📘 AAE recently conducted a Gap Analysis of Voluntary Carbon Market (VCM) Standards against Safeguards Requirements and Good Practice, commissioned by KfW. The analysis reviewed six leading VCM standards — including the two most widely used core standards, VCS and Gold Standard, as well as Plan Vivo, SD VISta, CCBS, and Social Carbon — to assess how they align with international safeguards benchmarks such as the World Bank Environmental and Social Standards (ESS), ILO Core Conventions, UNDRIP, and others.
💡 Our takeaway? Many VCM standards still lack several basics when it comes to environmental and social risk management.
➡️ Human rights, land tenure, Indigenous Peoples' rights, and gender — even though these are critical and widely acknowledged safeguard topics — are still poorly covered areas by most standards.
➡️No single VCM standard meets all safeguards aspects of good practice. Even combining standards often fails to fully close the gaps.
➡️VCS and Gold Standard, the two most widely used VCM standards, lack simple and structured Environmental and Social Management Systems (ESMS) and fall short on key safeguard areas like Indigenous Peoples’ rights, security risks, and benefit-sharing. Despite being dominant in the market, neither provides full protection for vulnerable groups.
➡️ While Plan Vivo is considered a niche standard, its requirements have evolved significantly — just last year it published a new Environmental and Social Risk Management in Plan Vivo Projects: Plan Vivo E&S Procedures. It now includes one of the most structured approaches to risk screening, stakeholder engagement, and grievance mechanisms.
➡️ Plan Vivo also stands out as the only standard that addresses risks from patrolling and security personnel — a growing concern in projects involving conservation law enforcement or access restrictions. Yet even Plan Vivo has limitations, e.g. by lacking specific protection of remote groups in voluntary isolation and it does not include explicit safeguards for indigenous intellectual property rights.
🚨 From a safeguards perspective, these findings raise concerns — especially as VCMs continue to scale up as a major climate finance mechanism. Without clear and enforceable safeguards, the risk of harm to people and ecosystems remains high, as well as project credibility!
✅ The path forward? VCMs need more than just carbon accounting. They need robust, transparent, and enforceable safeguards — built into their core — to ensure projects genuinely protect people, their rights, and ecosystems. Strengthening Environmental and Social Management Systems (ESMS), ensuring culturally appropriate stakeholder engagement, and embedding human rights protections are essential steps to ensure the VCM truly delivers on its promise of sustainability. Our analysis can help understand existing gaps, and, until they are filled by the standard providers themselves, suggests gap filling measures that can be used by implementers.
📄 You can read the full report here:
More insights coming soon via the Safeguards Hub!