GS5304 MKOPA Solar Lighting Programme of Activities - Uganda VPA 2

Audit Analysis

The M-KOPA Solar Lighting PoA (Uganda VPA 2) is a Gold Standard solar lighting project with VVB-confirmed additionality and documented safeguards, but it is undermined by a project-specific baseline, an impact survey conducted only in Kenya rather than Uganda, a 0% leakage deduction with contradictory justifications across reports, and a significant discrepancy between the claimed ERR (182,006 tCO₂e) in the 2026 verification report and the 9,326 tCO₂e figure in the 2025 monitoring report. Ten corrective actions and numerous material findings indicate ongoing documentation and methodological gaps that reduce confidence in the integrity and transparency of the credit claims.

Project Description

Red Flags

• ⚠Impact survey was conducted only in Kenya; the project proponent justified representativeness for Uganda based on regional similarities and sales volume, but no Uganda-specific survey data was provided (material finding in the 2026 verification report).
• ⚠The 2026 verification report claims 182,006 tCO₂e of verified ERR for the 2023–2024 monitoring period, while the November 2025 monitoring report reports only 9,326 tCO₂e — a roughly 20-fold discrepancy that is unexplained in the extracted record.
• ⚠Leakage justification is contradictory: the 2026 verification report states leakage is 'deemed negligible' (0% deduction), while the 2024 verification report described it as 'quantified.' The more recent report is privileged, but the inconsistency weakens confidence.
• ⚠No buffer pool percentage is stated in any available document, and reversal events are marked as 'not addressed' despite the detail text noting no identified risk — the absence of a formal permanence safeguard is a gap for a 12-year crediting period.
• ⚠Usage monitoring method is contradictory: the 2026 verification report states 'annual survey' while the 2023 verification report referenced 'smart meter.' M-KOPA is widely known for smart-meter-based pay-as-you-go systems, so the shift to survey-based monitoring raises questions about data quality.

Credit Vintages