# Double counting policy

<table data-header-hidden><thead><tr><th width="261"></th><th></th></tr></thead><tbody><tr><td><strong>Document name</strong></td><td>Rainbow Double Counting Policy</td></tr><tr><td><strong>Release date</strong></td><td>November 20th 2025</td></tr><tr><td><strong>Version number</strong></td><td>1.2</td></tr><tr><td><strong>Status</strong></td><td>Public consultation</td></tr></tbody></table>

### Purpose of this document <a href="#z80749zd5wtb" id="z80749zd5wtb"></a>

The purpose of this document is to:

* Outline the requirements set by the Rainbow Standard to ensure that carbon credits are unique, following the No Double Counting criteria in the [Rainbow Standard Rules](https://docs.rainbowstandard.io/~/changes/215/rainbow-standard-documents/rainbow-standard-rules).
* Inform Project Developers and carbon credit buyers to avoid making misleading claims about the greenhouse gas emission reductions their activities enable

## Double use

### Background <a href="#id-5gl6uhgvjpri" id="id-5gl6uhgvjpri"></a>

Double use occurs when a single carbon credit is used and/or retired twice (by two entities, or two times by the same entity). This is prevented on the Rainbow Registry, where Rainbow Carbon Credits are traced with a unique identification number from issuance to retirement.

An immutable certificate is generated upon retirement, available to the public on the Rainbow Registry, with the following information:

* Entity that retired the carbon credit
* Vintage year
* Mechanism (avoidance or removal)
* Date of retirement
* Credit IDs
* Credit source (project name and information)
* Any applicable credit labels (e.g. CORSIA)

Refer to the [Rainbow Procedures Manual](https://docs.rainbowstandard.io/~/changes/215/rainbow-standard-documents/broken-reference) for more detailed information.

There are no project-specific requirements related to double use.

## Double issuance

Double issuance occurs when multiple carbon credits are issued for one greenhouse gas (GHG) reduction or removal activity. This can occur in two ways:

* Two carbon credits are issued for the same amount of emission reductions or removals that actually occurs
* Two different entities (e.g., the manufacturer of the material/equipment and the user), both claim the same GHG avoidance or removal and request carbon credit issuance for it, to the same or two different crediting standards.

### Requirements

Projects shall not seek credit issuance for the same GHG avoidance or removal under the Rainbow Standard and another crediting program. Project Developers commit to this by signing the [Rainbow MRV & Registry Terms & Conditions](https://docs.rainbowstandard.io/~/changes/215/other/terms-and-contracts/terms-and-conditions-for-project-developers-mrv-+-registry).

Where there exists a risk of overlapping claims of GHG avoidance and removal between actors in the same supply chain, projects shall clearly delineate the GHG accounting boundary of the GHG avoidance and removal activity. The Rainbow Standard shall only issue one carbon credit for the GHG avoidance or removals that occur within the project’s GHG accounting boundary, and not to any overlapping activities.

Methodologies may specify requirements for projects to reduce risk of double issuance between actors in the same supply chain by, for example:

* Obtaining signed agreements from upstream suppliers or downstream users
* Adding relevant clauses in sales contracts
* Providing information to users via marketing, packaging, or other outreach

Projects shall not be eligible for Rainbow Carbon Credits if the Certification team identifies overlaps of GHG accounting boundaries with another project’s GHG accounting boundaries, within the same or any other crediting program.

If the project is already registered under another crediting program, and intends to register and/or issue credits under the Rainbow Standard, the project must prove that the same emission avoidance and removals will not be issued under both crediting programs, and shall de-register from the other program (although previously issued credits may still be sold on the other program's registry). Only GHG avoidance and removal units of a different vintage and/or scope, that have not already been issued under the other crediting program, shall be eligible for Rainbow Carbon Credits.

The project shall provide the following information related to the project status under the other crediting program to Rainbow:

* Project unique identifier
* Vintage period(s) and corresponding volumes
* Proof of de-registration with the other crediting program.&#x20;

Rainbow shall complete regular spot checks to ensure that the same project, and different projects with overlapping project scopes and mitigation activities, are not also included on other registries under other carbon credit programs. Spot checks are conducted for each project based on geographies, similar processes types, and other standards/methodologies. Projects found to be non-compliant will face penalties outlined in the [Rainbow MRV & Registry Terms & Conditions](https://docs.rainbowstandard.io/~/changes/215/other/terms-and-contracts/terms-and-conditions-for-project-developers-mrv-+-registry).

## Double claiming <a href="#id-3rdcrjn" id="id-3rdcrjn"></a>

Double claiming occurs when the same GHG emission avoidance or removal is claimed by two different entities towards their mitigation targets, inventories, or pledges. The following sections outline requirements to prevent double claiming across several scenarios.

### Double claiming with an NDC <a href="#id-6dhpi8s4eli1" id="id-6dhpi8s4eli1"></a>

If one of the following conditions are met, Project Developers shall follow requirements in 3.2.2 through 3.2.5.

* the project issues carbon credits for use towards a nationally determined contribution (NDC), or
* the project issues carbon credits for a domestic climate mitigation target of a jurisdiction or nation **other than the host country**, or
* the project issues RCC to be used under CORSIA.

Obtain an authorisation by the project’s host country, to use the project carbon credits for the intended purpose. This authorization will be made publicly available with the project documentation, and updated as needed.

Obtain confirmation from the project’s host country, that the corresponding carbon credits will be granted a corresponding adjustment. This written confirmation will be made publicly available with the project documentation, and updated as needed.

Ensure the project’s compliance with host country regulations/guidance relating to the voluntary use of carbon credits that are also accounted towards a country’s NDC.

### Double claiming with national climate policies and emissions trading schemes <a href="#id-570lol5y7f23" id="id-570lol5y7f23"></a>

If the following conditions are met, Project Developers shall follow requirements in 3.3.3.

* the **host country** has a regulated domestic climate mitigation target and/or national emissions trading scheme, and
* the project’s GHG removal/avoidance units fall within the scope of the host country’s domestic climate mitigation target and/or national emissions trading scheme, and
* the GHG avoidance or removal units may also be **claimed by another country**, **jurisdiction, or entity**

Obtain a letter from the host country/regional regulator stating that the GHG removal or avoidance unit is not accounted for under the host country’s domestic mitigation target and/or national emissions trading scheme, or that an accounting adjustment or cancellation has been made.

### Double claiming with other GHG-related environmental credits <a href="#id-58gecp17gmks" id="id-58gecp17gmks"></a>

Project Developers shall not seek issuance of credits for GHG avoidance and removal units under the Rainbow Standard at the same time as another GHG-related environmental credit for the same project activity and time period. Project Developers commit to this by signing the [Rainbow MRV & Registry Terms & Conditions](https://docs.rainbowstandard.io/~/changes/215/other/terms-and-contracts/terms-and-conditions-for-project-developers-mrv-+-registry).

If the Project Developer seeks to issue credits with another GHG-related environmental credit framework for a **different time period** than GHG avoidance and removal units sought under the Rainbow Standard, the Project Developer shall provide evidence that the other GHG-related environmental credits will not be issued for the same time period as the impact credited under the Rainbow Standard.

### Double Claiming of Emissions for Reporting Towards Voluntary Climate Pledges <a href="#qraiq97rpz8g" id="qraiq97rpz8g"></a>

Where the Project Developer is a buyer or seller of a product within a supply chain, and implements a project that generates a GHG avoidance/removal that changes the GHG inventory of another entity within the supply chain (e.g. through insetting), there is a risk that the other entity upstream or downstream within the supply chain could double claim the GHG avoidance/removal.

The Project Developer shall

* inform entities throughout the supply chain that they are claiming and reporting the emission reductions from the associated intervention,
* retire the associated Rainbow Carbon Credits on the registry on their own behalf,
* and inform Rainbow of the associated change in their product's emission footprint through an issued statement.

Any transfer of GHG removal/avoidance units from one entity to another within the supply chain must be documented through an authorized project representative issuing a signed statement detailing the transfer that has occurred.

Situations may arise where two end users seek different types of claims (e.g. contributory vs. offsetting claims) from GHG avoidance/removal units issued by the same Project Developer from the same project. Under such circumstances, the company shall seek guidance from reporting companies, the GHG Protocol, and other accounting tracking mechanisms that emerge.

## Claims under Article 6 of Paris Agreement <a href="#id-44sinio" id="id-44sinio"></a>

Projects that aim to issue RCCs that meet the requirements of Article 6 of the Paris Agreement, or other Paris Agreement-related programs such as CORSIA, must be differentiated from RCCs that are only eligible to be used for voluntary carbon market purposes. This is to prevent double counting between the host country’s NDC and the buyer or airline’s own climate targets, accounting and claims. As such, unique Rainbow Standard labels can be issued to avoidance or removal credits that meet the requirements of Article 6 and CORSIA.

The Rainbow Standard mainly covers projects based in Europe. In the context of Article 6, sellers of Internationally Transferred Mitigation Outcomes (ITMOs) are most likely to be low-income countries, while high-income countries, such as European countries are more likely to be the buyers. This is due to greater financial need, higher emission reduction potential at a lower cost, and the ability for ITMOs to facilitate technology transfer and capacity building in lower-income countries. Furthermore, high-income countries are more likely to purchase ITMOs to take responsibility for historical emissions and meet emission reduction targets.

Therefore, while the Rainbow Standard has introduced the use of Rainbow Standard labels to enable the use of credits under Article 6, at least in the short term, projects located in Europe are unlikely to become sellers of ITMOs under Article 6. However, seeking the labeling of Rainbow Carbon Credits remains an option for Project Developers, since ITMOs may be used for other purposes.

### Requirements <a href="#id-6mqrc39hkuc3" id="id-6mqrc39hkuc3"></a>

Any project that intends to issue Rainbow Carbon Credits for use under Article 6 or CORSIA shall meet any necessary established requirements specifically recognised under Article 6 of the Paris Agreement and CORSIA mechanisms. Projects that meet these requirements, including those relating to double counting and corresponding adjustments, may receive the relevant Rainbow Standard labels. These credits will be labeled accordingly and be made available within the Rainbow Registry.

Rainbow labeled credits may also be used for voluntary carbon market purposes that do not require Article 6 or CORSIA labels but not vice versa.

To obtain the Rainbow Standard labels on Rainbow Carbon Credits, the Project Developer must provide an official Letter of Authorisation from the Host Country. The Letter of Authorisation shall be made public on the Rainbow Registry. A template letter is made available [here](https://docs.rainbowstandard.io/~/changes/215/rainbow-standard-documents/procedural-templates/letter-of-authorization-article-6-corsia).

The Project Developer applying these requirements shall provide evidence to Rainbow that the Host Country has applied relevant corresponding adjustments in accordance with Article 6 of the Paris Agreement and its Letter of Authorisation. It shall also provide evidence that the Host Country is and continues to fulfill its obligations required under the relevant Paris Requirements.

The Project Developer shall provide evidence of the appropriate application of a corresponding adjustment within two years of the required application of corresponding adjustments pursuant to Article 6 of the Paris Agreement.

If the Project Developer is unable to provide evidence of the appropriate application of a corresponding adjustment, Rainbow upholds the right to withdraw the Rainbow Standard label from carbon credits in the registry and inform all account holders.

Rainbow shall prepare and publish regular annual reports prior to April 1st of each calendar year, on the status of Rainbow Carbon Credits associated with Article 6 authorisations on its website. The report will provide information relating to Rainbow Carbon Credits authorized for use as ITMOs and categorize this data by host country, project activity type, and vintage. This will provide information to fulfill their reporting obligations in accordance with the Paris Agreement.

## Version history

<table data-full-width="true"><thead><tr><th width="399">Description of the change</th><th>Justification</th><th width="183">Date</th><th>Version changed to</th></tr></thead><tbody><tr><td>Specified projects must de-register from other program before registering with Rainbow</td><td>Stricter protection against double issuance</td><td>November 2025</td><td>V1.0 to V1.1</td></tr></tbody></table>
