PCS GA 013 Grievance & Appeals Procedure_v1.0

Document Control

Document identification

  • Document code: PCS-GA-013

  • Title: Grievance & Appeals Procedure

  • Scope: Defines the institutional mechanism for submitting, assessing, investigating, and resolving grievances and appeals related to PCS governance, projects, methodologies, VVB conduct, registry operations, safeguards/SDG integrity, and PCS decisions.

  • Outcome: Provides a transparent, fair, and accessible due-process pathway with clear roles, timelines, confidentiality protections, documentation requirements, and enforceable outcomes.

Version history and change log

Table DC-1. Revision history

Version
Date
Status
Summary of changes
Prepared by
Approved by

v1.0

TBD

Draft

Initial release for public consultation

PCS Secretariat

TBD

Superseded versions

No superseded versions for v1.0.

Governance note on versioning and archiving

Only the latest approved version of this Procedure shall be used. Superseded versions shall be archived and retained for traceability and audit purposes. Printed or downloaded copies are uncontrolled; stakeholders must refer to the PCS Registry publication as the authoritative current version.

Chapter 1 - Introduction And Purpose

1.1 Purpose of the Procedure

  1. The purpose of this Grievance and Appeal Procedure is to establish a transparent, fair, and accessible mechanism through which any stakeholder may raise concerns regarding the conduct, decisions, processes, or outcomes associated with the Planetary Carbon Standard.

  2. This procedure ensures that grievances and appeals are addressed in a timely, impartial, and consistent manner. It reinforces accountability within PCS, safeguards the integrity of governance processes, and supports the rights of stakeholders who may be affected by PCS decisions.

1.2 Importance of Grievance and Appeals Mechanisms

  1. Effective grievance and appeals mechanisms are essential components of robust standard governance. They provide an avenue for addressing concerns related to the actions of project developers, Validation and Verification Bodies, the PCS Secretariat, or the PCS Regulatory Council. They also help identify systemic issues, strengthen operational policies, protect vulnerable parties, and promote continuous improvement.

  2. The mechanism ensures that PCS decisions—including those involving methodology approvals, project registrations, issuance of Planetary Carbon Units, and accreditation actions—can be reviewed and, where justified, reassessed.

1.3 Principles Governing the Procedure

  1. This procedure is guided by the principles of fairness, impartiality, transparency, accessibility, confidentiality, and non-retaliation. Stakeholders must be able to raise concerns without fear of discrimination or retribution. All grievances and appeals must be evaluated objectively, based on evidence, procedural rules, and PCS governance frameworks. Records of grievances and appeals must be maintained in the PCS Authorization Archive to ensure accountability and institutional learning.

1.4 Institutional Roles and Responsibilities

  1. The PCS Secretariat is responsible for receiving, documenting, and administering grievances and appeals. It conducts initial assessments, coordinates investigations, communicates with stakeholders, and prepares recommendations.

  2. The PCS Regulatory Council serves as the final decision-making body for appeals and for grievances involving Secretariat actions. Independent experts may be engaged in investigations when specialized knowledge is required. The system ensures that no individual or body is responsible for reviewing its own decisions, thereby maintaining objectivity and impartiality.

1.5 Applicability of this Procedure

  1. This procedure applies to all stakeholders interacting with PCS, including project developers, VVBs, host country authorities, indigenous communities, affected individuals, civil society organizations, methodology proponents, and members of the public.

  2. It applies to grievances concerning conduct, procedural errors, ethical concerns, and disputes related to project activities. It also applies to appeals directed at PCS decisions, including methodology approvals, project registration outcomes, accreditation rulings, and issuance decisions.

Chapter 2 - Scope Of The Procedure

2.1 Overview of the Scope

  1. This procedure defines the institutional rules and processes through which grievances and appeals may be submitted, assessed, investigated, and resolved within the Planetary Carbon Standard. It establishes the boundaries of what issues can be raised, who may raise them, and how they are addressed by the PCS Secretariat or the PCS Regulatory Council.

  2. The scope of this procedure is intentionally broad to ensure that all legitimate concerns related to PCS activities, decisions, or governance processes are reviewed in a fair and transparent manner.

2.2 Types of Issues Covered by the Procedure

  1. The grievance component of this procedure covers concerns related to misconduct, procedural errors, ethical violations, non-compliance with PCS rules, operational failures, environmental or social harm arising from projects, and any actions or omissions by stakeholders participating in PCS activities. It also covers concerns regarding the behavior or performance of Validation and Verification Bodies, project developers, methodology proponents, members of the PCS Secretariat, and any other entity acting within the PCS ecosystem.

  2. The appeal component addresses formal challenges to decisions made by the PCS Secretariat or the PCS Regulatory Council, including decisions on methodology approval or rejection, project registration, issuance of Planetary Carbon Units, accreditation rulings, rejection of clarifications, or determinations affecting stakeholder rights or eligibility.

2.3 Stakeholders Eligible to Submit Grievances and Appeals

  1. Any person or entity with a legitimate interest in PCS-related activities may submit a grievance or appeal. This includes project developers, VVBs, host country authorities, indigenous or local communities affected by project activities, civil society organizations, research institutions, methodology proponents, partner institutions, and members of the general public. The procedure ensures that no restriction is placed on eligibility, provided that the complainant can demonstrate a reasonable connection between their concern and PCS activities. Anonymous grievances may be accepted when credible evidence is provided, although anonymity may limit the Secretariat’s ability to seek clarifications.

2.4 Application Across PCS Functions and Tracks

  1. This procedure applies across all functions and operational areas of PCS. It covers grievances and appeals arising from Regular Track projects, Nature-based Solutions Track projects, methodology development, methodological revisions, VVB accreditation activities, registry-related operations, safeguard and SDG assessments, and stakeholder engagement processes.

  2. Regardless of the procedural area in which an issue originates, the grievance and appeal process follows the same overarching principles of fairness, transparency, and accountability.

2.5 Actions and Decisions Subject to Appeal

  1. Appeals may be lodged against decisions made by the PCS Secretariat or PCS Regulatory Council that have a material impact on the rights, obligations, or status of a stakeholder. These include decisions such as the approval or rejection of methodologies, decisions on methodology clarifications, acceptance or refusal of project registration, issuance or denial of Planetary Carbon Units, decisions relating to the accreditation or suspension of Validation and Verification Bodies, or any other formal ruling issued under PCS rules.

  2. Appeals that challenge decisions outside PCS jurisdiction cannot be considered under this procedure.

2.6 Exclusions from Scope

  1. Certain matters fall outside the scope of this procedure. PCS cannot review disputes that arise solely under national jurisdiction, such as disagreements between project developers and landowners, community-level social conflicts unrelated to PCS requirements, national permitting issues, or disputes governed entirely by contractual terms between private parties. This procedure also does not cover issues managed under separate PCS mechanisms, such as formal deviation requests from approved methodologies or project-level corrective action requests issued by VVBs, unless these matters escalate into grievances or appeals related to PCS governance.

2.7 Relationship to Other PCS Mechanisms

  1. This grievance and appeal procedure is intended to complement, not replace, other governance tools within PCS. For example, issues involving methodological inconsistencies may lead to methodological clarifications or revisions, while oversight findings related to VVB performance may lead to accreditation actions. Safeguard-related issues may trigger additional compliance checks under the PCS Safeguard Framework.

  2. Where an issue intersects with multiple governance areas, the PCS Secretariat determines the appropriate procedural pathway while ensuring that the complainant retains access to review through this grievance mechanism.

2.8 Geographic and Institutional Coverage

  1. This procedure applies to all PCS activities globally, regardless of the country or region in which project activities take place. It also applies across all institutions participating in PCS processes, including project entities, VVBs, consulting organizations engaged in methodology development, digital MRV service providers, and Secretariat personnel.

  2. The procedure ensures consistent treatment of grievances and appeals irrespective of origin, geography, or institutional context.

2.9 Temporal Applicability

  1. Grievances and appeals may be submitted at any point after the event or decision in question, provided that the issue falls within PCS jurisdiction and that sufficient evidence is available to support a meaningful review. There is no rigid time limit for submitting grievances related to misconduct or environmental or social harm, as such issues may only become apparent after significant time has passed.

  2. Appeals to PCS decisions, however, must follow the submission timelines described in later chapters of this procedure to enable orderly governance.

Chapter 3 - Types Of Grievances

3.1 Purpose of Categorizing Grievances

  1. The classification of grievances is essential for ensuring that each concern received by the Planetary Carbon Standard is addressed through the appropriate institutional pathway. By grouping grievances into categories based on their nature, origin, and potential impact, the PCS Secretariat can ensure that investigations are conducted with the correct level of rigor, that the responsible bodies are engaged, and that outcomes are consistent, fair, and timely. Categorization also helps PCS identify recurring issues, structural governance gaps, and areas requiring policy or procedural reform.

  1. One category of grievances relates to concerns about the governance processes administered by the PCS Secretariat or the PCS Regulatory Council. These include allegations of procedural irregularities, administrative errors, unjustified delays, or failures to comply with the governance rules outlined in PCS manuals and procedures. Stakeholders may raise concerns if they believe that decisions were made without proper review, that required consultation steps were omitted, or that governance processes were not applied consistently. Such grievances are treated with seriousness because they directly affect the integrity of the PCS governance system.

3.3 Grievances Concerning Methodology Development and Approval

  1. Another important category concerns issues arising from methodological submissions, evaluations, public consultations, and approval processes.

  2. Stakeholders may submit grievances regarding inadequate scientific justification, improper handling of public comments, perceived methodological bias, or concerns that the review process was incomplete or inconsistent with the principles governing methodology governance.

  3. These grievances often require careful technical assessment, because they may relate to scientific validity, environmental integrity, or fairness in methodology development. They also play an important role in identifying weaknesses in methodological frameworks that may require future clarification or revision.

  1. Grievances may be raised concerning the conduct, performance, or impartiality of Validation and Verification Bodies operating under PCS. This includes allegations that VVBs have failed to follow approved methodologies, have conducted inadequate due diligence, have overlooked evidence, or have demonstrated bias or conflict of interest. Such grievances may also relate to concerns over the professionalism, capacity, or ethical conduct of VVB personnel. These matters are addressed through both this grievance procedure and the PCS Procedure for Accreditation and Approval of VVBs, depending on their nature and severity.

  2. Complaints against VVBs are particularly important because of the central role VVBs play in ensuring independent assurance of emission reductions and removals.

3.5 Grievances Involving PCS Secretariat or Staff Conduct

  1. Some grievances may involve alleged misconduct, bias, conflict of interest, breach of confidentiality, unprofessional behavior, or other violations of the PCS Code of Conduct by Secretariat personnel. The PCS Secretariat must uphold the highest standards of integrity, and grievances involving staff members are therefore handled with strict confidentiality and impartiality.

  2. These grievances may trigger internal investigations, disciplinary actions, or escalation to the PCS Regulatory Council if the allegations involve senior staff or decisions made at a high level. The procedure ensures that no individual or office is responsible for reviewing a grievance about its own conduct.

3.6 Grievances Concerning Project-Level Environmental or Social Harm

  1. One of the most important categories of grievances relates to potential environmental or social harm caused by project activities claiming certification under PCS. Such grievances may be raised by communities, local stakeholders, civil society organizations, or individuals affected by project operations.

  2. Concerns may involve land-use conflicts, human rights violations, negative impacts on biodiversity, livelihood disruptions, inequitable benefit sharing, or environmental degradation not adequately addressed by project safeguards. These grievances require careful assessment to determine whether PCS safeguard requirements have been breached and whether corrective actions, enforcement measures, or suspension of project activities may be warranted.

  1. Grievances may also arise concerning the assessment of environmental and social safeguards or SDG contributions associated with PCS projects. Stakeholders may challenge whether safeguard data was collected properly, whether risks were adequately mitigated, or whether SDG claims were overstated or unsupported by evidence. These grievances are considered important because safeguards and SDGs form a core pillar of PCS project integrity. The Secretariat evaluates such grievances by examining project documentation, validation findings, verification records, and the consistency of safeguard claims with PCS frameworks.

3.8 Grievances Concerning Registry Operations and PCU Issuance

  1. Certain grievances may relate to the operation of the PCS Registry, including errors in project listings, incorrect issuance of PCUs, delays in registry updates, or discrepancies in project documentation. Stakeholders may also raise concerns about potential double counting, data inaccuracies, or technical malfunction affecting registry entries. These grievances require close coordination between the grievance mechanism and PCS Registry administrators to ensure that any potential integrity risks are resolved promptly and transparently.

3.9 Grievances Concerning Fraud, Misrepresentation, or Misconduct

  1. PCS must retain the ability to address serious allegations of fraud, fabrication of data, misreporting, manipulation of monitoring information, or intentional deception by project developers, VVBs, or other participating entities. These grievances warrant immediate attention due to the risk they pose to environmental integrity and global market confidence. They may require escalation to independent investigators, forensic experts, or relevant national authorities. When grievances involve criminal conduct or legal violations, PCS cooperates with appropriate jurisdictions.

3.10 Grievances Outside PCS Jurisdiction

  1. Some grievances may concern matters outside the scope or authority of PCS. These include disputes between private parties, disagreements based solely on commercial terms, national permitting conflicts, or complaints that do not relate to PCS rules, decisions, or governance processes.

  2. When a grievance is deemed outside PCS jurisdiction, the PCS Secretariat informs the complainant and, where appropriate, may refer them to a more suitable mechanism or authority. Such grievances are documented for transparency but do not proceed to investigation.

3.11 Importance of Proper Categorization

  1. Accurate categorization of grievances ensures that each issue is handled through the appropriate channels, with the correct level of technical evaluation, procedural oversight, and escalation. It ensures that project-related concerns are distinguished from methodological, governance, or registry issues and that issues involving fraud or misconduct receive appropriate attention.

  2. Categorization also allows PCS to identify trends and recurring issues that may indicate systemic weaknesses. These insights inform future updates to PCS governance documents, methodological improvements, and capacity-building initiatives.

Chapter 4 - Submission Of Grievances

4.1 Purpose of the Submission Process

  1. The grievance submission process provides stakeholders with a formal, accessible, and transparent mechanism to raise concerns related to PCS governance, project activities, methodological issues, safeguard performance, registry operations, or the conduct of entities participating in PCS. This process ensures that all grievances are captured systematically, documented accurately, and routed to the appropriate investigative pathway. The procedure reinforces fairness and accountability by ensuring that grievances are evaluated on their merits, supported by evidence, and handled according to consistent institutional standards.

4.2 Accessibility of the Submission Mechanism

  1. The grievance submission mechanism must be accessible to all stakeholders without discrimination. The PCS Secretariat maintains multiple channels through which grievances may be submitted, including electronic submission through the PCS Registry, email submission to designated grievance addresses, and—in exceptional circumstances—paper submissions when digital access is limited. The mechanism is intentionally designed to be user-friendly so that individuals without technical backgrounds, including affected communities, can submit grievances without procedural barriers. Language accessibility may be supported through translated instructions or assistance provided through local partners.

4.3 Required Information for Submitting a Grievance

  1. To facilitate effective assessment, each grievance must include sufficient information for the PCS Secretariat to understand the nature, context, and urgency of the issue.

  2. The grievance must clearly describe the concern, identify the project, policy, decision, or entity involved, explain how the issue affects or may affect stakeholders, and provide any relevant evidence or documentation.

  3. The submission should also include the identity and contact information of the complainant unless anonymity is explicitly requested.

  4. When grievances are incomplete, the Secretariat may request additional information to enable a fair evaluation.

4.4 Anonymous Grievances

  1. Anonymous grievances may be accepted when the substance of the complaint is supported by credible evidence or when disclosing the identity of the complainant could expose them to personal risk.

  2. While anonymity may limit the Secretariat’s ability to seek clarifying information, PCS recognizes the need to protect complainants in sensitive cases, particularly when grievances relate to misconduct, retaliation, corruption, human rights issues, or community-level risks.

  3. Anonymous submissions are assessed with equal seriousness but may require more substantial evidence to compensate for the lack of direct engagement with the complainant.

4.5 Submission Timelines

  1. Grievances may be submitted at any time after the stakeholder becomes aware of the issue. PCS does not impose strict deadlines for grievances involving environmental or social harm, misconduct, fraud, or violations of PCS rules, as these issues may emerge gradually.

  2. However, grievances related to procedural errors or administrative matters should be submitted as soon as reasonably possible to facilitate timely resolution.

  3. Timely grievances help prevent escalation, reduce uncertainty, and support corrective actions before issues become systemic.

4.6 Acknowledgement of Receipt

  1. Once a grievance is submitted, the PCS Secretariat issues a written acknowledgement of receipt. This acknowledgement confirms that the grievance has been formally recorded, provides a unique case reference number, and outlines the next steps in the review process. The acknowledgement also informs the complainant about expected timelines for initial assessment and, where appropriate, requests additional information if needed to complete the initial review.

4.7 Initial Screening for Admissibility

  1. The PCS Secretariat conducts an initial screening to determine whether the grievance falls within PCS jurisdiction, whether it contains adequate information, and whether the matter should be addressed through the grievance mechanism or redirected to another PCS process. Screening ensures that grievances outside PCS authority, such as private contractual disputes or national permitting issues, are identified early.

  2. When a grievance is deemed inadmissible, the Secretariat informs the complainant with an explanation and, if possible, provides guidance on more appropriate avenues for redress.

4.8 Registration of Admissible Grievances

  1. Grievances deemed admissible are formally registered in the PCS Authorization Archive. Registration ensures traceability, enables systematic tracking, and preserves a complete documented record of all submissions and actions taken. Each registered grievance forms part of the PCS institutional memory and contributes to long-term governance assessment, risk identification, and learning across the PCS ecosystem.

4.9 Communication with the Complainant

  1. Effective communication with the complainant is essential for ensuring transparency, fairness, and trust in the grievance process. After a grievance is registered, the PCS Secretariat maintains communication with the complainant throughout the assessment and investigation stages, unless anonymity prevents direct interaction. Communication includes updates on progress, requests for additional evidence, clarifications, and notification of outcomes. All communication is documented and stored in the grievance file for auditability.

4.10 Protection Against Retaliation

  1. Any stakeholder submitting a grievance is entitled to protection from retaliation, discrimination, or adverse consequences resulting from their participation in the grievance mechanism.

  2. PCS strictly prohibits any action by project developers, VVBs, Secretariat staff, or any related party that seeks to punish or intimidate complainants. Allegations of retaliation are treated as separate and serious grievances requiring immediate attention and potential escalation. PCS may anonymize records, restrict disclosure, or take procedural measures to ensure complainant safety.

4.11 Responsibilities of the Complainant

  1. While PCS strives to make the submission mechanism accessible, complainants have certain responsibilities. They must provide information that is truthful to the best of their knowledge, supply relevant evidence when available, and respond to reasonable requests for additional information unless anonymity prevents direct contact.

  2. Complainants are not required to provide legal arguments or technical analysis; however, factual clarity helps ensure that grievances are assessed efficiently and fairly.

4.12 Importance of Proper Submission Procedures

  1. Proper submission procedures ensure that grievances are captured accurately and evaluated consistently across the PCS system. They create an orderly foundation for subsequent investigation, safeguard the rights of complainants, and support impartial review. The submission process also reinforces accountability by ensuring that grievances are documented from the outset and linked to subsequent assessments, investigations, decisions, and corrective actions.

Chapter 5 - Secretariat Handling And Assessment

5.1 Purpose of Secretariat Handling and Assessment

  1. The handling and assessment phase is the first formal stage of grievance processing following submission and registration. Its purpose is to ensure that grievances are evaluated systematically, impartially, and efficiently by the PCS Secretariat. This stage determines whether a grievance warrants a full investigation, whether immediate corrective action is required, and which institutional body or mechanism should lead the next steps. Proper handling and assessment maintain the integrity of the grievance system by ensuring that concerns are neither dismissed prematurely nor escalated unnecessarily.

5.2 Role of the PCS Secretariat in Grievance Administration

  1. The PCS Secretariat serves as the administrative focal point for grievance management. It is responsible for reviewing submissions, maintaining comprehensive records, coordinating communication with the complainant, conducting initial assessments, determining admissibility, and preparing recommendations regarding investigation and follow-up actions.

  2. Secretariat staff handling grievances must be trained in conflict resolution, impartial evaluation, and confidentiality requirements. They must also remain independent of any PCS processes, project activities, or decisions that may be related to the grievance to avoid conflicts of interest.

5.3 Initial Assessment of the Grievance

  1. Once a grievance has been registered, the PCS Secretariat conducts an initial assessment to understand the nature, scope, and seriousness of the concern. This assessment examines the complainant’s description, the parties involved, the potential impacts, the relevance to PCS rules or decisions, and any evidence provided.

  2. The Secretariat determines whether the issue relates to governance processes, project operations, safeguard violations, VVB conduct, or other categories defined in Chapter 3. Where necessary, the Secretariat may request additional information from the complainant or from relevant parties to ensure that the assessment is properly informed.

5.4 Determination of the Appropriate Handling Pathway

  1. Based on the initial assessment, the PCS Secretariat determines whether the grievance should be resolved directly through administrative action, referred for investigation, escalated to another PCS mechanism, or dismissed due to being outside PCS jurisdiction.

  2. Grievances involving procedural errors, minor administrative issues, or misunderstandings may be resolved quickly by clarifying rules or correcting documentation.

  3. Grievances involving potential harm, misconduct, fraud, or violations of PCS rules typically require full investigation.

  4. Grievances that relate specifically to methodology issues may be referred to the methodology governance process.

  5. All pathway decisions must be documented clearly and communicated to the complainant.

5.5 Assessment of Urgency and Severity

  1. The Secretariat evaluates whether the grievance involves urgent circumstances requiring immediate action. This assessment considers whether the grievance alleges ongoing environmental or social harm, violations of safeguard requirements, risks to community well-being, breaches of conduct by VVBs or Secretariat staff, fraud, or imminent threats to PCS integrity.

  2. Urgent grievances may require temporary suspension of project activities, expedited investigation, or emergency engagement with relevant parties. Cases without immediate harm proceed through the standard investigative timelines defined in subsequent chapters.

5.6 Engagement with Stakeholders for Preliminary Clarification

  1. During the assessment phase, the Secretariat may engage with relevant stakeholders to seek clarifications, verify factual claims, or obtain additional documentation. These stakeholders may include project developers, VVBs, Registry administrators, methodology proponents, or community representatives. All interactions are recorded in the grievance file to ensure transparency. Stakeholder engagement at this early stage is intended solely to clarify facts, not to resolve the grievance prematurely or influence the investigation before it formally begins.

5.7 Conflict-of-Interest Review

  1. Before proceeding further, the Secretariat conducts an internal conflict-of-interest review to determine whether any staff member handling the grievance has personal or professional ties to the parties involved. If a conflict is identified, the staff member must recuse themselves from the grievance process, and the case must be reassigned to another qualified personnel member. This ensures the integrity and impartiality of the grievance assessment.

5.8 Decision to Initiate an Investigation

  1. Upon completing the initial assessment, the Secretariat decides whether the grievance warrants a formal investigation. The decision is based on the seriousness of the allegations, the credibility of the evidence, the potential implications for PCS integrity, and the relevance to PCS rules or procedures.

  2. If an investigation is warranted, the Secretariat documents the rationale and develops an investigation plan that outlines the scope, responsibilities, timelines, and resources required. The complainant is informed of the decision, and relevant parties are notified as appropriate.

5.9 Administrative Resolution Without Investigation

  1. Certain grievances may be resolved administratively without requiring a formal investigation. Administrative resolution may apply when the grievance identifies correctable procedural issues, minor inconsistencies in documentation, misunderstandings about PCS rules, or simple data errors that can be addressed directly by the Secretariat. In these cases, the Secretariat informs the complainant of the corrective actions taken and documents the resolution in the grievance record. Administrative resolutions are still subject to recordkeeping requirements to ensure accountability.

5.10 Notification of Investigation or Closure

  1. After determining the next course of action, the PCS Secretariat provides formal notification to the complainant. If a full investigation will be conducted, the notification includes an outline of the anticipated process and indicative timelines.

  2. If the grievance is closed at the assessment stage for reasons such as lack of jurisdiction, insufficient evidence, or administrative resolution, the Secretariat provides an explanation detailing the grounds for closure. Transparency in communication ensures fairness and supports complainant trust in the PCS grievance system.

5.11 Documentation of the Assessment Stage

  1. Every step of the assessment process must be documented thoroughly in the grievance file, including the nature of the grievance, communications exchanged, evidence reviewed, assessment findings, conflict-of-interest evaluations, and the decision regarding investigation or closure. Documentation ensures the process is auditable, facilitates oversight by the PCS Regulatory Council, and supports future learning and systemic improvement.

5.12 Importance of Fair and Consistent Handling

  1. Fair and consistent handling of grievances during the assessment stage is essential to maintaining stakeholder confidence and ensuring the legitimacy of the entire grievance mechanism. Proper assessment prevents premature dismissal of valid grievances, ensures proportionate responses to serious issues, and supports the broader objective of maintaining environmental and social integrity across PCS activities. The Secretariat must therefore approach each grievance with impartiality, diligence, and respect for stakeholder rights.

Chapter 6 - Appeals Against Pcs Decisions

6.1 Purpose of the Appeals Process

  1. The appeals process provides stakeholders with a structured and fair mechanism to challenge decisions made by the PCS Secretariat or the PCS Regulatory Council that directly affect their rights, project status, accreditation standing, or methodology submissions. The purpose of this process is to ensure that PCS decisions are subject to independent review, that stakeholders have access to due process, and that errors or procedural irregularities can be corrected. The appeals mechanism reinforces transparency, trust, and accountability across all PCS governance functions.

6.2 Nature of Decisions Subject to Appeal

  1. An appeal may be submitted when a stakeholder disagrees with a formal decision made by PCS. Decisions subject to appeal include, but are not limited to, the rejection or conditional approval of a project registration, the denial or suspension of Planetary Carbon Unit issuance, the accreditation or suspension of a Validation and Verification Body, the approval or rejection of a methodology, the rejection of a clarification request, or the refusal to consider a revision.

  2. Appeals may also relate to Secretariat determinations regarding safeguard compliance, eligibility assessments, or procedural decisions that materially influence project or stakeholder status.

  3. Only decisions issued formally through PCS governance channels may be appealed; informal communications or advisory notes are not subject to appeal.

6.3 Stakeholders Eligible to Submit an Appeal

  1. The right to appeal is granted to any stakeholder directly affected by the decision in question. This includes project developers, VVBs, methodology proponents, host country authorities, and any institution or individual whose rights, obligations, or project status have been impacted by a PCS decision.

  2. Appeals must clearly demonstrate a substantive and direct connection to the decision being challenged.

  3. Third-party appeals, submitted by entities not directly impacted by the decision, are generally not accepted unless the appeal pertains to matters of procedural fairness or governance integrity.

6.4 Timeframe for Filing an Appeal

  1. Appeals must be submitted within a defined timeframe to ensure timely review and to maintain procedural certainty. Unless otherwise specified, appeals must be submitted within thirty days of receiving the formal decision notice.

  2. The PCS Secretariat may grant extensions in exceptional circumstances where the appellant can demonstrate reasonable cause for delay, such as lack of access to information, unforeseen disruptions, or serious operational constraints.

  3. However, appeals related to decisions made several months or years earlier are generally not accepted unless the appellant can show that the impact of the decision only became apparent at a later date.

6.5 Submission Requirements for Appeals

  1. An appeal must be submitted using the official PCS Appeal Submission Form and must include a clear description of the decision being challenged, the grounds for the appeal, supporting evidence or documentation, and the outcome sought. Appeals must present factual and procedural arguments rather than general dissatisfaction or disagreement.

  2. The appellant must demonstrate how the decision violates PCS rules, misapplies methodology requirements, incorporates factual or procedural errors, or fails to consider relevant evidence.

  3. Appeals lacking sufficient detail may be returned to the appellant for clarification before being admitted for review.

6.6 Grounds for Appeal

  1. Appeals may be based on several types of grounds. These include allegations that PCS misapplied a rule or requirement, failed to follow established procedures, overlooked critical information, relied on inaccurate data, or issued a decision inconsistent with PCS governing documents.

  2. Appeals may also contest decisions that appear arbitrary, discriminatory, or unsupported by technical evidence.

  3. Appeals cannot, however, be used to request exceptions to PCS rules or to challenge decisions that fall outside PCS jurisdiction.

6.7 Initial Screening of Appeal Submissions

  1. Upon receipt, the PCS Secretariat conducts an initial screening to determine whether the appeal is admissible. Screening verifies that the appeal was submitted within the prescribed timeframe, that the appellant has standing to appeal, and that the submission contains the required information. If the appeal is incomplete or unclear, the Secretariat may request additional information. Appeals found inadmissible are rejected with a written explanation. Appeals that pass screening proceed to full review.

6.8 Suspension of Decisions Pending Appeal

  1. The PCS Secretariat may suspend the enforcement of the challenged decision while the appeal is under review, if doing so is necessary to prevent undue harm or irreversible consequences.

  2. Suspension is not automatic; it is determined on a case-by-case basis based on the seriousness of the decision and the potential impact on the appellant or affected stakeholders.

  3. Where suspension is granted, the decision remains legally inactive until the appeal process is concluded.

6.9 Review of Appeals by the PCS Regulatory Council

  1. The PCS Regulatory Council is the final decision-making body for appeals. Upon acceptance of an appeal, the Secretariat prepares a comprehensive appeal dossier that includes the original decision, relevant records, appellant submissions, supporting evidence, and any internal assessments.

  2. The Regulatory Council reviews the dossier in detail, evaluates the appellant’s arguments, considers procedural and technical implications, and determines whether the original decision was appropriate.

  3. The Council may seek input from independent technical experts if the appeal concerns complex or highly specialized matters.

6.10 Standard of Review Applied by the Council

  1. The Regulatory Council assesses whether the original decision was made in accordance with PCS rules, supported by sufficient evidence, and free of procedural errors. The Council examines the decision-making process rather than replacing the Secretariat’s technical judgments unless those judgments were clearly flawed, demonstrably inconsistent with PCS requirements, or based on incomplete or inaccurate information. This approach ensures deference to technical expertise while maintaining robust oversight.

6.11 Possible Outcomes of an Appeal

  1. After completing its review, the Regulatory Council may uphold the original decision, modify the decision, overturn it entirely, or remand the matter back to the Secretariat for further analysis or procedural correction. The Council must justify its decision in a written document that explains the reasoning, technical considerations, and procedural basis for the outcome. Decisions of the Regulatory Council are final and binding within the PCS system.

6.12 Notification of Appeal Outcomes

  1. The PCS Secretariat informs the appellant of the outcome of the appeal and provides the written decision of the Regulatory Council. The notification outlines the basis for the decision and describes any follow-up actions required from the appellant, Secretariat, or other stakeholders. The decision must be communicated promptly to ensure procedural clarity and to allow ongoing PCS activities to proceed without unnecessary delay.

6.13 Documentation of Appeal Processes

All appeal-related documentation must be stored in the PCS Authorization Archive, including the appeal submission, communication records, evidence submitted, the Secretariat’s assessments, the Regulatory Council’s decision, and any related investigation materials. Documentation ensures transparency, supports future audits, informs systemic improvements, and provides a reliable record of how PCS governance decisions were reviewed and resolved.

6.14 Importance of the Appeal Process

The existence of a formal appeal mechanism reinforces the credibility of the Planetary Carbon Standard by ensuring that decisions can be re-examined objectively and that stakeholders can seek redress when they believe procedural fairness has not been upheld. By providing a structured pathway for review and correction, the appeals mechanism strengthens governance integrity, enhances trust in PCS, and improves decision-making quality across all levels of the system.

Chapter 7 - Investigation Process

7.1 Purpose of the Investigation Process

The investigation process ensures that grievances accepted for formal review are examined in a systematic, impartial, and evidence-based manner. Investigations provide the factual foundation required to determine whether violations of PCS rules, safeguards, ethical standards, or governance procedures have occurred. The purpose of this process is to ensure fairness for all parties, uphold the integrity of the PCS system, address potential harms, and identify any corrective or disciplinary actions needed to protect environmental or social integrity and maintain stakeholder trust.

7.2 Initiation of the Investigation

An investigation is initiated once the PCS Secretariat concludes that a grievance warrants in-depth review. The initiation includes defining the scope of the investigation, identifying relevant parties, outlining key issues to be examined, and determining the appropriate investigative methodology. The Secretariat informs the complainant and all relevant stakeholders that an investigation has commenced unless confidentiality requirements prevent disclosure. The initiation marks the transition from assessment to formal evidence gathering and analysis.

7.3 Appointment of Investigators

Investigations are conducted by qualified individuals or teams designated by the PCS Secretariat. Investigators must be impartial, technically competent, and free of actual or perceived conflicts of interest. Depending on the nature of the grievance, investigators may include PCS Secretariat staff, external technical experts, legal specialists, safeguard specialists, or independent investigators. When grievances involve potential misconduct by Secretariat personnel or members of the PCS Regulatory Council, an external investigator or independent body must be appointed to ensure objectivity and neutrality.

7.4 Scope and Terms of Reference for Investigations

Each investigation is guided by a formal Terms of Reference (ToR) that outlines the objectives, factual questions, methodology, evidence sources, timeline, and reporting requirements. The ToR ensures clarity, prevents scope creep, and enables consistent and transparent investigation processes. The ToR may include review of project documents, validation and verification reports, registry logs, communications records, public consultation feedback, monitoring data, or other relevant information. All investigations must remain within the scope defined by the ToR unless formally amended based on new findings.

7.5 Evidence Gathering and Verification

The core of any investigation is the collection and verification of evidence. Investigators review documentation submitted by complainants, project developers, VVBs, methodology proponents, or Secretariat staff. They may conduct interviews with stakeholders, request additional data, examine field-level information, or analyze digital MRV records where applicable. Evidence may include technical analyses, monitoring reports, emails, meeting minutes, geospatial data, witness statements, or photographic and video material. Investigators must verify the authenticity, reliability, and relevance of each piece of evidence before incorporating it into their findings.

7.6 Stakeholder Engagement During Investigation

Investigators may engage with stakeholders to clarify facts, validate claims, or understand contextual details. Engagement may include interviews, written inquiries, or meetings conducted virtually or in person. All interactions must be impartial, respectful, and carefully documented. Stakeholder engagement enables investigators to understand diverse perspectives, uncover additional evidence, and ensure that all materially affected parties have an opportunity to contribute relevant information. Engagement does not imply acceptance of claims but serves as an essential component of fact-finding.

7.7 Confidentiality and Information Protection

Investigations often involve sensitive information, including technical data, personal information, internal communications, or allegations of misconduct. Investigators must protect the confidentiality of all parties and ensure that sensitive information is not disclosed improperly. Information is shared only with those directly involved in the investigation or decision-making process. When necessary, investigators may anonymize statements or evidence to safeguard the identity of vulnerable individuals. Confidentiality builds trust in the grievance mechanism and protects complainants from retaliation.

7.8 Assessment of Findings and Analysis

Upon completion of evidence gathering, investigators conduct a structured assessment to determine whether the evidence supports or refutes the allegations. This analysis examines the internal consistency of evidence, corroborating details, discrepancies between accounts, procedural compliance, and alignment with PCS rules and safeguards. Investigators must provide a balanced and objective analysis, acknowledging uncertainties or limitations in the available evidence. They also assess the potential implications of findings for environmental integrity, social impacts, PCS governance processes, and stakeholder rights.

7.9 Preparation of the Investigation Report

Investigators prepare a comprehensive Investigation Report that summarizes the grievance, describes the investigative methodology, presents verified evidence, analyses findings, and provides clear conclusions. The report identifies whether violations of PCS rules, safeguards, or ethical standards occurred and recommends corrective, remedial, or disciplinary actions. Investigation Reports must be clear, factual, unbiased, and sufficiently detailed to support informed decision-making by the PCS Secretariat or PCS Regulatory Council. All reports are archived permanently in the PCS Authorization Archive.

7.10 Review of the Investigation Report by the PCS Secretariat

Upon receiving the Investigation Report, the PCS Secretariat reviews its findings for completeness, clarity, and alignment with procedural requirements. The Secretariat does not alter the investigator’s findings but ensures that the report addresses all components of the Terms of Reference. The Secretariat assesses whether the recommended actions are consistent with PCS policies and whether additional considerations are required before advancing the report to the PCS Regulatory Council or before implementing corrective measures.

7.11 Escalation to the PCS Regulatory Council

Investigations involving serious violations of PCS rules, ethical breaches, accreditation concerns, methodology integrity issues, or harm to communities or ecosystems are escalated to the PCS Regulatory Council. The Council reviews the Investigation Report, considers the recommendations, and determines the appropriate response. The Council’s decision may include corrective actions, sanctions, suspension of project activities, modification of methodologies, or updates to governance procedures.

7.12 Communication of Investigation Outcomes

The PCS Secretariat communicates the outcomes of investigations to the complainant and to relevant stakeholders. Communication includes an explanation of the findings, any corrective or disciplinary actions to be taken, and the rationale for decisions. When confidentiality constraints apply, the Secretariat provides a summary that respects privacy and legal requirements. Transparent communication reinforces trust in the grievance mechanism and ensures that stakeholders are aware of actions undertaken to address legitimate concerns.

7.13 Importance of Rigorous Investigation Processes

A rigorous investigation process upholds the credibility of the PCS system by ensuring that grievances are addressed based on verified evidence and impartial analysis. It protects the rights of stakeholders, supports environmental and social integrity, and enables PCS to identify and correct systemic weaknesses. Effective investigations strengthen confidence in PCS governance mechanisms and reinforce the commitment of PCS to fairness, transparency, and accountability.

Chapter 8 - Decision-Making And Resolution

8.1 Purpose of the Decision-Making Stage

The decision-making stage is the formal step at which the PCS Secretariat or the PCS Regulatory Council determines the outcome of a grievance or appeal based on the findings of the investigation. This stage ensures that all evidence has been fairly considered, that decisions align with PCS rules and principles, and that appropriate corrective actions are adopted. Decision-making and resolution play a critical role in reinforcing institutional integrity, maintaining stakeholder trust, and ensuring consistent application of PCS governance frameworks.

8.2 Responsibility for Decision-Making

Responsibility for issuing decisions depends on the nature and seriousness of the grievance or appeal. The PCS Secretariat is authorized to resolve grievances that involve administrative issues, procedural clarifications, minor errors, or matters that do not require disciplinary action. However, grievances involving significant violations of PCS rules, ethical breaches, environmental or social harm, VVB misconduct, or issues that materially affect project or methodology status must be escalated to the PCS Regulatory Council for final determination. Appeals must always be decided by the PCS Regulatory Council to maintain independence and impartiality.

8.3 Basis for Decision-Making

Decisions must be grounded in verified evidence and must reflect procedural fairness, transparency, and adherence to PCS principles. Decision-makers must rely on the Investigation Report, supporting documentation, testimonies, relevant PCS rules, methodology requirements, accreditation criteria, and applicable safeguard obligations. Decisions cannot be influenced by political, financial, or personal interests and must account for both the immediate grievance and broader implications for PCS governance. When evidence is inconclusive, decision-makers must adopt a precautionary approach that prioritizes environmental and social integrity.

8.4 Deliberation Process

The decision-making process involves internal deliberation either within the Secretariat or the PCS Regulatory Council. Deliberation may include discussions on evidence, the credibility of testimonies, applicable procedural rules, and potential implications for ongoing or future projects. Decision-makers may consult additional experts where specialized knowledge is required, provided that such consultations do not compromise impartiality. The deliberation process must be documented to ensure transparency and accountability, even if the details remain confidential due to sensitive information.

8.5 Determination of Outcomes

Decisions may result in a range of outcomes depending on the nature of the grievance or appeal. Possible outcomes include confirming that no violation occurred, identifying procedural errors that require correction, mandating corrective actions, issuing warnings, suspending project activities, revoking project registration, withholding or cancelling issuance of Planetary Carbon Units, requiring revalidation or reverification, mandating remedial safeguard measures, suspending or terminating VVB accreditation, or revising methodological guidance. Outcomes will always be proportionate to the seriousness of the issue and aligned with PCS governance principles.

8.6 Corrective and Preventive Actions

When a violation or procedural deficiency is identified, PCS may require corrective actions to address the issue immediately. Corrective actions may include updating project documentation, improving monitoring procedures, revising baseline calculations, conducting additional field assessments, or implementing community engagement measures. Where systemic issues are identified, PCS may also adopt preventive actions such as updating governance procedures, improving guidance documents, implementing capacity-building initiatives, or strengthening oversight. Corrective and preventive actions must be clearly documented and assigned reasonable timelines for completion.

8.7 Communication of Decisions to Stakeholders

Once a decision is finalized, the PCS Secretariat communicates the outcome to the complainant and to all relevant parties affected by the resolution. Communications include a written summary of the decision, the rationale behind it, and any required corrective actions or follow-up tasks. The communication must be clear, respectful, and appropriately detailed, taking into account confidentiality requirements. When confidentiality restrictions apply, a summarized version of the decision may be provided while protecting sensitive information.

8.8 Implementation and Monitoring of Decisions

Following the issuance of a decision, the PCS Secretariat oversees the implementation of corrective or disciplinary actions. Monitoring ensures that required actions are completed within stipulated timelines and that stakeholders adhere to remedial obligations. For serious grievances involving safeguard breaches, misconduct, or environmental harm, ongoing monitoring may continue until full compliance is achieved. Non-compliance with mandated corrective actions may result in additional sanctions, suspension of activities, or escalation to the PCS Regulatory Council.

8.9 Documentation and Archiving of Decisions

All decisions, including the underlying rationale, corrective actions, and implementation records, must be archived within the PCS Authorization Archive. This archive serves as the official institutional record and ensures full traceability for governance audits, external reviews, and historical reference. Documentation supports institutional learning, helps identify recurring issues, and ensures consistent decision-making across the PCS system. The archival process strengthens transparency and reinforces public confidence in the grievance and appeal mechanism.

8.10 Publication of Decisions (Where Applicable)

Certain decisions, particularly those involving systemic issues, significant governance improvements, or outcomes relevant to general stakeholders, may be published on the PCS Registry to promote transparency and enhance accountability. Publication may include redacted or summarized versions when confidentiality constraints exist. PCS balances transparency with the obligation to protect sensitive information, ensuring that the public is informed without compromising the privacy or security of involved parties.

8.11 Importance of Consistent Decision-Making

Consistent decision-making ensures fairness across all PCS stakeholders and prevents arbitrary or disproportionate responses to similar cases. By evaluating grievances and appeals using standardized principles and documented procedures, PCS maintains a governance environment that is predictable, transparent, and aligned with international best practices. This consistency supports long-term confidence in PCS governance processes and strengthens the credibility of Planetary Carbon Units issued under the standard.

Chapter 9 - Confidentiality And Protection Of Complainants

9.1 Purpose of Confidentiality Provisions

Confidentiality provisions are essential to maintaining the integrity, fairness, and accessibility of the PCS grievance and appeal mechanism. Many grievances involve sensitive information, potential risks to individuals or communities, or allegations that could result in retaliation if identities or details are disclosed prematurely. The purpose of this chapter is to ensure that all parties are treated with respect, that sensitive information is protected throughout the grievance process, and that complainants feel safe in raising concerns without fear of adverse consequences.

9.2 Protection of Complainant Identity

The identity of complainants must be protected at all stages of the grievance and investigation process unless the complainant explicitly consents to disclosure. Protection is especially important for individuals or community representatives who may be vulnerable to reprisals, intimidation, or discrimination. When grievances involve allegations against powerful entities, local authorities, or commercial actors, confidentiality becomes critical to preserving the safety of complainants and ensuring that grievances can be submitted without personal risk.

9.3 Confidentiality of Sensitive Information

Grievances may involve confidential business information, internal documentation, personal data, safeguard-related evidence, or sensitive community-level information. The PCS Secretariat must ensure that such information is handled exclusively by authorized personnel and used solely for grievance-related purposes. Confidential documents must not be shared outside the necessary review process, and all digital or physical records must be secured using appropriate access controls. Sensitive information must be excluded from any public disclosures, summaries, or reports unless anonymized or redacted.

9.4 Use of Anonymous Grievances

PCS allows the submission of anonymous grievances when revealing the complainant’s identity may pose personal, social, or legal risks. Anonymous grievances are evaluated based on the credibility and sufficiency of evidence presented. While anonymity may limit the Secretariat’s ability to seek clarifications or additional information, it still provides a vital channel for individuals unable to disclose their identity. The protection of anonymity must be upheld throughout the grievance process unless the complainant voluntarily withdraws anonymity.

9.5 Prevention of Retaliation and Intimidation

PCS has a strict non-retaliation policy to ensure that any person submitting a grievance or providing information during an investigation is protected from intimidation, threats, discrimination, or punitive measures. Retaliation includes any form of adverse action taken against a complainant, witness, or stakeholder because of their participation in the grievance mechanism. Allegations of retaliation are treated as separate and serious grievances requiring immediate assessment, potential interim measures, and expedited investigation. PCS reserves the right to impose sanctions or corrective actions on entities found responsible for retaliatory conduct.

9.6 Confidentiality Obligations of PCS Staff and Investigators

All PCS Secretariat staff, investigators, and external experts who access grievance-related information must adhere to strict confidentiality obligations. They must avoid discussing grievance details outside authorized channels and must refrain from using confidential information for purposes unrelated to the grievance process. Breach of confidentiality by PCS personnel constitutes misconduct and may result in disciplinary action. This obligation ensures trust in the grievance mechanism and prevents misuse of sensitive information.

9.7 Secure Handling and Storage of Grievance Records

All grievance documents—including submissions, evidence, communications, Investigation Reports, and decisions—must be stored securely within the PCS Authorization Archive. Access to these records is restricted to designated Secretariat staff and members of the PCS Regulatory Council when necessary for decision-making. Digital records must be stored in secure systems with encryption and controlled access rights. Physical records, if any, must be stored in locked and monitored storage environments. Record retention complies with PCS data protection standards and international best practices.

9.8 Protection During Stakeholder Engagement

During investigations, investigators may need to engage with complainants, witnesses, project developers, VVBs, or community groups. All stakeholder interactions must be designed to minimize risks to participants. Investigators must avoid revealing the identity of complainants unless strictly necessary and approved by the complainant. When interacting with local communities or vulnerable groups, investigators must follow culturally appropriate practices, ensure informed consent, and avoid exposing individuals to unintended consequences.

9.9 Disclosure Restrictions in Public Reports and Summaries

PCS may publish summaries of grievances or decisions to promote transparency and improve understanding of governance processes. However, public disclosures must be carefully prepared to exclude identifying details or sensitive information. Summaries must use anonymized descriptions, generalized terms, or redacted content when necessary. PCS prioritizes transparency but does not compromise the confidentiality of complainants, witnesses, or individuals implicated in ongoing investigations.

9.10 Handling Requests for Information

Stakeholders may request access to grievance-related information for legitimate purposes, such as verification or audit activities. Such requests are evaluated carefully by the PCS Secretariat. Access may be granted only when it does not violate confidentiality obligations, compromise investigations, or expose individuals to risks. When possible, PCS provides redacted or summary versions of documents rather than full disclosure. The Secretariat must balance transparency with the duty to protect sensitive information.

9.11 Obligations of External Parties

External parties involved in grievance processes, such as VVBs, project developers, or subcontractors, must respect confidentiality requirements and refrain from unauthorized disclosure of grievance-related information. PCS may require written confidentiality agreements from external investigators or consultants to ensure compliance. Breach of confidentiality by external parties may result in sanctions, loss of accreditation, or referral to relevant authorities.

9.12 Importance of Confidentiality in Ensuring Effective Grievance Mechanisms

Confidentiality plays a central role in building trust in the grievance system. Stakeholders must have confidence that grievances will be handled discreetly, that their identity will be protected, and that they will not face adverse consequences for raising concerns. Without robust confidentiality provisions, individuals may hesitate to report violations, which undermines PCS integrity, weakens safeguard protections, and compromises transparent governance. Ensuring confidentiality fosters an environment in which stakeholders can safely participate and hold the PCS system accountable.

Chapter 10 - Publication Of Grievance Outcomes

10.1 Purpose of Publishing Grievance Outcomes

The publication of grievance outcomes is an important transparency mechanism that supports stakeholder confidence in the Planetary Carbon Standard. Publishing outcomes—when appropriate—demonstrates that grievances and appeals are taken seriously, processed consistently, and resolved in accordance with PCS principles. Publication also contributes to broader learning within the PCS ecosystem by highlighting systemic issues, clarifying governance expectations, and promoting improved practices among project developers, Validation and Verification Bodies, and other participants.

10.2 Principles Governing Disclosure

Publication of grievance outcomes must balance transparency with confidentiality. PCS is committed to disclosing information that improves understanding of governance processes without compromising the privacy, safety, or rights of complainants or involved parties. Disclosure must therefore be selective, respectful, and aligned with the confidentiality provisions described in Chapter 9. Only information suitable for public release is published, and sensitive details are redacted as necessary.

10.3 Types of Information Eligible for Publication

PCS may publish summaries of grievances, investigation findings, and final decisions that have broader relevance to governance integrity or systemic improvement. Published content may include the nature of the grievance, a high-level summary of findings, corrective or preventive actions undertaken, and the final determination. Details that reveal identities, sensitive personal information, confidential business data, or information that may compromise ongoing projects or investigations are excluded. Publication focuses on issues with systemic implications, lessons learned, or relevance to the PCS community.

10.4 Situations Where Publication Is Required

Publication is required when the grievance or appeal outcome results in significant governance actions or when the associated risk or issue has implications for the broader PCS system. These situations include sanctions against project developers or VVBs, suspension or revocation of accreditation, modification or withdrawal of methodologies, suspension of project registration, or changes to major procedural rules. Publication in such cases ensures that stakeholders are informed of actions taken to protect environmental and social integrity.

10.5 Situations Where Publication Is Not Appropriate

Some grievances involve highly sensitive issues, personal risks, or confidential material that cannot be disclosed publicly. These may include grievances submitted anonymously, allegations involving personal misconduct, sensitive community-level information, or matters linked to ongoing legal processes. In such cases, publication is not appropriate and may cause harm or compromise investigations. PCS may issue generalized statements or high-level reports without disclosing specifics to maintain transparency while protecting confidentiality.

10.6 Format and Content of Public Summaries

When grievance outcomes are published, PCS uses a standardized format to ensure clarity, consistency, and accessibility. Public summaries include a neutral description of the issue, a non-technical explanation of the review or investigation process, the nature of the findings, actions taken, and any follow-up measures required. Summaries must be written clearly, using non-judgmental language that reflects factual information without assigning blame beyond the formal decision. The level of detail is determined based on relevance, confidentiality needs, and potential implications for the PCS community.

10.7 Publication Through the PCS Registry

All public grievance outcomes are published on the PCS Registry, which serves as the central platform for PCS transparency. Published outcomes are accessible under a designated governance section, allowing stakeholders to browse decisions, review summaries, and understand how PCS resolves disputes. The Registry provides long-term access to these summaries, ensuring traceability and supporting external oversight. When necessary, archived versions of summaries are retained for reference while newer versions reflect updated governance decisions or corrective actions.

10.8 Notification of Affected Parties

Before publishing any grievance outcome, PCS notifies the complainant and the parties involved in the grievance or investigation. Notification provides transparency, gives affected parties an opportunity to prepare for publication, and ensures that no confidential information is disclosed inadvertently. If affected parties identify concerns about the release of sensitive information, these concerns are evaluated and addressed before publication proceeds.

10.9 Publication of Appeals Decisions

Decisions on appeals—including those upholding, modifying, or overturning earlier PCS decisions—are particularly important for transparency and governance quality. PCS therefore publishes summarized versions of all appeal outcomes unless confidentiality restrictions apply. Appeal summaries help stakeholders understand the evolution of decisions, the rationale underlying governance outcomes, and the role of the PCS Regulatory Council in safeguarding integrity.

10.10 Annual Reporting of Grievances and Appeals

PCS may prepare an annual public report summarizing the number and types of grievances and appeals received during the year, key themes emerging from grievance mechanisms, actions taken, and planned improvements to governance processes. This annual report strengthens institutional learning, highlights recurring issues, and demonstrates commitment to continuous improvement. The report does not include identifying information or sensitive grievance details.

10.11 Importance of Transparent Publication Practices

Transparent publication practices help to reinforce PCS’s credibility as a trustworthy climate standard committed to environmental integrity, social responsibility, and accountable governance. By providing structured and meaningful public disclosures, PCS ensures that stakeholders understand how grievances and appeals are handled, which decisions have been taken to address systemic issues, and how PCS continually improves its governance frameworks. Publication also contributes to market confidence, enabling buyers, host countries, and project proponents to trust the PCS system.

Chapter 11 - Final Provisions

11.1 Purpose of the Final Provisions

The final provisions establish the legal, administrative, and implementation rules governing this Grievance and Appeal Procedure. They ensure that the mechanism is applied consistently, remains aligned with PCS governance principles, and evolves appropriately as the PCS system develops.

11.2 Governing Authority

This procedure is issued under the authority of the PCS Regulatory Council, which is responsible for approving, interpreting, and amending the provisions contained herein. The PCS Regulatory Council serves as the final decision-making body for all appeals and for grievances escalated beyond the Secretariat’s remit.

11.3 Role of the PCS Secretariat

The PCS Secretariat is responsible for administering all aspects of the grievance and appeal mechanism, including the intake, screening, assessment, investigation coordination, communication with stakeholders, and recordkeeping. The Secretariat ensures impartiality, confidentiality, and adherence to procedural timelines.

11.4 Relationship with Other PCS Governance Documents

This procedure must be applied in conjunction with other PCS governance documents, including the PCS Framework v2.0, PCS Operational Manual, PCS Methodology Governance Procedure, PCS VVB Accreditation Procedure, and PCS Safeguard and SDG frameworks. In the event of conflicting provisions, the PCS Regulatory Council determines the prevailing interpretation.

11.5 Version Control and Effective Date

Each version of this procedure must include a unique version number, an effective date, and a summary of changes. Only the version published on the PCS Registry is authoritative. This version—PCS Grievance and Appeal Procedure v2.0—enters into force on the date approved by the PCS Regulatory Council.

11.6 Amendments to the Procedure

Only the PCS Regulatory Council may amend or update this procedure. Amendments may arise from systemic findings, investigation results, stakeholder feedback, or new international requirements. Amendments must be published on the PCS Registry and accompanied by transitional guidelines when applicable.

11.7 Transitional Arrangements

When updates occur, the PCS Secretariat establishes clear transitional arrangements to ensure fair implementation. Transitional rules may specify how ongoing grievances or appeals are handled, deadlines for compliance with new requirements, and the continued validity of prior provisions during the transition.

11.8 Binding Nature of Decisions

All decisions rendered under this procedure by either the PCS Secretariat or the PCS Regulatory Council are final and binding within the PCS system. Stakeholders must comply with required corrective actions, sanctions, or procedural outcomes. Failure to comply may result in further administrative actions or sanctions.

11.9 Confidentiality Obligations

All parties participating in grievance or appeal processes must adhere to confidentiality requirements described in Chapter 9. Confidentiality obligations apply to PCS staff, external investigators, complainants, appellants, VVBs, and project entities.

11.10 Data Retention and Archiving

All grievance and appeal records—including submissions, evidence, communication logs, investigation materials, and decisions—must be stored permanently in the PCS Authorization Archive. Records support transparency, allow future audits, and maintain historical reference to governance decisions.

11.11 Official Language

The official language of this procedure is English. Translations may be made available for stakeholder convenience, but the English version governs in all matters of interpretation.

The PCS grievance and appeal mechanism is administrative in nature. It does not supersede national legal systems, adjudicate private contractual disputes, or replace judicial processes. Stakeholders retain the right to seek remedies through applicable legal channels outside PCS.

11.13 Entry into Force

This procedure enters into force on the date of its approval by the PCS Regulatory Council. It applies to all grievances and appeals submitted on or after that date. Ongoing cases are handled according to transitional arrangements established by the Secretariat.

11.14 Importance of the Procedure in PCS Governance

This procedure is fundamental to ensuring fairness, transparency, accountability, and continuous improvement within the Planetary Carbon Standard. It strengthens protections for stakeholders, reinforces environmental and social integrity, and ensures that PCS remains a trusted and credible standard within global carbon markets.

Annex A - Grievance Submission Form

A.1 Purpose of the Form

This form provides stakeholders with a standardized template to submit grievances to the Planetary Carbon Standard. It ensures consistent and complete information for effective assessment, investigation, and resolution.

Table A-1: PCS Grievance Submission Form

Section
Information Required

1. Grievance Reference Number

(Assigned by PCS Secretariat upon receipt)

2. Date of Submission

Date the grievance is formally submitted.

3. Complainant Information

Full name, organization (if applicable), email, phone, mailing address. Indicate if anonymity is requested.

4. Relationship to PCS Activities

Description of the complainant’s connection to the project, VVB, methodology, or governance process.

5. Description of the Grievance

Detailed account of events, nature of the issue, people involved, project or process affected, location, and timeline.

6. Relevant PCS Rules or Procedures

Identify PCS rules, safeguards, methodological provisions, or governance requirements believed to have been violated.

7. Evidence or Supporting Information

List and description of documents, data, photos, correspondence, or other material submitted as evidence. Attach separately.

8. Impact of the Issue

Explanation of environmental, social, procedural, or governance impacts caused or expected.

9. Previous Actions Taken

Description of any actions taken by the complainant or involved parties to address or resolve the issue prior to contacting PCS.

10. Requested Resolution

Summary of what the complainant is requesting (e.g., corrective action, policy clarification, investigation).

11. Confidentiality Request

Indicate whether all or part of the submission should remain confidential. Provide justification if needed.

12. Declaration

Signed statement certifying the accuracy of information provided.

13. Secretariat Use Only

Registration date, assigned case manager, classification of grievance, screening decision, next steps.

Annex B - Appeals Submission Form

B.1 Purpose of the Form

This form provides stakeholders with a standardized mechanism to submit formal appeals against decisions issued by the PCS Secretariat or the PCS Regulatory Council. The Appeals Submission Form ensures that all appeals include sufficient and relevant information to support a fair, transparent, and efficient review by the PCS Regulatory Council.

Table B-1: PCS Appeal Submission Form

Section
Information Required

1. Appeal Reference Number

(Assigned by PCS Secretariat upon receipt)

2. Date of Submission

Date the appeal is submitted.

3. Appellant Information

Full name, organization (if applicable), contact information (email, phone, address). The appellant must identify themselves unless exceptional anonymity is required and justified.

4. Decision Being Appealed

Description of the PCS decision being challenged. Include decision date, reference number, and the issuing body (Secretariat or Regulatory Council). Attach a copy of the decision letter if available.

5. Standing to Appeal

Explanation of how the decision directly affects the appellant’s rights, project status, methodology submission, accreditation standing, or legitimate interests.

6. Grounds for Appeal

Detailed explanation of why the appellant believes the decision is incorrect. Grounds may include procedural errors, misapplication of PCS rules, incorrect interpretation of evidence, bias, or inconsistency with governing documents.

7. Supporting Evidence

List and description of supporting documentation, including reports, correspondence, technical analyses, legal references, or factual records. Attach separate files as needed.

8. Summary of Key Arguments

Clear, structured summary of the main arguments supporting the appeal. This section highlights the core reasons the decision should be reconsidered.

9. Requested Remedy or Outcome

Description of the corrective action or outcome sought by the appellant (e.g., reversal of decision, reconsideration, procedural review).

10. Confidentiality Requests

Indicate whether any submitted information should remain confidential and provide justification for confidentiality.

11. Declaration of Accuracy

Statement confirming that all information and evidence provided are accurate and complete to the best of the appellant’s knowledge. Signature required.

12. PCS Secretariat Use Only

Screening outcome, date accepted, assigned reviewer(s), escalation notes, decision timeline.

Annex C - Document Control

C.1 Purpose of the Document Control Annex

This annex establishes the rules for version management, updates, and archival of the PCS Grievance and Appeal Procedure. Document control ensures that stakeholders always reference the correct version and that all historical versions remain available for audit and institutional memory.

Table C-1: Version History and Document Control

Version Number
Effective Date
Summary of Changes
Approved By

v2.0 (2025 Edition)

[Insert Approval Date]

Initial release of the PCS Grievance and Appeal Procedure, including Chapters 1–11 and Annexes A–C.

PCS Regulatory Council

v2.1

Reserved

Reserved for future amendments, procedural refinements, or updates based on systemic findings.

PCS Regulatory Council

v2.2

Reserved

Reserved for minor editorial clarifications or administrative updates.

PCS Regulatory Council

C.2 Archival Requirements

All superseded versions of this procedure must be stored permanently within the PCS Authorization Archive. The archive must retain:

  • The full text of each historical version

  • Approval records

  • Change summaries

  • Digital signatures or blockchain hashes (if applicable)

  • Any transition guidance associated with the version

Historical versions must remain accessible for governance audits, dispute resolution, and retrospective analysis.

C.3 Publication and Distribution

The current approved version of this procedure must be published through the PCS Registry. Only the version displayed on the Registry is considered authoritative. The PCS Secretariat is responsible for distributing updates to:

  • Accredited and provisional VVBs

  • Project Developers

  • Host Country Authorities

  • Methodology Proponents

  • Registered stakeholders

Publication must occur promptly after approval by the PCS Regulatory Council.

C.4 Control of Physical and Digital Copies

Printed or downloaded copies of this procedure are considered “uncontrolled” documents and may become outdated. Stakeholders must always consult the PCS Registry to confirm that they are using the most recent version. Digital systems used by PCS must embed the current version number for reference across MRV and registry processes.