# Working as a VVB on the OCP

## **Application Requirements, including Accreditation**

All VVBs are required to be accredited under an international standard such as:

* accreditation under **ISO 14065** by an **International Accreditation Forum (IAF) member**
* accreditation under the **UNFCCC Kyoto Protocol Clean Development Mechanism**, or the **Paris Agreement Article 6, paragraph 4 Supervisory Body**
* **ISAE3000**, on the condition that the VVB must nominate a named GHG subject-matter lead on each engagement and produce a report addressing all OCP Validation scope elements, regardless of ISAE 3000 form limitations on opinion expression.

Accreditation status is checked upon registration by the OCP, and is publicly available on the List of Active VVB Partners.

In addition to accreditation, every VVB must have experience and competence in both GHG accounting and the relevant sector. The minimum requirements for demonstrating experience and competence include:

* **Expertise in the OCP Registry and OCP methodologies**, including relevant sub-documents. This is taught and assessed in the OCP VVB Onboarding and OCP VVB Training processes. Both must be completed before any Validation or Verification work can begin.
* **Experience using GHG accounting frameworks** (such as the GHG Protocol), demonstrated by examples of previous work.
* **Experience working in the relevant sector**, demonstrated by examples of previous work, or by the relevant ISO sector accreditation.
* **Multiple team members working on validation/verification** - a validator/verifier who performs the assessment, and a separate team leader, who monitors and reviews the process and output.

Finally, all VVB must be legal organizations and have professional indemnity insurance. Sole traders and individuals may not be approved as VVB on the OCP. This requirement ensures that (a) appropriate liability can be attributed; (b) KYB and AML checks can be performed on the organization; and (c) professional indemnity insurance obligations can be verified.

### **New Accreditations**

When an organization applies to be a VVB under an accreditation standard not listed above, the OCP conducts a formal Functional Equivalence Assessment prior to approval.

The assessment evaluates whether the alternative standard provides requirements functionally equivalent to ISO 14065 across four domains:

* **Competence:** does the standard set minimum personnel competence criteria equivalent to ISO 14065/14066 for GHG validation and verification?
* **Independence**: does the standard impose independence requirements equivalent to ISO 14065, including conflict of interest prohibitions and disclosure obligations?
* **Scope**: does the accreditation cover GHG validation and verification activities, or activities directly analogous to GHG project assurance?
* **Decision authority:** does the standard require an independent review of validation conclusions before a report is issued?

The assessment is conducted by the OCP Chief Product Officer, Rio Richardson, and approved by the OCP Advisory Board.

This assessment was conducted for the **CSAE 4400 approach under the ISAE 3000** accreditation held by EY.

<table><thead><tr><th width="257.7578125">ISO 14065 expectation</th><th>How addressed under CSAE 4400 approach</th></tr></thead><tbody><tr><td>GHG-specific technical competence</td><td>Engagement teams include personnel with demonstrated experience in greenhouse gas accounting, carbon project methodologies, and ISO 14064-series standards. Subject-matter experts are involved where specialized technical judgement is required, consistent with competence requirements for environmental validation and verification activities.</td></tr><tr><td>Methodology understanding</td><td>Agreed-upon procedures are designed and performed against GHG-specific criteria, including applicable project methodologies, calculation approaches, and defined reporting frameworks. Procedures are tailored to the nature of the GHG claim, while avoiding the expression of any assurance conclusion, in line with CSAE 4400.</td></tr><tr><td>Impartiality</td><td>Independence and ethical requirements under the IESBA Code of Ethics apply at both the firm and engagement levels. Threats to impartiality are identified, evaluated, and mitigated through documented safeguards consistent with ISO 14065 principles and CSAE 4400 requirements</td></tr><tr><td>Separation from consultancy</td><td>Firm policies prohibit the provision of advisory or consultancy services relating to the same GHG claims or projects that are subject to agreed-upon procedures. This separation mitigates self-review and advocacy threats and aligns with ISO 14065 expectations regarding objectivity and conflict management.</td></tr><tr><td>Review and decision independence</td><td>Each carbon project is subject to robust quality review procedures performed by individuals independent of the engagement team responsible for executing the agreed-upon procedures. Review and sign-off responsibilities are segregated to reinforce objectivity and support compliance with ISO 14065 impartiality principles.</td></tr></tbody></table>

## **Onboarding & Training**

Every VVB has to complete the 5 step onboarding process before they are approved to work on validation or verification work on the OCP.

**Step 1: Application**

* Organization must complete the VVB Application Form, which requires organizational details, current accreditations and sector expertise, evidence of technical competence, information and expertise of team members performing validation/verification work, internal COI policy, and evidence of professional indemnity insurance.
  * As part of this application form, they must also attest to: Follow all OCP rules and governance, including the COI policy and procedures; participate in the Annual Audit; and work with the OCP in the case in any complaints and grievances.

**Step 2: Due Diligence**

* The OCP team, led by Rio Richardson (CPO) conducts the following due diligence checks within 10 business days of receiving a complete application:
  * **Accreditation Verification**: cross-check accreditation scope and expiry date against the relevant database. Verified scope must explicitly cover GHG validation/verification in relevant sector.
  * **KYB (Know Your Business)**: confirm legal entity status, beneficial ownership, and jurisdiction of incorporation ([more detail](https://open-carbon-protocol.gitbook.io/ocp-handbook/governance/kyb-anti-money-laundering-and-anti-bribery-and-corruption-policy)).
  * **COI Screening**: Reviews COI attestation and list of relevant team members against current OCP senior team, advisory board and current project developers. Conflicts that cannot be managed through recusal result in inability to work in a specific project sector, or a blanket rejection if structural.
  * **Technical Competence Review**: Review prior engagement list and key personnel CVs against methodology types and sectors for which approval is sought. Assess whether experience is relevant, recent (within 5 years), and at sufficient scale.
  * **ABC Policy Review**: Confirm organization maintains an anti-bribery and corruption policy consistent with OCP requirements. If no internal policy, confirm acceptance of OCP ABC Policy as binding.

**Step 3: Approval Decision**

* If due diligence is satisfactory, the OCP issues written approval notice to the organization via email, specifying:
  * Approved VVB status on OCP;
  * Accreditation standard(s) confirmed;
  * Approved scope of activity types and geographies;
  * Any conditions or limitations on the approval;
  * Date of next annual review.
* The organization is then added to the publicly available List of Active VVB Partners at [ocp.earth/validators](http://ocp.earth/validators).
* If the due diligence raises concerns, the organization is notified via email with specific grounds for refusal or conditions for re-application.

**Step 4: Platform Onboarding**

* Upon approval, the VVB will receive an invitation to complete OCP Account Sign-Up
* They can optionally watch demo videos or schedule time with the OCP team to walkthrough navigation, validation/verification tools, methodology and project review.

**Step 5: Training**

* After onboarding, all new VVBs must complete OCP VVB Training before validating a project. As of April 2026, this training takes place on a training platform and completion of the training is recorded digitally. Before April 2026, training took place over video conference with a member of the OCP team.
* The training covers 7 modules:
  1. OCP Rules and Governance
  2. Conflict of Interest, Independence, and ABC Obligations
  3. OCP Methodology Requirements and current Approved Methodologies
  4. SDG, Safeguards and Co-Benefits
  5. Project Validation scope, minimum requirements and output
  6. Data Verification scope, minimum requirements and output
  7. Platform use and documentation

## Selection of VVB for Project Validation and Data Verification

The OCP team works with Project Developers to approve an appropriate VVB for the specific project based on:

* Sector expertise,
* Accreditation status,
* Geography and capacity,
* Potential conflicts of interest,
* Data verification scope.

For any single project, the same VVB can perform Project Validation and on-going Data Verification if the PD has selected the ‘Per Issuance’ verification pathway. The OCP will perform a separate verification audit using a unrelated VVB after every 5 years within a crediting period. If the verification audit identifies any issues with the current PD + VVB partnership, a full review of the project Validation and Verification will be triggered, during which no further credits can be issued from the project.

If the review discovers fraudulent activity, the project and associated credits will be cancelled. Any active or retired credits held by anyone other than the PD will be compensated from the OCP buffer pool.

The OCP is responsible for the rotation of VVB between projects using the same methodology, and projects submitted by the same PD. At a minimum, no more than three projects in a row from either the same methodology or same PD can use the same VVB/Auditor.

The OCP does not allow ‘renewal’ of projects past the maximum crediting period of 20 years. Once an initial crediting period is complete, the project developer will have to submit a new project proposal if they wish to 'renew'. This project proposal will include reassessment of baseline scenarios and will need revalidation by a different third-party VVB than any previous projects using the same methodology.

## **Conflict of Interest Policy**

* VVBs must comply with [OCP's conflict of interest policy](https://open-carbon-protocol.gitbook.io/ocp-handbook/governance/conflict-of-interest) to ensure independent review.
  * If there's a conflict of interest between the VVB and the project proponent, they will not be approved for that project.
* VVBs must disclose familial relationships with the project developer, methodology curator, or OCP leadership in their conflict of interest attestation.
* If the VVB has their own internal COI policy, they can upload their procedural documents in our form.

## Oversight

* Accreditations, expertise and performance is checked upon registration and audited yearly.
  * Every year, the OCP team will require an information update on accreditations, expertise and potential COIs. We will then run internal due diligence with the relevant accreditors.
  * In addition, the OCP team will work with independent third-party assessors to review a random selection of validation reports and processes to assess performance, accuracy and completeness.
* Instances of non-compliance or misconduct are reported to the relevant accreditation body.
* The OCP reserves the right to restrict partnerships and suspend VVB accounts in the event of poor performance or behavior. These instances and path forward will be discussed with the OCP Advisory Board.
* All validators must follow our [conflict of interest policy](https://open-carbon-protocol.gitbook.io/open-carbon-protocol-knowledge-base/how-we-work/conflict-of-interest), ensuring independence (financial or otherwise) from any project developer they work with, and comply with our annual audit process to assess protocol compliance and validation performance.
* Responsibility for Validator oversight (including conflict of interest management, audits and accreditation checks) lies with Rio Richardson, Chief Product Officer.

## Fees

* Fees are arranged on a project-by-project basis, based on time & travel commitment by the VVB.
* Fees for validation are paid by the Project Developer.
* Payment structure is agreed at the time of the project-specific contract.
* See also [Fees and Business Model](/ocp-handbook/governance/fees-and-business-model.md)


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