Coal Left in the Ground, Credits on Hold: ICR's Conditional Yes to Avoided Mining

The International Carbon Registry has conditionally approved the first methodology that would let project proponents generate carbon credits by permanently preventing the mining of commercially viable thermal coal, subject to a successful demonstration pilot by the methodology’s author, according to Carbon Pulse. For buyers and developers, the headline is a new supply category with no supply in it yet: no project is registered under the methodology, no credits have been issued, and none can be until the pilot clears validation, verification and a further registry review.

Conditional Approval, With Dates and a Locked Sequence

Source: CarbonMeld — independent carbon credit market intelligence. Document-based quality scores and assessments across all major registries: carbonmeld.com

The ICR Board approved methodology M-ICR010, Coal Abatement for the Energy Transition v3.0, on 1 October 2026, in principle only and on a safeguarded pilot basis, and published it on 16 October 2026, according to the registry’s documentation. The Board’s final determination is reserved until the first project applying the methodology has been registered, monitored and verified, and ICR has reviewed that verification. Until then, the methodology is not available to other project proponents.

The sequencing is fixed. The first project registered under the methodology must be a project of the developer, TransEnergy Global, which has until 16 April 2027, six months from publication, to bring that project into validation. ICR will review the methodology after the first verified project or by 16 October 2028, 24 months from publication, whichever comes first, and will report on its application at each ordinary Board meeting.

What Qualifies, and What Is Excluded

M-ICR010 applies to projects that permanently prevent the extraction and combustion of commercially viable thermal coal reserves, and only to thermal coal used for electricity generation. It is globally applicable, subject to evidentiary, legal, regulatory, monitoring and ownership requirements. Metallurgical coal, stranded assets and assets owned or controlled by government entities are not eligible.

The baseline is not established by the mere existence of coal reserves. A project-specific Declaration of Reserve, prepared by a Competent Person in conformance with an accepted mining code and completed no more than 24 months before the project start date, estimates the coal that would be economically viable and technically feasible to extract under current conditions. Modifying Factors, covering economic viability, technical feasibility, legal and regulatory compliance, and environmental and social considerations, are applied to produce a counterfactual production schedule, which becomes the basis for baseline emissions.

That schedule is not static. The economic viability and legal compliance factors are monitored annually and reassessed where material changes arise or at the renewal of each crediting period, and a reassessment produces a new counterfactual production schedule that governs future crediting.

Additionality, Permanence and Leakage Carry the Integrity Load

Additionality is demonstrated at three levels: greenhouse gas additionality under ISO 14064-2, statutory additionality and common practice additionality, with ex-post additionality reporting through the crediting period. Permanence requires one or more permanent legal barriers preventing extraction and combustion of the reserve, enforceable under the law of the host jurisdiction, binding on successors and assigns, and effective for at least 100 years or in perpetuity. The barrier is monitored annually for the full 100 years, and projects carry out a permanence risk assessment under ICR’s non-permanence procedures.

Leakage is treated as material by design. Market leakage must be quantified for every project through project-specific Computable General Equilibrium modelling, with uncertainty handled using recognized statistical approaches and the leakage adjustment factor derived conservatively. For a credit class whose core claim is that demand for the underlying fuel does not simply shift to another mine, that modelling burden is the central evidentiary test.

Three Review Rounds Before the Board Said Yes, Conditionally

The methodology went through public consultation, independent validation by TÜV NORD CERT under ISO 14064-3 and ICR review across three rounds before reaching the board, according to Carbon Herald. The registry describes it as the first of its kind, intended to credit emissions reductions achieved by permanently leaving commercially viable thermal coal reserves unmined.

The Pilot Points to Botswana

TransEnergy Global, a Singapore-incorporated climate-tech company, says it is advancing its intended first pilot in Southern Africa, located in Botswana, with a start date of 2027 and a project life of 15 years, according to the developer’s project page. The Southern Africa Project aims to permanently prevent the extraction and combustion of unmined thermal coal reserves while supporting renewable energy investment and just transition initiatives. Registration and any future credit issuance remain subject to successful validation, verification, further ICR review and applicable registry decisions.

What Buyers and Developers Should Watch

The near-term markers are procedural and dated:

• Whether TransEnergy Global files the Botswana pilot for validation by 16 April 2027. Missing the six-month window would stall the entire methodology, since no other proponent may register a project in the meantime.
• The verification outcome for the first project and the substance of ICR’s review, due after the first verified project or by 16 October 2028 at the latest.
• Whether the Board’s final determination opens the methodology to other proponents, which is the precondition for any broader supply.

For buyers, the practical position is simple: this is a methodology signal, not purchasable supply, and any forward procurement interest should track the pilot’s validation milestones rather than assume credit volumes. For developers working on supply-side fossil fuel abatement concepts, the conditional approval establishes that a registry is willing to test avoided extraction crediting, but only under explicit additionality, 100-year permanence and per-project leakage modelling requirements that will be expensive to meet.