GCOM Guidelines

SAUDI ARABIA’S GREENHOUSE GAS CREDITING &

OFFSETTING MECHANISM (GCOM)

Requirements and specifications for the quantification, monitoring,

reporting, verification, and registration of project-based GHG
emissions reductions and removals in the Kingdom of Saudi Arabia

V.1 | JULY 2023

Copyright
All rights reserved. No part of this publication may be reproduced, displayed, modified
or distributed without express written permission of the GCOM. The sole permitted use of
the publication is for the registration of projects on the GCOM registry. Except for the
Authorized Use, all commercial use of this document is prohibited. It’s not permitted to
view, download, modify, copy, distribute, transmit, store, reproduce or otherwise use,
publish, license, transfer, sell or create derivative works (in whatever format) from this
document or any information obtained from this document otherwise than for the
Authorized Use or for personal, academic or other non-commercial purposes.

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Table of Contents

1 EXECUTIVE SUMMARY ......................................................................................................... 4

2 PURPOSE OF THE DOCUMENT ............................................................................................. 5

3 INTRODUCTION TO GCOM ................................................................................................. 5

3.1 PURPOSE AND OBJECTIVE OF GCOM ..................................................................................... 5

3.1.1 VISION 2030 AND SAUDI’S AMBITIOUS CLIMATE GOALS ......................................................... 6
3.1.2 ARTICLE 6 OF THE PARIS AGREEMENT .................................................................................... 7
3.2 GCOM GUIDING PRINCIPLES ................................................................................................ 7
3.2.1 RELEVANCE ....................................................................................................................... 7
3.2.2 COMPLETENESS.................................................................................................................. 8
3.2.3 CONSISTENCY ................................................................................................................... 8
3.2.4 ACCURACY ...................................................................................................................... 8
3.2.5 TRANSPARENCY ................................................................................................................. 8
3.2.6 CONSERVATIVENESS ........................................................................................................... 8
3.2.7 PERMANENCE.................................................................................................................... 8
3.2.8 ADDITIONALITY .................................................................................................................. 9

4 GCOM SCOPE..................................................................................................................... 9

4.1 TYPE OF METRIC.................................................................................................................... 9

4.1.1 GHG METRIC ................................................................................................................... 9
4.1.2 NON-GHG METRIC ........................................................................................................... 9
4.2 SECTORAL COVERAGE......................................................................................................... 11

5 GCOM PROJECT DEVELOPMENT PROCESS ...................................................................... 12

5.1 PROJECT PREPARATION AND PLANNING ...................................................................... 12

5.1.1 PROJECT OWNERSHIP ........................................................................................................13
5.1.2 PROJECT LOCATION/ BOUNDARY .......................................................................................14
5.1.3 PROJECT SCALE ................................................................................................................14
5.1.4 PROJECT START DATE ........................................................................................................14
5.1.5 PROJECT CREDITING PERIOD ..............................................................................................15
5.1.6 PROJECT METHODOLOGIES ................................................................................................15
5.1.7 ADDITIONALITY .................................................................................................................16
5.1.8 PROJECT CONTRIBUTION TO SUSTAINABLE DEVELOPMENT .......................................................16
5.1.9 BUNDLING OF PROJECTS ....................................................................................................17

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5.2 VALIDATION ................................................................................................................... 17
5.3 SUBMISSION.................................................................................................................... 18
5.4 PROJECT REGISTRATION ................................................................................................. 18
5.4.1 GCOM REGISTRY ............................................................................................................19
5.5 MONITORING ................................................................................................................. 19
5.6 VERIFICATION................................................................................................................. 20
5.7 APPROVAL ...................................................................................................................... 21
5.8 CREDIT ISSUANCE ........................................................................................................... 21

6 GCOM PROGRAM PROJECT ADDITIONALITY .................................................................. 21

6.1 BASELINE SCENARIOS .......................................................................................................... 22

6.2 THREE-LEVEL ADDITIONALITY TEST .......................................................................................... 22
6.3 LEGAL OR REGULATORY TEST ................................................................................................. 23
6.4 COMMON PRACTICE TEST .................................................................................................... 23
6.5 BARRIER TEST ...................................................................................................................... 24
6.5.1 FINANCIAL BARRIER ...........................................................................................................24
6.5.2 TECHNOLOGICAL BARRIER..................................................................................................24
6.5.3 INSTITUTIONAL BARRIER .......................................................................................................24
6.6 POSITIVE LIST ...................................................................................................................... 25

7 FEEDBACK AND GRIEVANCE PROCESS ........................................................................... 25

8 GLOSSARY, DEFINITIONS, AND REFERENCES ................................................................... 25

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1 Executive Summary
Saudi Arabia’s Greenhouse Gas Crediting and Offsetting Mechanism (GCOM) is
an inclusive mechanism aiming to incentivize the deployment of emission
reduction and removal activities at scale to support and enable climate-related
national strategies, policies, and programs. It is meant to increase cooperation
among national entities seeking to fulfil their climate ambitions by helping to
mobilize finance in all sectors for a variety of projects and activities.

The ultimate objective of the GCOM is to drive progress towards a path to net
zero emissions by allowing interested companies and entities to offset their
greenhouse gas emissions by purchasing credits and/or certificates from project
proponents that voluntarily reduce or remove greenhouse gas emissions. The
Mechanism is also meant to promote high-quality credits and/or certificates by
providing guidance, transparent infrastructure, and best practices, including for
project-level accounting.

Key features of GCOM are:

• Voluntary project-based participation.

• Scope covers GHG and non-GHG metrics across all sectors.
• Eligible Participants include:
o All entities from all sectors can participate.
o Subsidiaries of international companies active in the Kingdom also
are entitled to participate.
• Open to a variety of methodologies; DNA prepared and DNA approved.
• Robust additionality requirements.

The Mechanism is meant to adapt to future changes and developments at both

the national and international level, including alignment with Article 6 of the
Paris Agreement.

The Saudi Designated National Authority (DNA) will be acting as the regulator of
GCOM.

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2 Purpose of the Document
This document outlines the processes, requirements, and documentation
required to participate in Saudi Arabia’s Greenhouse Gas Crediting and
Offsetting Mechanism. The purpose of this guideline is to support stakeholders in
the implementation of GCOM projects.

This document will be updated regularly to reflect any developments.

3 Introduction to GCOM
Saudi Arabia’s Greenhouse Gas Crediting and Offsetting Mechanism (GCOM)
aims to support the achievement of Saudi Arabia’s climate ambitions by
advancing national efforts to reduce and remove greenhouse gas (GHG)
emissions while maintaining economic growth and national diversification plans.
It also aims to incentivize the deployment of emission reduction and removal
activities at scale to support and enable climate-related national strategies,
policies, and programs.

The Mechanism considers, in its core, the inclusivity and integration of clean
hydrocarbon technologies to support the Circular Carbon Economy (CCE)
approach, as well as to create the financial incentives to scale up such
technologies. The Mechanism encourages sustainable development projects as
defined by and measured against the United Nations Sustainable Development
Goals (UNSDGs).

The Mechanism is meant to adapt to future changes and developments at both

the national and international level, including alignment with Article 6 of the
Paris Agreement.

3.1 Purpose and Objective of GCOM

The purpose of establishing the GCOM in the Kingdom is to increase
cooperation among national entities seeking to fulfil their climate ambitions by
helping to mobilize finance in all sectors for a variety of projects and activities. It
aims to drive positive social, environmental and economic impacts beyond
emission reductions or removals. The efforts undertaken in GCOM are meant to
contribute to national emission reduction and/or removal levels, aligned with
Saudi’s ambitious climate goals, in the most cost-effective manner.

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The ultimate objective of the GCOM is to drive progress towards a path to net
zero emissions by allowing interested companies and entities to offset their
greenhouse gas emissions by purchasing credits and/or certificates from project
proponents that voluntarily reduce or remove greenhouse gas emissions. The
Mechanism is also meant to promote high-quality credits and/or certificates by
providing guidance, transparent infrastructure, and best practices, including for
project-level accounting.

3.1.1 Vision 2030 and Saudi’s Ambitious Climate Goals

Saudi Arabia’s Vision 2030 is an ambitious roadmap that expresses the
Kingdom’s long-term goals and expectations, while harnessing the country’s
strengths and capabilities. With sustainability at its heart, Vision 2030 inspires
creativity and responsibility when addressing today’s energy and climate
challenges.

The Kingdom of Saudi Arabia has ambitious climate goals and initiatives,
including:

• Nationally Determined Contribution (NDC) - Saudi Arabia’s most recent

NDC embodies efforts to implement actions, projects, and plans that aim
to reduce and avoid GHG emissions by 278 million tons of CO2eq annually
by 2030, with the year 2019 designated as the base year for this NDC. The
achievement of this ambitious NDC relies on many tools, including
dynamic baselines and the Circular Carbon Economy (CCE).
• Global Methane Pledge – Saudi Arabia joined the Global Methane
Pledge as part of its commitment to reduce global methane emissions by
30% by 2030 relative to 2020 levels.
• Saudi Net Zero 2060 - Saudi Arabia announced its intention to reach Net
Zero emissions by 2060, in a manner that preserves the Kingdom’s leading
role in enhancing the security and stability of global energy markets. The
Kingdom aims to progress towards Net Zero through;
o Circular Carbon Economy (CCE) - KSA developed and adopted the
Circular Carbon Economy (CCE) framework using the four Rs;
Reduce, Reuse, Recycle, and Remove greenhouse gas emissions
from atmosphere
o National Strategies and Initiatives - Saudi Green Initiative (SGI),
Middle East Green Initiative (MGI)

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3.1.2 Article 6 of the Paris Agreement
The GCOM is aligned with Article 6 and the Kingdom strategically encourages
implementing GCOM project activities in a manner that is in line with the
principles of Article 6 of the Paris Agreement. Article 6 allows Parties to the Paris
Agreement to enter into cooperative approaches that internationally transfer
emission reductions and removals, known as Internationally Transferred
Mitigation Outcomes “ITMOs”.

Credits generated from GCOM can be ITMOs subject to the authorization of

KSA’s Designated National Authority (DNA).

GCOM requirements are aligned with the reporting requirements and

environmental integrity expectations of Article 6, noting that deliberations on the
full implementation of Article 6 have yet to conclude. The Mechanism is meant
to adapt to future changes and developments at both the national and
international level, including alignment with Article 6 of the Paris Agreement.

For a project proponent developing a project outside the Kingdom of Saudi

Arabia that results in emission reductions or removals;

• If the credits from the project must count towards Saudi Arabia’s NDC, or
• If the proponents would like the credits to count towards Saudi’s NDC,

please contact the DNA for further guidance on the procedures and
requirements.

3.2 GCOM Guiding Principles

The GCOM builds upon international best practices and standards and is
aligned with main principles and requirements which focus on GHG emission
reduction projects or project-based activities that are specifically designed to
reduce or remove GHG emissions. This alignment provides the principles and
requirements for determining project baseline scenarios, as well as provide
project-level guidance for quantification, monitoring, and reporting of projects
and activities in relation to their baseline scenario.

3.2.1 Relevance
The project should define appropriate inventory boundaries that reflect the
needs of the user. GHG activities, data collection, and methodology must be
relevant and appropriate to the project proponent.

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3.2.2 Completeness
All relevant information about emission sources and removals within the chosen
inventory boundary of the project needs to be fully accounted for in order to
achieve a comprehensive and meaningful emission reductions or removals.

3.2.3 Consistency
The project should apply consistent accounting approaches, inventory
boundaries, and calculation methodologies in order to produce comparable
GHG emissions data over time. Project data must be consistent and
comparable over time. If the inventory boundary, methods, data, or any other
factors affecting emission estimates change, they must be transparently
documented and justified.

3.2.4 Accuracy
Project data of the credits generated should be precise in order to reduce bias.
A high level of accuracy is needed to ensure that the reported information is
credible. The quantification and reporting processes should be carried out in a
way that reduces uncertainty while increasing transparency.

3.2.5 Transparency
Project information must be disclosed in a clear and factual manner.
Stakeholders must be able to make decisions with reasonable confidence.
Ensure information is recorded, compiled, and analyzed in such a way that it
upholds credibility and reliability.

3.2.6 Conservativeness
Project Proponents should use conservative assumptions, values, and
procedures so that net GHG emission reductions or removals are not
overestimated.

3.2.7 Permanence
Permanence refers to the longevity of removal enhancements and the risk of
reversal (i.e., the risk that atmospheric benefits will not be permanent). Reversals
may be unintentional or intentional. For projects with a risk of reversal of GHG
removal enhancements or avoided conversion projects, Project Proponents
shall assess and mitigate risk, and monitor, report, and compensate for reversals.

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3.2.8 Additionality
The project must demonstrate that it would not have occurred in the absence
of the incentives provided by the mechanism, to prove that the project is
additional. If a Project Proponent undertakes an activity even in the absence of
a crediting mechanism, the activity is not additional. There are a range of
options to test the additionality of a project, as described in section 7 of this
document which pertains specifically to additionality.

4 GCOM Scope
4.1 Type of Metric
The GCOM allows the use of both GHG and non-GHG metrics, in accordance
with the methodology used.

4.1.1 GHG Metric

Carbon offsets using GHG-metrics are measured in metric tons of carbon
dioxide equivalent (CO2e) and may represent primary categories of
greenhouse gases: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O),
sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs)
and Nitrogen trifluoride (NF3).

In the context of the economic structure in Saudi Arabia, CH4 emissions related
to oil production are addressed, PFCs are relevant in aluminum production, N2O
emissions in the chemical industry (e.g., nitric acid production), and SF6 for
operating electricity grids. Finally, HFCs are relevant in the cooling sector (HVAC
systems and AC units), NF3 are relevant in some high-tech industries, including in
the manufacture of many electronics.

4.1.2 Non-GHG Metric

When the GHG reductions are measured in units other than CO2 or CO2eq,
these are known as non-GHG metrics. GCOM accommodates the types of
activities relevant in the Kingdom as listed:

Non-GHG Metric Activity

MW installed capacity Renewable electricity generation
Renewable electricity generation, energy
MWh produced/saved
efficiency improvement

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m2 floor area Energy efficient buildings (new)
Water efficiency improvement, renewable
m3 saved/produced
desalination
Electric passenger vehicles, rail-based public
Person-km
transport
Tonne-km Electric freight road and rail transport vehicles
Units replaced Cooling equipment replacement
MW capacity replaced Cooling equipment replacement
Tonne of RDF used RDF use in cement industry
Tonne of H2 / ammonia Replacement of grey H2 /ammonia with green
produced or blue H2 /ammonia
Tonne of recycled material Recycling of wastes
Tonne of waste incinerated Waste incineration
ha of forest land; number of
Afforestation and reforestation
vegetation units
Tonne of product Localization of agriculture

Renewable Energy: The load factor of renewable electricity generation plants

i.e., their share of operational hours in the total hours of a year, depends on the
availability of the underlying resource. For solar power plants a natural limit of
the load factor is given by the share of sunlight hours in the overall hours of the
day; while site-specific influences are cloud cover (which is higher near the sea
and in high mountains) and dust prevalence (which is higher in the desert).

A conservative approach would be to choose the highest cloud cover and

dustiness that exists in a certain geographic area, for example differentiated by
coastal lowlands at the Red Sea, mountains above 1000m altitude, the interior
(>100 km from the coast) and the coast of the Arabian Gulf.

Desalination Plants, Buildings and Vehicles: The energy intensity of desalination

plants, buildings and vehicles strongly depends on the characteristics of
technology used, buildings and vehicles. A differentiation could be done as
follows:

• Desalination plants: Reverse osmosis (RO), multistage flash (MSF) and

multieffect distillation (MED).

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 • Building types: e.g. single family homes, multi-apartment / commercial
accommodation buildings below 5 floors, accommodation buildings
(apartments and commercial accommodation above 5 floors, office
buildings above 5 floors, shopping malls.
• Passenger vehicle types: private cars and SUVs, commercial and
administrative car fleets, buses. Differentiation as per SASO standards.
Freight vehicle types: Differentiation as per SASO standards.

The operation hours of cooling equipment: as specified in academic study

(Krarti and Howarth (2020)).

4.2 Sectoral Coverage

GCOM encourages the reduction or removal of greenhouse gas emissions
across all sectors. As such, projects or activities in all sectors are accepted by
GCOM, provided the projects comply with GCOM requirements. The sectors
include, but are not limited to:

• Energy Efficiency and Renewable and lower GHG emissions Energy

Generation
o Renewable Energy Production: (hydropower, biomass energy,
biomass fuels, geothermal power, solar power, wind energy, fuel
cell)
o Energy Efficiency Improvements: (conservation, efficiency, waste
heat recovery, cogeneration, trigeneration, industrial process
optimization)
• Industrial processes (non-combustion, chemical reaction, fugitive, other)
o SF6 replacement
o SF6 emission avoidance
o HFC destruction/decomposition
o PFC anode effect mitigation
o Production of nitric acid and adipic acid
o Reduced emissions from destruction of N2O in manufacturing
• Transportation, Modal, and Fuel Shift
o Lower emission vehicles (electric, hydrogen vehicles)
o Route optimization
o Metro, Bus Rapid Transport (shift from private to public transport)
o Internal combustion engine
• Land Use, Land Use Change and Forestry (LULUCF)

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 o Sequestration of carbon due to afforestation, avoided
deforestation, sustainable forest management, forest products)
o Soil carbon sequestration (no-till, grass cover)
• Carbon Capture and Storage
o Emissions sources that are injected into underground geological
formations (e.g., abandoned oil and gas reservoirs, saline aquifers,
or un-minable coal seams)
• Livestock
o Methane Collection and Destruction
o Livestock and other anaerobic digester operations
o Agricultural methane emission reduction
o Agricultural carbon emission reduction
• Waste Handling and Disposal
o Capture and destruction of Landfill gas
o Capture and use of Landfill gas (bio digestion, aerobic treatment)
o Methane recovery in wastewater treatment
o Avoidance of methane production in wastewater treatment
o Coal mine methane
o Waste to Energy

5 GCOM Project Development Process

For a Project Activity to be eligible under the GCOM, The Project Proponent shall
refer to the GCOM Project Development Process outlined below, and proceed
according to the outlined steps for registration and issuance of credits:

GCOM Steps

1 2 3 4
Preparation &
Validation Submission Registration
Planning

5 6 7 8
Monitoring Verification Approval Credit Issuance

5.1 PROJECT PREPARATION AND PLANNING

→ Plan and prepare all the required documents for project registration

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When developing and preparing a project, the Project Proponent shall:

• Establish project ownership.

• Ensure the Project Activity is not registered under any other crediting
mechanism, including the CDM, to avoid double counting.
• Comply with the GCOM requirements applicable to the corresponding
project type and sector.
• Demonstrate that the Project Activity delivers real, measurable, and
additional emission reductions or removals compared to its baseline by
applying a relevant GCOM methodology.
• Demonstrate that the Project Activity contributes to sustainable
development by progressing at least one of the United Nations
Sustainable Development Goals and avoids negative environmental and
social impacts.
• Ensure that all data and documentation is stored safely and easily
accessible for at least two years after the final Crediting Period has ended
for any given Project Activity.

Project Proponent (PP) shall prepare all required documents with sufficient data
for consideration by GCOM, specifying project type as GHG Metric or Non-GHG
Metric. The PP details the Project Activity using the GCOM Project Design
Document (PDD) template, which can be found on the GCOM website.

Project Proponent must ensure the PDD’s completeness, and compatibility with
the GCOM standards and relevant methodology that are applicable to the
Project Activity.

The Project Proponent can seek clarifications from the DNA through the GCOM
contact email/website, on:

• Requirements of the PDD and any other forms applicable to a Project

Activity type.
• A list of DNA-Accredited Validators for the Project Activity type.
• Other questions regarding the GCOM process.

5.1.1 Project Ownership

The Project Proponent must have the legal right to control and operate emission
reduction or removal projects or activities in Saudi Arabia. Project Proponents
shall provide documentary evidence demonstrating the uncontested legal right
to the emission reductions or removals arising from the project. Project

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ownership arising from the legal right to control and operate the project can be
established through one or more of the following:

• Project ownership arising by law or regulation.

• Project ownership arising by proprietary or contractual right in the land,
plants, equipment, or process that generate the GHG emission reductions
or removals resulting from the project.
• Project ownership arising from a contractual agreement with the project
owner regarding the right to the emission reductions or removals arising
from the project.

5.1.2 Project Location/ Boundary

The Project Proponent must provide information about the physical/geographic
location of the Project Activity, including information that allows it to be uniquely
identified.

Moreover, the Project Proponent must define the proposed project's boundary,
including the physical delineation of the project as well as the emission sources
and metrics as required by the applicable methodology.

5.1.3 Project Scale

Project Proponents shall estimate the annual expected emission reductions or
removals over the project Crediting Period using a relevant GCOM
methodology and include the estimations in the Project Design Document (PDD)
forms, which can be found on the GCOM website.

5.1.4 Project Start Date

A project start date for all project types (other than LULUCF) is considered as the
date the project begins to reduce or remove GHG emissions against its baseline.

The Project Proponent may submit a project which has already started
operations for registration in GCOM, provided the project start date does not
precede 1 January 20191. The project proponent shall follow the GCOM Project
Development Process and may request retroactive issuance of credits from the
project start date until the latest period for which the Project Proponent can
provide a monitoring report.

1 Projects that have begun before this date will not be eligible to participate in the GCOM.

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5.1.5 Project Crediting Period
A Crediting Period is the finite length of time during which a GCOM Project
Activity is valid, and can generate credits against its baseline scenario.

Crediting periods are limited in order to require Project Proponents to re-confirm,

at intervals appropriate to the project type, that the baseline scenario remains
realistic and credible, the Project Activity remains additional, and that best
practices for GHG accounting continue to be used.

For LULUCF projects, a crediting period shall be 7 years, renewable for a

maximum of two subsequent times (in total 21 years) or as specified in the
relevant GCOM sector requirements or methodology.

For Non-LULUCF projects, a crediting period shall be 5 years renewable for a

maximum of two subsequent times (in total 15 years) or 10 years of fixed
crediting period or a conservative estimate of the technical lifetime of the
installed technologies or implemented measures, whichever is shorter.

For activities involving removals, a crediting period shall be a maximum of 15

years renewable a maximum of twice, as appropriate to the activity and the
methodology used.

The Project Proponent shall ensure that all data and documentation is stored
safely and easily accessible for at least two years after the final Crediting Period
has ended for any given Project Activity.

5.1.6 Project Methodologies

A mechanism methodology is a technical document that defines a standard set
of parameters, criteria and operations required to calculate and quantify the
expected emission reductions or removals to be generated by a Project Activity.
The main purpose of the methodology is to estimate the expected credits to be
issued as accurately as possible, subject to monitoring results. GCOM Project
Methodologies set out detailed procedures describing various aspects of the
proposed project. These aspects include project boundaries, setting baselines,
assessing additionality, and ultimately quantifying the GHG emissions to be
reduced or removed.

The methodologies using GHG-metrics quantify GHG emission reductions and

removals in metric tons of CO2eq using the 100-year global warming potential.
non-GHG metrics are also considered under the mechanism and would quantify
emission reductions and removals in a metric other than CO2eq.

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The acceptable types of methodologies are organized into two categories:

• DNA Prepared Methodologies

o DNA has prepared methodologies for projects that are strategically
important for the Kingdom to achieve its ambitious climate goals.
These methodologies are available to project proponents by
request from the GCOM website:
▪ Methodology for determining emission reductions resulting
from fuel switching from oil to natural gas in existing power
plants for electricity generation.
▪ Methodology for determining emission reductions from
electricity generation from renewable sources.
▪ Methodology for determining emission reductions resulting
from CCS/CCUS activities.
▪ Methodology for determining emission reductions resulting
from projects supporting for the dissemination of electric
vehicles (EV).
▪ Methodology for determining emission reductions resulting
from the application of hydrogen in iron and steel
production.
• DNA Approved Methodologies
o Internationally recognized methodologies approved by DNA such
as methodologies under IREC, Verra and Gold Standards.

5.1.7 Additionality
The Project Proponent must assess additionality of the Project Activity in
accordance with GCOM's additionality requirements, as elaborated in Chapter
6 of this document.

5.1.8 Project contribution to Sustainable Development

The Project Proponent must attest that the project is in material compliance with
all applicable laws, including environmental regulations, when preparing and
planning the project, and must have acquired all required permits, and
completed the required environmental impact assessment.

The Project Proponent must demonstrate that the Project Activity contributes to
sustainable development by progressing at least one of the United Nations
Sustainable Development Goals (UNSDGs). The Project Proponent must also
demonstrate that the GHG reduction or removal project avoids negative

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environmental and social impacts to determine that the Project Activity does
not jeopardize progress on any environmental issues such as air and water
quality, protection of endangered species, conservation of natural resources,
and environmental justice. This assessment must be completed with every
crediting period renewal for all project types.

5.1.9 Bundling of Projects

Generally, each GHG project as defined by the project definition and/ or
project boundary must register separately with the GCOM. However, protocols
for certain project types (as defined in the methodologies) may allow project
boundaries to span multiple activities or locations. Only certain types of GCOM-
recognized GHG projects may be bundled for registration and reporting
purposes.

5.2 VALIDATION
→ To determine whether a project meets all GCOM rules and requirements

The validation process guarantees the reliability and credibility of the project
and its associated emission reductions and removals. The purpose is to
objectively assess the Project Activity for compliance with GCOM requirements
and confirm the corresponding methodology has been applied correctly to
quantify the emission reductions or removals achieved by the Project Activity.

The Project Proponent shall choose a DNA-accredited VVB to validate the PDD
and other relevant documents. The selected VVB must attest that no conflict of
interest exists between it and any of the Project Activity stakeholders. Any fees
associated with the validation function shall be agreed by the Project
Proponent and the selected VVB, independent of the GCOM. The VVB that
performs validation for a project cannot also perform verification for the same
project. Upon completion of the validation function, the VVB is expected to
issue a validation report that is consistent with the relevant GCOM forms.

Selected Committees comprised of DNA Members (based on sector) shall

accredit a list of independent third-party national/ regional/ international VVBs
to conduct the validation function of the projects or activities undertaken by
Project Proponents. VVBs shall be accredited for project validation and
verification in the sector of the applicable methodology according to the
competency requirements and standards set out by the DNA.

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The VVB must keep all documents and records in a secure and retrievable
manner for at least 2 years after the end of the relevant project crediting period,
even if it does not carry out verification throughout the project crediting period.

5.3 SUBMISSION
→ To submit all project documentation & validation report through the
GCOM website for review

The Project Proponent (PP) shall submit all required documents with sufficient
data for consideration by DNA, specifying project type as GHG Metric or Non-
GHG Metric. Submission must include the complete PDD forms that were
previously prepared as well as the associated Validation Report.

Upon submission, the project shall be assigned a unique tracking number that
will not change through the lifetime of the project.

Once all required documents are submitted, the DNA shall begin its review
processes, which include reaching out to the project proponent if any
missing/insufficient data and/or information is identified.

5.4 PROJECT REGISTRATION

→ To officially register accepted projects in GCOM registry

The DNA conducts its review of the project documentation and the associated
validation report. Finalization of the review processes includes a secondary
stakeholder engagement that is held for 15 days on the GCOM website.
Individuals, entities, and interested organizations or group that might have
interaction or interest in the Project Activity are considered stakeholders in this
case. The stakeholder engagement is meant to allow stakeholders to express
their views, comments and concerns regarding a specific Project Activity and its
potential environmental, social and economic impacts.

Upon completion of the review processes, the DNA shall communicate the
results of its review, as:

a. Acceptance
b. Acceptance contingent on requested corrections or clarifications
c. Rejection

Accepted Project Activities shall be issued an official registration letter and be

listed in the corresponding GHG Metric or Non-GHG Metric section of the

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GCOM Registry. All non-confidential information included in the final validated
PDD, the validation report and any other relevant documents and/or data shall
be made publicly available through the registry.

5.4.1 GCOM Registry

The GCOM Registry acts as the central repository for all information and
documentation relating to registered projects or activities. It records and tracks
GCOM projects and activities as well as the associated issuance, transfer,
cancellation and retirement of credits and certificates (both in GHG and non-
GHG metrics).

The registry shall be implemented within a comprehensive and transparent

national registry system and shall be operated by the DNA.

The registry is also responsible to keep record of the ownership of credits, to

ensure integrity of credits issued under the registry by safeguarding against
double counting or double selling of the serialized credits. A serial number is
assigned to each verified credit, so when a credit is sold, the serial number for
the reduction is transferred from the account of the seller to the account of the
buyer. When buyers use or cancel credits the registry retires the serial number of
that credit, such that the same credit cannot be re-sold.

The registry shall also:

• Uniquely identify each mitigation Project Activity and allow for viewing of
any non-confidential information associated with the project.
• Assign serial numbers for credits or certificates generated by each Project
Activity.
• Transparently track ownership of credits in order to make it possible to
trace each credit back to the project from which it was originated.
• Allow to check the status of a credit (i.e., whether a credit has been
retired, transferred or cancelled).

5.5 MONITORING
→ To measure, record, compile, and analyze data & information to calculate
GHG emission reductions and/or removals

The Project Proponent shall implement the monitoring plan as set out by the
applied baseline and monitoring methodology in the validated PDD. This
includes installation of necessary monitoring equipment and/or techniques to
monitor the emission reductions/removals achieved from the Project Activity.

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The Project Proponent shall prepare a Monitoring Report that contains actual
measurements of emission reductions or removals achieved by the Project
Activity and appoint an accredited VVB to audit the monitoring report and issue
a Verification Report.

By the end of the first monitoring period, and each subsequent monitoring
period, the Project Proponent must demonstrate that the project has
contributed to national progress of UNSDGs.

5.6 VERIFICATION
→ To check the results of the monitoring report and verify that the project is
delivering the emission reductions and/or removals

The verification process guarantees the reliability and credibility of the project
and its associated emission reductions and removals. The purpose is to
objectively assess the Project Activity for compliance with the monitoring plan as
set out in the validated PDD and confirm the actual measurements to quantify
the emission reductions or removals achieved by the Project Activity. The project
proponent can decide the interval of verification of its monitoring reports and
may subsequently submit the reports to the DNA a maximum of once per year.

In the case of sequestration projects, the scope of the verification should

include an updated assessment of the risk of reversal and an updated buffer
determination, as applicable.

The Project Proponent shall choose a DNA-accredited VVB to verify the

monitoring report and other relevant documents. The selected VVB must attest
that no conflict of interest exists between it and any of the Project Activity
stakeholders. Any fees associated with the verification function shall be agreed
by the Project Proponent and the selected VVB, independent of the GCOM.

The VVB that performs verification for a project cannot be the same VVB that
performed the validation for the same project. Upon completion of the
verification function, the VVB is expected to issue a verification report that is
consistent with the relevant GCOM forms.

Selected Committees comprised of DNA Members (based on sector) shall

accredit a list of independent third-party national/ regional/ international VVBs
to conduct the verification function of the projects or activities undertaken by
Project Proponents. VVBs shall be accredited for project validation and

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verification in the sector of the applicable methodology according to the
competency requirements and standards set out by the DNA.

The VVB must keep all documents and records in a secure and retrievable
manner for at least 2 years after the end of the relevant project crediting period,
even if it does not carry out verification throughout the entire project crediting
period.

The Monitoring report and Verification report are submitted to DNA.

5.7 APPROVAL
→ To review and approve the verification report and the corresponding
monitoring report before issuing the verified credits

Upon submission of the Verification Report and the Monitoring Report to the
DNA, the DNA shall undertake a thorough review of the aforementioned reports.
The approval or rejection of these reports will be determined by various factors,
including but not limited to, the completeness and accuracy of the information
submitted.

5.8 CREDIT ISSUANCE

→ To issue emission reduction and/or removal credits that correspond with
the approved monitoring and verification reports

Serialized credits are issued by the DNA for the reporting period specified in the
monitoring and verification reports to the Project Proponent's GCOM Registry
account upon approval. For projects with an assessed permanence risk, per the
project type and relevant methodology, GCOM shall elaborate on necessary
measures.

6 GCOM Program Project Additionality

GCOM's additionality requirements are meant to ensure that the credits and
certificates issued by the mechanism go beyond the GHG reductions and
removals that would have happened due to present laws and regulations, or
industry standards. A Project Activity must also be subject to at least one of
three implementation barriers. A Project Activity passes the additionality test if it
results in "additional" emissions reductions that wouldn't have happened in the
absence of the Mechanism. The emission reductions or removals from a GCOM

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Project Activity must lower emissions beyond those that would have occurred in
a "below business as usual" scenario.

To qualify as additional, the GCOM requires every Project Activity to pass a

three-level additionality test:

• A legal or regulatory additionality test

• A common practice test
• An implementation barrier test

6.1 Baseline Scenarios

The baseline scenario represents the GHG emissions that would have occurred
in the absence of the mitigation project. The baseline scenario shall be
determined so that an accurate comparison can be made between the GHG
emissions that would have occurred under the baseline scenario and the GHG
emission reductions and/or removals that were achieved by the Project Activity.

In developing the baseline scenario; assumptions, values, and procedures shall

be selected that help ensure that net GHG emission reductions and removals
are not overestimated.

The Project Proponent is required to set a baseline at a level “below business as

usual” and provide a demonstration in the Project Design Document (PDD)
Form. Setting a below business as usual baseline is required when quantifying the
credits in GHG and non-GHG metrics. The emission reductions or removals
credited utilizing a “below business as usual” baseline should result in a lesser
quantity of credits than the amount that would have been credited utilizing a
business as usual baseline. This is meant to promote environmental integrity,
quality mitigation outcomes, and ensure the Project Activity contributes to a
global net emission reduction by safeguarding against possibility of over-
crediting.

6.2 Three-level Additionality Test

In order to pass the three-levels test, projects must illustrate that they are more
stringent than currently enforced laws and regulations, are more stringent than
the standard in the relevant industry sector and geographic area and are
subject to at least one of three implementation barriers (financial,
technological, or institutional). The GHG Project Plan must include a convincing
justification for the GCOM and The Validator/Verification Body (VVB), that the
project passes these tests.

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Some DNA-approved methodologies require a specific demonstration of
additionality within the application of the methodology. Where the utilized
methodology requires a demonstration of additionality, unless otherwise stated
by the GCOM conditions, the project proponent shall comply with that
requirement and the compliance shall be checked within the validation
process.

6.3 Legal or Regulatory test

The Project Proponent must assess any current laws and regulations that
explicitly mandate the Project Activity and that call for specific technical,
performance, or management activities in order to pass the regulatory surplus
test. These legal requirements may call for the adoption of a particular
technology, compliance with a particular performance standard (such as clean
source performance standards), or management of operations in accordance
with a particular set of rules or procedures.

6.4 Common Practice Test

The common practice test calls for the Project Proponent to assess the dominant
technologies or practices being used in a specific industry, sector, and/or
geographic region, determined by the extent to which those technologies or
practices have permeated the market, and show that the proposed Project
Activity is not common practice and will reduce GHG emissions below levels
produced by common technologies or practices in a comparable environment
(e.g., geographic area, regulatory framework, investment climate, access to
technology/financing).

Depending on the variation of the baseline technologies, different industries and

geographical regions may have different levels of penetration that constitute
standard practice. If there are numerous alternative technologies and methods,
the market share or penetration rate for the typical practice may be extremely
low. In contrast, if there are few competing technologies or practices, the
market share or penetration rate of the prevalent practice may be relatively
high. Projects that are the “first of its kind” are not common practice.

For the duration of their Crediting Period, projects that are thought to go
beyond standard procedure are treated as such. The project may become
non-additional and ineligible for renewal if common practice adoption rates of
a certain technology or practice change throughout the Crediting Period, but
this does not influence its additionality during an active Crediting Period.
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Noting that a performance standard is different from the common practice test.
For some activities, the information used to define common practice in a given
industry, sector, or location may be functionally similar to the information
needed to create a performance standard based on accepted practice. In
these circumstances, Project Proponents may choose the option to show
additionality by creating a performance benchmark based on practices and
proving that the Project Activity both meets and surpasses this standard.

6.5 Barrier Test

An implementation barrier represents a factor that would prevent the execution
of the Project Activity proposed by the Project Proponent. Under the
implementation barriers test, Project Proponents shall choose at least one of
three barrier assessments (financial, technological, or institutional). Project
Proponents may demonstrate that the Project Activity faces more than one
implementation barrier but are not required to address more than one barrier.

6.5.1 Financial barrier

A financial barrier is any obstacle that may prohibit the Project Activity. The
project may encounter difficulties, such as high expenses, restricted access to
financing, or an internal rate of return that is lower than the Project Proponent's
specified and proven minimum acceptable rate in the absence of carbon
revenue.

High risks include unproven technology or business models, unfavorable credit

ratings of project partners, and project failure risk. Project Proponents must
provide strong quantitative proof, such as net present value and internal rate of
return calculations, if they choose the financial implementation barrier test.

6.5.2 Technological barrier

Technological barriers include R&D deployment risk and subsequently risk of
technological failure, non-availability of skilled and/or properly trained personnel
to operate and maintain the technology, lack of infrastructure for
implementation and logistics for maintenance of the technology, and
technology used in the proposed Project Activity is not available in the relevant
region.

6.5.3 Institutional barrier

Institutional barriers include institutional challenges to technology
implementation due to procedures or situations for adopting technologies, new

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policies (e.g., power market restructuring policies), aversion to upfront costs, and
lack of awareness of benefits.

6.6 Positive List

Positive lists identify a broad set of abatement activities that are deemed
additional on a global, regional, or domestic level. If the GCOM Project Activity
applies a technology, fuel or feedstock listed under a positive list, the Project
Activity is deemed automatically additional. The GCOM Positive List is
determined based on research and analysis that applies credible sources of
information and considers national, regional and global additionality. The list is
currently under development and pending review by DNA Committee.

7 Feedback and Grievance Process

Any stakeholders may want to contact the DNA to provide feedback related to
the GCOM process. This can be done through the dedicated web portal using
the feedback email.

A Project Proponent or GCOM stakeholder may object to the application of the

GCOM requirements or a DNA decision by sending a detailed email that
contains any supporting documents to the aforementioned feedback email.

8 Glossary, Definitions, and References

Glossary of abbreviations used in this document

Abbreviation Term
GCOM Greenhouse Gas Crediting & Offsetting Mechanism
CCE Circular Carbon Economy
CCUS Carbon Capture and Use/Storage
CDM Clean Development Mechanism
CO2eq Carbon Dioxide Equivalent
GCOM Greenhouse Gas Crediting & Offsetting Mechanism
GHG Greenhouse Gas
ITMO Internationally Transferred Mitigation Outcomes
LULUCF Land Use, Land Use Change and Forestry

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NDC Nationally Determined Contributions
PDD Project Design Document
SDGs Sustainable Development Goals
VVB Validator Verification Body

Definitions of terms commonly used in this document.

Term Definition
projects or activities which deliver emissions reductions and/or
Additional removals beyond those that would take place in the absence
of the Mechanism.
Article 6 of the Paris Agreement describes how countries can
“pursue voluntary cooperation,” including through
Article 6
international transfer of mitigation outcomes “ITMOs”, for
parties to reach their climate targets.
The process of capturing GHGs at source, before it enters the
Carbon Capture
atmosphere.
An emissions unit that is issued by a carbon crediting program
and represents an emission reduction or removal of
Credit greenhouse gases. Credits are uniquely serialized, issued,
tracked, and retired or canceled by means of an electronic
registry.
A situation in which a single greenhouse gas emission
Double-counting reduction or removal is counted by more than one party or
entity toward achieving its goals.
Nationally Determined Contributions are domestic adaptation
Nationally
and mitigation measures that are nationally determined, and
Determined
that Parties to the Paris Agreement pursue, with the aim of
Contributions
achieving the objectives such contributions.
A reduction or removal of GHG emissions that is used to
Offset compensate for an equivalent amount of emissions from
another GHG emitting activity occurring elsewhere.
An organization or individual that develops and manages
Project Proponent
emission reduction or removal projects.
Verified decrease in GHG emissions measured against baseline
Reduction
emissions.
An activity that reduces emissions from that atmosphere, either
Removal by a nature-based solution or a technology such as tree
planting or direct air capture.

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 A project is “registered” when the project has been verified by
Registered a VVB, submitted by the Project Proponent to the DNA for
approval, and accepted.
The period of time in which the Project Proponent has
Reporting Period monitored, quantified, and reported the GHG reductions to
the DNA.
A project is considered “submitted” when all of the
Submitted appropriate forms have been completed, uploaded, and
submitted to the GCOM platform.
A project is considered “verified” when the VVB has submitted
Verified the project’s Verification Statement and the Verification
Report in the Reserve System.
An independent third-party organization or company that has
Validator
been accredited under GCOM to perform GHG validation/
Verification Body
verification activities.

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