Challenges Implementing Article 6 from the Perspectives of Party Representatives

Survey responses revealed the most significant barriers and challenges for Article 6 Implementation, as shown in Figure 17. Among the 90 Parties invited to participate, 29 responded, resulting in a 32% response rate. The most significant challenge/barrier to implementation was gaining a general understanding of Article 6 itself;  31% identified this as their top priority. The need to create a strong policy framework is an additional primary challenge, selected by 20% of survey respondents. Additional challenges included  creating legal frameworks (14%) and addressing the absence of finalized Article 6.4 rules (7%). 
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Moreover, 28% of responses combined several barriers, including bottlenecks. gaps, or low capacity in local carbon market operating environments: identifying sources of demand (6.2, CORSIA,VCM, 6.4); inter-ministerial coordination issues; lack of overall political interest or will; inconsistent or inaccessible finance; unclear or inconsistent supply managing overselling risks; and challenges in developing or selecting methodologies. These findings indicate that guidance is necessary to assist Parties understand the complexities of Article 6 and establish the policies and legal frameworks needed for effective implementation.

Survey responses emphasized the most prioritized technical assistance needs for Article 6 readiness, with capacity building challenges (see Figure 17).  Respondents emphasized the need for a deeper understanding of Article 6 (37%) and support for drafting strategies and policy frameworks (30%). Additionally, 11% mentioned the importance of linking Article 6 to their national transparency frameworks, highlighting a need for alignment with climate accountability goals under the Paris agreement. Other technical assistance needs, comprising 32% of responses including priorities such as support for the application of corresponding adjustments, development of Article 6.2 authorization arrangements, identification of potential mitigation activities or types, mitigation of overselling risks, formulation of Article 6 reports, informed decision making on registry options and enhanced understanding of methodologies.The responses clearly indicate that Parties need foundational support to understand Article 6 and build the policy groundwork necessary for implementation. With the appropriate support, Parties can move past early challenges and ensure that Article 6 efforts line up with national climate goals.

6.2 A6ISR Survey (Open Ended Questions)

​The open-ended responses from the A6ISR survey offer additional insight into the challenges Parties face implementing Article 6. A key commonality is the need for robust regulatory frameworks, which are crucial yet difficult to establish. While many Parties aim to align Article 6 efforts with NDCs, adapting GHG reduction strategies to their unique economic and environmental conditions represents a significant challenge. Respondents noted a need for enhanced expertise on national carbon markets, as Article 6 demands specialized knowledge in designing, implementing, monitoring, and evaluating projects. 
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Although engagement with the private sector introduces additional complexity, it is critical to widespread implementation of Article 6. Respondents highlighted that the private sector requires a better understanding of Article 6 and also needs to build skills to structure projects for funding. Respondents expressed concern that businesses may be driven by financial returns over climate goals. Practical issues such as limited staffing, knowledge gaps, and inconsistent funding create additional complications. Respondents further  acknowledged that limited budgets and high certification costs represent challenges to launching and maintaining projects. There are also other obstacles such as shifting government priorities, wavering practical will, and fluctuating demands. Strong coordination across government agencies requires extensive training and awareness to ensure the participation of government officials and the private sector. Respondents also stressed the importance of collaboration across ministries to develop a unified approach to carbon trading. 
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Policy development and integrity concerns pose further challenges, with Parties often struggling to integrate Article 6 requirements into their national frameworks. Respondents raised questions about additionality, with concerns about whether activities genuinely reduce GHGs and support NDC goals. Complications also arise from credit transfer limits, identifying demand, and meeting complex authorization criteria. For Parties in the early stages of building carbon markets, creating a supportive environment that enables Article 6 cooperative approaches can be overwhelming. For example, policies regarding carbon ownership, land rights, institutional structures, and roles for market participants are essential for successful carbon markets. 

Finally, respondents expressed a need for clear guidance on methodologies and corresponding adjustments, as well as capacity-building tailored to local needs. Small and developing Parties in particular emphasized the need for support in building institutional frameworks, learning reporting standards, and developing technical skills to ensure an inclusive approach to Article 6 readiness.