SINE Strategy Wiki

The Carbon Accounting Landscape Review (ICC, 2026)

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Full title: “The Carbon Accounting Landscape Review — Foundations for a ledger-based carbon accounting framework that provides product-level data”, August 2026. Prepared by the Secretariat of the Technical Expert Panel on Carbon Accounting, published by the Carbon Measures.

A primary source: an independent landscape and gap analysis, published openly, written to serve as “a foundational resource for the Panel’s future work and deliberations”. The Secretariat states expressly that it is not the Panel’s final view.

Why it was ingested

Martin Pompéry, 2026-08-17. This is the first source in the wiki that assesses PACT from the outside — by a body with standard-setting ambitions of its own, against a target architecture PACT was not built for. Everything the wiki previously held on PACT came from PACT’s own publications or from SINE’s whitepapers, where PACT appears as the flagship success case.

What the document covers

Seven sections plus two appendices, in five declared steps:

  1. Section 2 — a map of the carbon-data ecosystem in nine functional clusters (primary-data providers, secondary-data providers, voluntary carbon-credit systems, accounting standards and frameworks, systems/ERP, verification/audit/assurance, disclosure initiatives and certifications, corporate target-setting, policy and regulation), and where accounting frameworks sit within it. Introduces the study’s organising distinction → carbon counting vs. carbon accounting.
  2. Section 3 — the three regulatory regimes that create product-level demand: EU CBAM, California LCFS, China’s CFMS, plus Australia’s Safeguard Mechanism as a facility-level contrast case → product-level carbon regulation.
  3. Section 4 — eight criteria for a framework producing decision-grade product-level data, distilled from eight existing criteria sets → the eight decision-grade criteria.
  4. Section 5 — six product-level approaches assessed criterion by criterion: GHG Protocol Product Standard, ISO 14067, PACT v3.0, E-Ledgers / E-liability, EU PEF, ISCC CFC. Plus §5.4 on the entity-level baseline (GHGP Corporate Standard) and the “comprehensive-ledger family” (E-Ledgers, EFI Foundation, CASI).
  5. Section 6 — findings, split into what the landscape already provides (§6.1) and what is missing, separated into quantification gaps (§6.2) and accounting-architecture gaps (§6.3).

Appendix A extends the short-list to twelve regimes; Appendix B is a glossary (allocation, chain of custody, E-liability/E-asset, embedded emissions, mass balance, PCR, …).

The premise, stated openly

The review does not pretend to neutrality, and says so on page 3:

“The initiative behind this effort was established on the premise that a ledger-based approach to carbon accounting is a critical tool for enabling emissions reduction while supporting economic growth and development. […] This review therefore does not evaluate whether existing frameworks qualify as meeting this very specific objective; they were not designed to be and they serve other important purposes. […] It asks what each contributes to such a ledger-based architecture, and what remains open.”

Every “open item” in the document is therefore distance from a chosen target architecture, not a defect. This qualification matters for reading the PACT assessment below and is repeated by the Secretariat at least four times.

Key substantive content (detailed in dedicated pages)

The three findings that bear on SINE

⟨Inference: the selection is mine; the quotations are the source’s.⟩

1. PACT is credited with the exchange layer and denied the accounting layer. Table 4 (p. 32) gives PACT v3 “Working, data-exchange infrastructure; a fixed cradle-to-gate default boundary and common exchange format; the Primary Data Share metric and maturity pathway” — and lists as open:

“Exchanges data rather than accountable quantities; period-average static figures rather than transaction-level records; does not provide conservation, transfer, or reconciliation mechanisms; inherits the quantification latitude of its methodological basis.”

§6.1 repeats the credit (“PACT demonstrates that interoperable, supplier-specific product carbon data can be exchanged across multi-tier supply chains at scale, with verification — a practical answer to the systems-layer problem identified in Section 2”), and §5.3 the boundary: “What none of these layers was designed to provide […] is the accounting architecture.” Appendix A puts it flatly: “no verification emissions transfer as accountable quantities.”

2. Confidentiality is named as a design requirement in Criterion B and then disappears. The one place the review states the problem SINE’s technical line exists to solve (§4.2 B, p. 21):

“Confidentiality and access control are part of verifiability’s design. Because product-level embedded emissions can reveal energy intensity, process efficiency, and cost structure, the system must allow authorised parties to verify the number while limiting unnecessary disclosure of underlying operational data — through permissioned access, aggregation, and data minimisation.”

It is not carried into Table 3 (criteria → regulatory demand), not into the Table 4 assessments, and not into either list of missing elements in §6.2 or §6.3. The review poses the requirement and does not treat its absence as a gap. See The confidentiality gap in ledger-based carbon accounting for the argument that this is the largest unclaimed space in the document.

3. Allocation is framed as market design, not method. §6.2, p. 34:

“Allocation is not merely a methodological detail. It influences how emissions are assigned to products, and therefore which products receive a commercial, regulatory, or reputational advantage.”

and, on the same page, methodology arbitrage:

“Where standards permit multiple allocation approaches for the same multi-output process, companies may be rewarded for selecting favourable calculation methods rather than improving underlying operations. […] reported PCFs can shift emissions among outputs without any change in real carbon performance.”

The proposed test for decision-grade comparability: “whether two practitioners using the same operational data for the same process would produce materially the same result.”

The self-diagnosis worth noting

§4.1 lists eight existing criteria sets (IPCC, GHG Protocol, ISO 14067, PACT, FASB, IFRS S1, ESRS, E-Ledgers proto-standard, plus EFI’s ledger principles) and opens with: “There is more agreement in the field than the plurality of frameworks suggests.” Eight overlapping principle lists, substantial agreement, no common architecture — the review does not name this as a coordination failure, but it is one. ⟨Inference: mine, per coordination vs. bargaining failure.⟩

Omissions (explicitly flagged)

Not transcribed in depth: §5.2’s full criterion-by-criterion prose (its conclusions are captured in Table 4 and on the concept pages), the Sources and references list, and Appendix B’s glossary (used for definitions, not reproduced). Appendix A’s twelve-regime table is summarised rather than transcribed.

The review’s own stated limits: it is a qualitative review resting on documentary analysis, not quantitative testing; it is a point-in-time assessment as of August 2026; and it is explicitly not the Panel’s final view.

Cross-references

Sources

  • sources/whitepapers/2026-08-17-icc-carbon-accounting-landscape-review.pdf — the immutable original.
  • sources/whitepapers/2026-08-17-icc-carbon-accounting-landscape-review/2026-08-17-icc-carbon-accounting-landscape-review.md — the Markdown twin this page cites against (conversion supplied by Martin Pompéry; see wiki/log.md).
  • sources/whitepapers/2026-08-17-icc-carbon-accounting-landscape-review/tables-recovered-from-pdf.md — Tables 1b, 2, 3 and 4 re-extracted natively from the PDF, because both Marker conversions collapsed their columns. A transcription aid, not a separate source.

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