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Organizations Involved: Institute for Policy Integrity

Source: Institute for Policy Integrity

Abstract

In December 2023, the Commodity Futures Trading Commission (CFTC) proposed guidance that identifies key features of high-integrity voluntary carbon credits (VCCs) for exchanges that list certain VCC derivatives. The Institute for Policy Integrity submitted comments that highlight additional sources of CFTC legal authority over these derivatives and suggest improvements to the proposed guidance’s discussions of additionality, leakage risk, quantification, risk of reversal, and exchanges’ discretion to set stringent standards. Finally, the comments recommend that the CFTC explore whether it has other authority to address issues with VCC integrity and whether to seek additional authority from Congress.

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