. http://hdl.handle.net/10986/42016. Assessment Framework and Assessment Procedure, 2024. https://icvcm.org/wp-content/uploads/2024/02/CCP-Book-V2-FINAL-6Feb24-compressed.pdf. 2 Institute of International Finance, Taskforce on Scaling Voluntary Carbon Markets, 2021. The Board of the International Organization of Securities Commissions, Voluntary Carbon Markets https://www.iif.com/Portals/1/Files/TSVCM_Report.pdf. Consultation Report, IOSCO, 2023. https://www.iosco.org/library/pubdocs/pdf/IOSCOPD749.pdf. 3 The Board of the International Organization of Securities Commissions, Voluntary Carbon Markets 11 Climate Action Data Trust, “CAD Trust Data Dashboard,” n.d. Consultation Report, IOSCO, 2023 https://www.iosco.org/library/pubdocs/pdf/IOSCOPD749.pdf. https://climateactiondata.org/data-dashboard. 4 Commodity Futures Trading Commission, Guidance Regarding the Listing of Voluntary Carbon 12 ISO/TC 322 is the technical committee responsible for the development of ISO standards Credit Derivative Contracts, RIN 3038-AF40, 2023. relating to sustainable finance. Sustainable finance is considered by ISO/TC 322 to mean financing, as well as related institutional and market arrangements, that support progress to achieving 5 Institute of International Finance, Taskforce on Scaling Voluntary Carbon Markets (TSVCM): the United Nations Sustainable Development Goals and addressing climate change. International Terms of Reference (ToR) for the New Governance Body, 2021. Organization for Standardization, “ISO/TC 322,” n.d. https://committee.iso.org/home/tc322. https://www.iif.com/Portals/1/Files/TSVCM_TOR.pdf. 13 Technical Committee 68 (ISO/TC 68) is responsible for creating global standards for the financial 6 World Economic Forum in collaboration with Bain & Company, Scaling Voluntary Carbon Markets: services industry. TC 68 is responsible for standards that cover core banking, capital markets A Playbook for Corporate Action, 2023. including asset management, payments, credit card processing, and information security aspects https://www3.weforum.org/docs/WEF_Scaling_Voluntary_Carbon_Markets_2023.pdf. specific to financial services. The committee is organized into three subcommittees: SC2 Information Security), SC8 (Reference Data), and SC9 (Information Exchange). International 7 The Board of the International Organization of Securities Commissions, Voluntary Carbon Markets Organization for Standardization, “ISO/TC 322,” n.d. https://committee.iso.org/home/tc322. Consultation Report, IOSCO, 2023. https://www.iosco.org/library/pubdocs/pdf/IOSCOPD749.pdf. The Board of the International Organization of Securities Commissions, Compliance Carbon 14 FIX Trading Community, “Financial Information Exchange (FIX®) Protocol,” 2024. Markets, 2023. https://www.iosco.org/library/pubdocs/pdf/IOSCOPD740.pdf. https://www.fixtrading.org/what-is-fix. 8 The Integrity Council for the Voluntary Carbon Markets, “The Core Carbon Principles,” n.d. 15 Integrity Council for the Voluntary Carbon Market, “Our Continuous Improvement Work Programs,” n.d. https://icvcm.org/core-carbon-principles. https://icvcm.org/continuous-improvement-work-programs. 9 Center for Internet Security, “The 18 CIS Critical Security Controls,” n.d. https://www.cisecurity.org/controls/cis-controls-list. National Institute of Standards and Technology, “Cybersecurity Framework 2.0,” 2024. https://www.nist.gov/cyberframework. Foreword Executive summary CMI WG Conclusion Endnotes Priority Area I II III CMIWG.ORG