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https://registry.verra.org/app/projectDetail/VCS/4381?_gl=1*ri7zy*_gcl_au*MTM0OTUzMjAxMS4xNzUxMjQ4MTI2*_ga*ODg2MDUxMTAyLjE3MDE2ODI3NDM.*_ga_2VGK901B6P*czE3NTQ0NTMwNTQkbzM5MiRnMSR0MTc1NDQ1NTU3MiRqNjAkbDAkaDA.

https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=140073&IDKEY=niquwesdfmnk0iei23nnm435oiojnc909dsflk9809adlkmlkf0193160667

Systematic Non-Compliance and Fabrication

Additional evidence indicates that these projects were non-compliant not only at the level of Article 6 alignment, but also under Indonesia’s own mandatory national rules.

First, the projects never applied Indonesia’s legally required FREL/FEL (Forest Reference Emission Level / Forest Emission Level) in baseline construction. Instead, project-level baselines were created entirely outside the national framework, despite Indonesia having an officially submitted and approved FREL under the UNFCCC. This alone disqualifies the projects from being considered valid mitigation activities under Indonesian law and international REDD+ norms.

Second, FPIC procedures were demonstrably fabricated. Community representatives presented as independent consent providers were, in several cases, the same individuals holding positions as local forestry officials, creating an obvious conflict of interest and invalidating any claim of free, prior, and informed consent. These irregularities were not corrected or meaningfully investigated.

Third, despite these fundamental defects, VVB CTI failed to flag or investigate the violations and nonetheless issued VVB reports that were submitted to Verra for registration. This process collapsed only on 25 March 2024, when CTI was suspended following its involvement in a separate large-scale fraud case in China. As a result, the project was forced back into “under development” status—not due to substantive corrective action, but due to verifier incapacity.

Critically, this did not lead to remediation. On 30 October 2025, the same project was resubmitted for validation under the guise of an “update,” this time reclassified from REDD+ to ARR. Yet the core violations remained unchanged: FPIC irregularities persisted, national FREL/FEL were still not used, and the project was never properly registered within Indonesia’s national carbon system. The methodological relabeling functioned as a reset of paperwork, not as compliance.

Throughout this period, false representations were actively made to Taiwanese investors and partners. These included claims that the project had already been “registered,” that carbon credits were imminent, and that annual issuance would reach “one million tonnes.” In reality, what existed was at most a preliminary project code or listing, not legal registration, not authorization, and not any completed regulatory process under Indonesian law.

Moreover, Indonesian government documents were allegedly fabricated or misrepresented. At no point were there valid, legally issued Indonesian approvals demonstrating completion of required procedures, host-country authorization, or recognition under national regulations. No lawful basis existed for claiming offset eligibility or future credit issuance.

Taken together, these facts point to a broader structural failure. Verra’s system—despite memoranda of cooperation with Indonesia—has functioned as an enabling environment for misrepresentation, allowing non-compliant projects to circulate internationally, particularly in jurisdictions such as Taiwan where Article 6–aligned oversight is absent. The result is not climate finance, but systematic capital extraction under the appearance of climate action.

This is not an allegation based on disagreement over standards.

It is a documentation of repeated regulatory non-compliance, verifier failure, and factual misrepresentation, none of which were substantively corrected before continued attempts at monetization.

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https://www.youtube.com/watch?v=LEt_EqOxQTA&t=32s

Misuse of the UNFCCC COP28 Platform

An additional and particularly serious concern is that some of these actors did not merely operate in regulatory gray zones, but actively leveraged the UNFCCC COP28 platform itself to launder credibility. By appearing in side events, fringe sessions, or loosely affiliated showcases around COP28, these projects wrapped themselves in the visual and institutional legitimacy of the UN climate process, despite lacking alignment with sovereign accounting requirements under Article 6.

This tactic exploits a well-known vulnerability in the COP ecosystem: while the UNFCCC sets the rules for intergovernmental accounting, the surrounding conference space allows a wide range of non-state actors to present narratives without formal validation. For unsophisticated investors or corporate audiences, the distinction between “being present at COP” and “being compliant with Paris Agreement accounting” is easily blurred. In these cases, COP visibility was used not to advance climate governance, but to manufacture perceived legitimacy for projects that could not meet host-country or Article 6 standards.

The issue here is not participation in COP per se, but representation. When projects that fail sovereign authorization or corresponding adjustment requirements present themselves under the symbolic umbrella of the UN climate process, the result is a form of institutional arbitrage. It allows legacy voluntary market narratives to survive longer than they should, precisely at a moment when sovereign systems are attempting to assert accounting discipline. This practice risks undermining trust not only in carbon markets, but in the broader multilateral climate framework.

In a sovereign carbon accounting era, COP participation cannot substitute for compliance. Visibility is not verification. Presence is not authorization. And association with the UNFCCC does not transform a non-accounted credit into a mitigation asset.

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