The PACM Era of “Accounting, Not Just Announcing” Begins
Bonn, October 10 2025 —
The Supervisory Body (SB) of the Paris Agreement’s Article 6 under the United Nations Framework Convention on Climate Change (UNFCCC) has formally adopted the A6.4-MEP008-A03: Biochar Carbon Removal and Storage (BiCRS) Methodological Tool.
According to the decision, the tool will enter into force on 25 February 2026, becoming the world’s first biochar-based carbon-removal methodology under the legally binding Paris Agreement Crediting Mechanism (Article 6.4 Mechanism, PACM).The adoption marks a decisive shift: biochar—long treated as a voluntary-market commodity—now attains the status of sovereign carbon accounting, enabling Parties to record it in their Nationally Determined Contributions (NDCs) and issue Article 6.4 Emission Reductions (A6.4 ERs) for compliance trade.
For the first time since the Kyoto era, a nature-based carbon-removal technology (NbS CDR) is recognized at the level of international law as a compliance-grade credit.
Following the announcement, the EU Carbon Removal Certification Framework (CRCF), Thailand’s Greenhouse Gas Management Organization (TGO), and Indonesia’s Ministry of Environment and Forestry (KLHK) each declared plans to align their national carbon-removal regulations with the new methodology.
Biochar, once a by-product of agriculture and renewable energy, is now positioned at the center of climate-governance infrastructure.
1. Birth of the Methodology — From Draft to Treaty Instrument
A6.4-MEP008-A03 was finalized by the Article 6 Methodological Expert Panel (MEP) in early October 2025 and adopted later that month at the SB’s 18th meeting (SBM018).
The 42-paragraph document defines project boundaries, MRV requirements, carbon-content measurement, permanence assessment, utilization tracking, and reversal-risk management.
Paragraphs 38 to 42 became the most cited passages worldwide:
“The quality of biochar shall be certified by a recognized third-party standard such as the European Biochar Certificate (EBC) or equivalent.”
For the first time, the UNFCCC explicitly requires third-party quality certification as a legal precondition for compliance issuance.
EBC, originally a regional European protocol, is elevated to a global benchmark for carbon-removal quality—and a model for future methodologies on mineralization, DACCS, soil carbon, and other CDR types.
According to § 2 of the decision, the BiCRS tool will enter into force on 25 February 2026.
From that date, Parties may register biochar projects under A6.4, have them validated and verified, issue A6.4 ERs, and—through Corresponding Adjustment (CA)—record the results within their national NDC accounts.
2. From International Standard to Domestic Law — Design Becomes Accounting
Within the UNFCCC architecture, the Supervisory Body develops methodologies, which must then be formally adopted by the Conference of the Parties serving as the Meeting of the Parties to the Paris Agreement (CMA) to acquire treaty status.
A6.4-MEP008-A03 is scheduled for inclusion at CMA 7 (Baku, late 2025) as Decision 17/CMA.7.
Subsequently, each Host Party must domesticate the CMA decision—updating MRV guidelines, validation and verification rules, registry procedures, and LoA/CA workflows.
Only after such domestication can national projects operate under A6.4 standards and appear in the UNFCCC registry.
This step effectively transforms Article 6 from institutional design into operational reality.
That is the true historical meaning of A6.4-MEP008-A03:
It converts carbon removal from voluntary storytelling into sovereign accounting.
When 25 February 2026 arrives, the world will witness a new order: biochar will no longer be an ESG narrative but an auditable entry in national NDC ledgers—no longer a Puro.Earth certificate but a UNFCCC-recognized compliance credit.
This paradigm shift extends beyond biochar.
From that day forward, carbon credits cease to be symbolic “green tokens” and become calculable international assets.
The BiCRS methodology’s entry into force represents the carbon-market’s evolution from “what can be said” to “what can be counted.”
It marks the beginning of the Compliance Carbon-Removal Era under PACM.
3. Adoption and Divergence — National Progress and Market Contrast
European Union.
The EU adopted its Carbon Removal Certification Framework (CRCF) in 2024, embedding EBC and ISO 14067 as MRV standards.
The resulting Certified Removal Units (CRUs) are considered potential future EU ETS offsets and are being designed for interoperability with the A6.4 Registry.
Thailand.
In 2025 TGO released the Premium T-VER CDR Methodology, mandating EBC or equivalent certification and aligning its effective date with A6.4 BiCRS — 25 February 2026.
Through CA and direct Article 6 Registry integration, Thailand will become Southeast Asia’s first fully synchronized Host Party.
Indonesia.
KLHK revised the SRN-PPI registry guidelines, adding biochar as a “carbon-removal pilot activity.” From 2026, all such projects must submit EBC test reports and obtain LoA authorization for CA tracking, ensuring results enter the national carbon ledger.
Japan, United States & China.
Japan plans to integrate A6.4 Removals tools into the JCM framework. The US DOE and USDA reference BiCRS standards in their CDR grant programs. China’s 2025 “Voluntary Emission Reduction Regulation” adds an “Agricultural Carbon Removal” chapter, listing biochar as a pilot category, with A6.4 alignment expected post-2026.
Market Contrast — Puro.Earth vs A6.4.
Puro.Earth, the world’s largest voluntary CDR platform, also uses EBC or IBI tests in its Biochar Methodology v3.0, yet its CORC (Certificate of Carbon Removal and Storage) is non-compliance—valid only for voluntary corporate disclosure.
A6.4 BiCRS credits (A6.4 ERs), by contrast, carry treaty status, enter the UNFCCC Registry, and can be converted to ITMOs through CA. In short: Puro speaks; A6.4 accounts.
Puro.Earth is evolving into a technology incubator—helping projects prepare for later migration into the compliance system.
4. SB 6.4 CDR Methodologies Enter into Force — The Operational Launch of PACM
Most headlines emphasized BiCRS alone, yet the real story is broader:
the entire methodological suite of Article 6.4 will enter into force simultaneously on 25 February 2026.
According to the A6.4-SBM018 Meeting Report, the SB approved a first set of operational tools (A6.4-MEP005 to MEP009) covering baseline setting, non-permanence and reversal risk, additionality and common practice, and sustainable-development disclosure.
All are scheduled for the same effective date. As the Chair stated in closing:
“We will not phase these tools; we will launch them together so that every participant enters a complete compliance framework on the same day.”
This one-time activation allows governments to update domestic laws in parallel, avoiding early-implementation gaps.
A6.4-MEP008-A03 may be the most visible, but it is only one piece of the “First Operational Methodology Package,” alongside the Baseline-Setting Tool for Mitigation Activities, Non-Permanence and Reversal Risk Tool, and Tool for Additionality and Common Practice.
By late 2025, Thailand, Indonesia, and Chile had already begun regulatory alignment to ensure national registries open for A6.4 project registration during the activation week.
From a legal perspective, the unified date means Article 6.4 achieves full operational status. Before that, it was a design framework; afterward, Parties can launch projects, validate through DOEs, issue A6.4 ERs, and execute CAs.
The UNFCCC Secretariat described it succinctly:
“The entry into force of the first set of Article 6.4 methodological tools on 25 February 2026 marks the operational start of the Paris Agreement Crediting Mechanism.”
From that moment, the PACM will formally begin. The boundary between voluntary and compliance markets will sharpen: projects not transitioned into A6.4 structures will be classified as non-compliance credits.
National registries—TGO (Thailand), SRN-PPI (Indonesia), and CRCF (EU)—will mirror the UNFCCC master ledger, creating a global PACM “mirror-registry” system.
Biochar is only the first natural-based technology to enter this regime.
Next in line are BECCS, DACCS, mineralization, and regenerative agriculture. Corporate carbon-removal purchases will evolve from voluntary ESG claims to quantified sovereign contributions.
Key Takeaways
- Entry into Force: All A6.4 methodological tools—including BiCRS—become legally operational on 25 February 2026.
- Legal Hierarchy: A6.4 ER = treaty-backed sovereign credit (eligible for CA and ITMO); Puro CORC = voluntary disclosure only.
- Quality Requirement: EBC or equivalent third-party certification is mandatory for biochar per § 38–42 of A6.4-MEP008-A03.
- Governance Shift: Control moves from private standards to national authorities via Host Party law and UNFCCC registry integration.
- Market Impact: Voluntary gray zones will close; PACM registries become the backbone of global CDR accounting.
