Nine hundred and eighty million credits are waiting at a door.

Roughly 980 million legacy credits asked to be let into the Paris Agreement's crediting mechanism. On the reported position, around 128 million have host country approval. That is about 13 per cent. The two largest historical supplier countries are absent from the approval list. Whatever the final number, this is the largest eligibility event the carbon market has ever produced, it is happening now, and nobody is keeping the score in public.

What is actually happening

The Clean Development Mechanism issued credits for two decades under the Kyoto Protocol. Those credits do not automatically carry over into the Paris Agreement Crediting Mechanism. A project has to request transition, and the host country has to approve it.

The UNFCCC set a deadline for host party approval, then extended it to June 2026 from an original end of 2025. The deadline for developers to file additional documentation was pushed to December 2026. Trade reporting puts the potential transition pool at roughly 980 million certified emission reductions, with approvals so far at around 128 million.

The gap is not administrative slippage. It is a decision, taken country by country. Notable by absence from the approval list are China and India, historically the two largest suppliers of CDM credits, whose non participation removes several hundred legacy projects and a potential supply measured in hundreds of millions of tonnes.

What happens to a credit that does not get through

Projects left outside the mechanism face three options: move to a voluntary standard, move to a domestic compliance scheme, or wind down. None of those is a neutral outcome for whoever is holding the credit.

This is what an eligibility loss looks like in practice. The credit did not reverse. No forest burned. No fraud was found. The tonne, whatever it was worth, is unchanged. What changed is the set of obligations the credit can be used against, and that set is the thing that gives it a price. A unit that can be surrendered into a compliance regime and a unit that cannot are different assets, and the difference was decided by an administrative process on a specific date.

Holders of avoidance era stock should read that carefully, because the mechanism generalises. Eligibility is a permission, permissions are granted and withdrawn by named bodies on dated decisions, and the withdrawal reprices the standing stock without touching the underlying project at all.

Why nobody can tell you the number

Ask what this event has cost holders and there is no answer available, for three reasons that are structural rather than accidental.

The denominators move. Is the relevant figure credits requesting transition, credits eligible to request, all outstanding CDM units, or units actually held by parties who wanted to use them? Each gives a different percentage and each is defensible. A number quoted without saying which is being used is not information.

The status is not binary and the data model usually is. A credit may be approved, refused, awaiting host approval, awaiting documentation, or in a state that could still change before the December 2026 deadline. A flat status field cannot represent "was valid, is currently frozen, may become valid again if a government moves". Systems that force it into one flag will produce clean data that is wrong.

Nobody is tasked with recording it. The UNFCCC publishes the approvals. Registries publish their own holdings. Analysts publish estimates. No party is responsible for maintaining the dated, typed, sourced record of what changed for whom, which is precisely why the market's headline statistics on eligibility loss already disagree with each other by tens of millions of tonnes.

The wider point about the rotation

The market is rotating from avoidance toward removals, and that rotation is usually discussed as sentiment: buyers prefer removals, standards are tightening, prices have bifurcated. Sentiment cannot be recorded.

What can be recorded is this. A standard publishes guidance that steps a durable share requirement upward, on a date. A compliance scheme approves or declines a programme for a phase, on a date. A regulator proposes admitting permanent removals only, on a date, subject to a legislative process. A mechanism refuses transition to a body of legacy units, on a date, project by project. Each of those is an event with an author, a document and a population affected.

Avoidance is being demoted. That is not the same as dead, and the distinction matters commercially: CORSIA's second phase re-approved jurisdictional avoided deforestation, and CCP labelled REDD has a pipeline in the hundreds of millions. What is happening is a repricing, and repricings can be dated.

What we are doing about it

The transition is a first edition candidate for the Carbon Loss Register, subject to one condition we apply to everything: the figures must resolve at source. Trade press numbers are leads, not evidence. The register will carry what the UNFCCC publishes, with the retrieval date, the deciding document and the denominator stated, and it will abstain where attribution to specific holders is not public rather than estimate it.

That is slower than writing a headline. It is also the only version of this that an auditor, an underwriter or a credit committee can use, which is the only version worth building.