On March 1, the Institute of International Finance (IIF) submitted a response to the International Organization of Securities Commissions (IOSCO) Voluntary Carbon Markets – Consultation Report. The letter focuses on several cross-cutting themes that leverage the IIF’s engagement on issues regarding the environmental integrity of carbon credits and market integrity dimensions of carbon markets, to date. We welcome IOSCO’s holistic approach to fostering the development of sound and well-functioning voluntary carbon markets, as we strongly believe that these markets are a critical component of the global response to climate change and the Net-Zero transition.

The response makes a number of specific suggestions, including but not limited to:

• Encouraging IOSCO to leverage the work of key VCM governance bodies, such as the Integrity Council for the Voluntary Carbon Market (ICVCM), and the Voluntary Carbon Market Integrity Initiative (VCMI) to support greater standardization and strengthen supply and demand-side integrity;
• Emphasizing that market integrity and environmental integrity are separate concepts which may warrant specific consideration by different entities;
• Requesting that IOSCO and its members strive for alignment across emerging regulatory guidance in key markets, and encourage that all regulation should follow existing financial market best practices.