Programme of Activity (PoA)

Programme of Activity (PoA)

Programme of Activity (PoA)

New PoA's

Following publication of new Programme of Activity Requirements and Procedures by Gold Standard (05.05.2022) the SustainCERT platform is updated to accommodate the new requirements.  

The new Programme of Activity (PoA) requirements apply to new projects and replace the old PoA requirements. Existing Programme of Activity (PoA) and VPA’s continue to follow old PoA requirements until they end or transition to new PoA requirements.  

Starting on March 20th, 2023 you will only be able to create NEW PoA with associated real case VPA and regular VPAs under the new PoA requirements, on the SustainCERT platform. You will not be able to create new PoA and VPA’s under the old PoA requirements.  

When you create a new PoA you need to follow the new PoA hierarchy and create real case VPA and regular VPA (instead of only VPA). A real case VPA is linked to a PoA and regular VPA is linked to real case VPA.   

Existing PoA's 

To help with the transition, the SustainCERT platform continues to support existing PoA and VPAs (with design certified or issued status), until they have ended of transitioned to the new PoA requirements. For existing PoAs created under old PoA requirements, you will still be able to add new VPA’s.   

You can continue to manage your projects for both the new and old structure using our platform. Requesting reviews, managing documents, paying invoices, and other actions will still be available as before for both new and old structures.     

How to create a project under Programme of Activities (PoA) requirements ( Version 2.0, Publication date: 05-05-2022)?

The creation of a project was updated to accomodate the changes to the Programme of Activities (PoA) requirements. The PoA requirements entered into force on 3 August 2022. Therefore, every new project will follow these new requirements, which apply to Energy and LUF projects. 

We currently only support Energy projects. LUF projects support will be available in the future.

You need to create projects in the following order:

1. PoA Master Project - You create PoA Master Project

2. Real case VPA - You create Real Case VPA

For Real Case and Regular VPAs, the process changed. In both cases, there’s the need to define to which project the VPA will be connected.  

Real Case VPAs should be connected to a PoA Master project. This PoA Master project should exist already. 

If there's no valid Master project, the following error will be displayed: 

3. Regular VPA

Regular VPAs should be connected to a Real Case VPA. This Real Case VPA should exist already. 

If there's no valid Real Case VPA project, the following error will be displayed: 

The rest of the process to create a project remains the same. The project structure, including all Real Case VPAs and Regular VPAs, can be seen in any project of the structure.  


For Master projects, in the Real-case VPAs tab: 

For Real Case VPAs and Regular Case VPAs, in the Programme of Activities field under Project Information Tab, which can be expanded to display the whole structure: 

The review types changed as follows: 


Master projects’ first review is now PoA Preliminary Review instead of PoA Design Consultation 

Regular VPAs don’t have preliminary review by default since those are optional. The optional preliminary review can be added clicking on “Add Review” 

How Bundles changed with the new Programme of Activities requirements? 
Bundles will continue to work under the new requirements. They continue to be created by Sustain-Cert following slightly different rules. Bundles can include Real Case VPAs and Regular VPAs. The rule is that only one Real Case VPA can be added to a bundle and all Regular VPAs should be connected to the Real Case VPA in the bundle. 
In the example below, we have the following structure: 

Following the structure above mentioned, a bundle named "Test bundle" was created. It contains one Real Case VPA and the only Regular Case VPA under it. It’s not possible to have two or more Real Case VPAs in the same bundle nor Regular Case VPAs from different Real Case VPAs.

Requesting reviews in a bundle continue to work as before, following the same rules with one adaptation: reviews can be requested in bundle for Real Case VPAs and its Regular Case VPAs at the same time. 


For projects with no Programme of activities or Master projects, the process is the same. 


A Programme of Activity (PoA) is a set of related activities with a common objective. PoAs enable replicable projects access to carbon finance through coordinated implementation. This document provides minimum requirements and procedures to Coordinating/managing entities (CMEs) and/or Voluntary Project Activity (VPA) implementers for designing, implementing, monitoring, and seeking issuance of Gold Standard Certified Impact Statements or Products and related actions under a PoA.

The objective is to seek feedback from relevant stakeholders in the following areas related to the PoA:
  • Sustainable development impacts of the PoA
  • Spread/location of the PoA
  • Feedback on the technology
  • Overall design of the PoA


Please read the POA Requirements document.

The Programme of Activity (PoA) requirements provide the minimum requirements for designing and implementing a PoA and seeking issuance of Gold Standard Certified Impact Statements or Products.

1.1.2 All Voluntary Project Activities (VPAs) or Component Project Activities (CPAs) submitted for Design Certification within a PoA, must be in compliance with relevant Gold Standard eligibility criteria (for example Principles & Requirements and applicable Activity Requirements).

1.1.3 These Requirements are not applicable to projects applying Land Use & Forests Activity Requirements or Contextual Requirements.

1.1.4 Unless otherwise specified in this the document, Gold Standard PoAs follow the requirements listed in the CDM Project Standard for Programmes of Activities.
Submission Date

*Date of PoA submission is the date on which the PoA Design Consultation Report is submitted for review.

Programme of Activity Design Change

The documents to be submitted during PoA design change shall be in line with the list of documentation mentioned in Annex A of the Principles & Requirements but with relevant documents to be submitted at the PoA level. 

PoA-level design change request does not require the Voluntary Project Activities (VPAs)/ Component Project Activities (CPA)-level documents to be submitted for design change review upfront. For the PoA-level design change request, the Coordinating/Managing Entity can only submit PoA-related documents such as the PoA-Design Document. 

*The consultation of the PoA can be conducted electronically. 

Microscale Programme of Activities (MPoA)

Microscale Programme of Activities (MPoA) refers to a PoA that involves implementation of microscale voluntary project activities (VPA). Refer to Section 5.1 | aboveType and scale, above. The rules and requirements mentioned in the main document for PoA/ VPAs shall apply to MPoA.


In the case of micro-PoAs, Objective Observer (OO) visits are mandatory at the time of internal validation of the PoA.

Gold Standard inclusion review

For the Voluntary Project activities (VPAs), four (4) VPAs can be submitted at one time for a Gold Standard inclusion review, which commences only after the payment of Inclusion Review Fees (USD 2500 per VPA).

Selection, Role and Responsibilities of Objective Observers.

In view of the inclusion and verification of VPAs to a MPoA, a target-random approach is applied to the VPAs appraisal, making use of an Objective Observer at validation, inclusion and/or verification stage by CB.

In the case of micro-PoAs, Objective Observer (OO) visits are mandatory at the time of internal validation of the PoA.

*For any VPA not selected for an appraisal by an Objective Observer at stage of inclusion, the CME shall conduct a self-assessment of the risks associated with respect to the safeguarding principles (human rights abuse, environmental degradation, non-adherence to labour laws, corruption, etc.), check completeness of stakeholder consultations as well as assess contribution to three SDGs.
PoA Design Consultation Requirements 
  • Host country DNA(s) (designated national authority)
  • Gold Standard Secretariat
  • Gold Standard international and Gold Standard local NGO partners
  • Other local NGOs
  • Research organizations/institutes (e.g. renewable energy development agencies, etc.)
  • Agencies responsible for setting the quality criteria for that technology in the host country
  • Coordinating/Managing entities (CMEs) of earlier similar PoAs in the region/country
  • Technology supplier

Design Consultation vs Stakeholder Consultations 

The PoA Design Consultation is a mandatory step of stakeholder consultation that must take place for all PoAs. At the PoA/CPA (Component Project Activity) or VPA (Voluntary Project Activity) level, The PoA Design Consultation is a mandatory step of stakeholder consultation that must take place for all PoAs. This design consultation needs to be carried out in addition to a PoA/activity level consultation. The objective of this consultation is to collect feedback from relevant stakeholders on the overall design and expected impacts of the programme in order to ensure it is in line with the national or regional sustainable development goals and priorities. This consultation can be conducted electronically.

Stakeholder consultation at the PoA/activity level involves a physical meeting with stakeholders including local people, communities impacted, local NGOs, government officials, etc. This meeting should be complemented with other feedback gained via bilateral discussions and calls for input via emails, letters of support, etc. The aim of this consultation process is to inform stakeholders in detail about the activities to be implemented within the programme and give them the opportunity to discuss the impact of the activities on them and on the environment.

New renewable energy


The new eligibility requirements, as defined in Renewable Energy Activity Requirements, paragraph 2.1.3, set the following requirements for Validated and/or listed PoAs:

  • Already validated and/or listed PoAs need to complete validation and submit the request for registration by 24 October 2020 if they do not wish to apply the new renewable energy eligibility rules. The PoA boundary defined and technology types included at the time of listing must remain unchanged during validation. At the time of the next renewal of the PoA, the criteria for inclusion of new Voluntary Project Activities (VPAs)/Component Project Activities (CPAs) shall be updated in line with the new eligibility rules as defined in RE activity requirements, paragraph 2.1.3.

  • New VPAs/CPAs included as per the previous rules can continue till the end of their respective maximum allowed crediting period.

  • PoAs submitted for registration after 24 October 2020 shall define the VPAs/CPAs inclusion criteria in line with the new RE activity requirements, paragraph 2.1.3.

VPA Inclusion

To include a regular VPA in a design certified PoA, the CME shall ensure that the proposed VPA complies with the latest version of the design certified PoA and its corresponding real case VPA and relevant GS4GG rules and  requirements as referred in registered PoA and real case VPA, unless a decision by TAC puts the applied methodology and/or methodological tool on hold.

The date of VPA Design Certification (inclusion date) is the last day of Design Review period, applicable as per the inclusion pathway, even if the design review is concluded after this date

A regular VPA may be included in the PoA by following one of the applicable pathways mentioned below. The figure below provides a schematic of all the three VPA inclusion pathways.

VPA Inclusion pathways

Inclusion of regular VPAs 

This pathway can be used by all proposed/implemented regular VPAs irrespective of their start dates and involves following two actions: 

a. Compliance check by VVB: Prior to inclusion of a regular VPA, the VVB shall conduct a compliance check with respect to the inclusion criteria defined in the PoA-DD and real case DD. The VVB shall submit a formal inclusion request by submitting VVB’s Inclusion Report to Gold Standard.

b. Design Certification Review by Gold Standard: After the compliance check by a VVB, Gold Standard shall conduct a Design Certification Review (2 weeks) of the regular VPAs before being formally included in the PoA.

The design review period starts when:

a. the relevant documents (VPA DD, VVB Inclusion Report and other documentation) are submitted to Gold Standard, and 

b. design review fee is paid.

The Gold Standard may conduct spot-checks for any of the proposed VPAs for inclusion by the VVB, based on a target-random approach. The spot-check will entail Gold Standard carrying out a full review as opposed to a compliance check done normally. Where selected for spot check, the VPA will undergo three week review period.

Fast-track inclusion of regular VPAs

This pathway involves a four-week Design Certification Review by Gold Standard only and does not require a compliance check by a VVB.
The design review period starts when; 

c. the relevant documents (VPA DD, Validation report and other supporting documents) are submitted to Gold Standard, and 

d. design review fee is paid. 

This pathway can be used for all proposed/implemented regular VPAs irrespective of their start dates provided that the CME can demonstrate that the regular VPA:

a. involves operations and implementation in the same host country, and

b. corresponds to a design certified real case VPA (and applying the same 
inclusion criteria and technology/measure), and

c. apply same methodology or combination of methodologies in accordance
with modalities of real case VPA.

This pathway cannot be used by regular VPAs in the following situations:

a. where identified as not applicable in the Preliminary Review Request Form.

For such cases, Gold Standard shall identify and inform CME via preliminary review request form of real case VPA if this pathway is not available or likely conditions and requirements and/or timeframe until when this pathway would not be available for corresponding real case VPAs). For example, material issues were identified at the preliminary review stage for a given real case VPA that requires a VVB assessment; regular VPAs are likely to involve assessment areas that requires compliance check by a VVB.

b. which belong to the type/scope of activities for which currently inclusion of new VPAs is temporarily put on hold by TAC, for example due to an ongoing investigation.

For the regular VPAs directly included by the CME applying the Fast Track inclusion pathway, the VVB that performs the first verification for such VPAs shall confirm that they comply with the requirements defined for the inclusion of VPAs in the registered PoA and corresponding VPAs. If the VVB finds that they do not comply with any of the applicable requirements, then:

Such VPAs shall be deemed to be erroneously included and will be further assessed in line with the requirements defined for treatment of erroneously included VPAs in section 3.5 above. 

b. The requirements mentioned in section 3.5 above will also apply to resolve the established non-conformity and no new regular VPAs shall be included without the positive conclusion of VVB compliance check for the next two VPAs.

For the regular VPAs directly included by the CME following Fast track inclusion pathway, the VVB shall conduct the site visit within two years of a VPA’s start date

Combined inclusion and issuance of real-case and regular VPAs

This pathway allows for inclusion and issuance of GSVERs for implemented VPAs in the PoA for achieving. This pathway entails the following three phases:

a. Validation/ compliance check: The VVB shall conduct a validation (real case VPAs)/ compliance check (regular VPAs) for inclusion of new VPA in the PoA.

b. Verification: The VVB shall conduct a verification of all new VPAs and/or any existing VPA. The VVB may combine verification assessment for all VPAs with same monitoring period start and end date in a single Verification Report. Also, the VVB may carry out a combined site visit for both validation and verification process. 

c. Combined Design and Performance Review: Gold Standard shall carry out a combined Design and Performance Review (6 weeks) of all new VPAs and Performance Review of all existing VPAs (as applicable) together. 

The combined design and performance review period starts when; 

a. the relevant documents (VPA DD, VVB reports and other documents) are submitted to Gold Standard, and 

b. applicable review fee is paid. 

FAQs on P.O.A

  1. Can registered Programme of Activities (PoAs) expand to new countries or expand the scope of the project?
No, not until the next PoA renewal. The PoAs that are in line with the new eligibility rules can extend the boundary of the registered PoA to include new countries or expand the scope to include new renewable technology types.
  1. Can registered Programme of Activities (PoAs) continue to include Voluntary Project Activities (VPAs)/Component Project Activities (CPAs) that may violate current eligibility requirements?
Yes, a registered PoA can continue including new VPAs/CPAs as per the approved inclusion criteria in the registered PoA-Design Document (i.e. against the previous RE eligibility rules) until the next renewal of the PoA. At that time, the inclusion criteria for new VPAs/CPAs must be updated in line with the new eligibility rules as defined in Renewable Energy Activity Requirements, paragraph 2.1.3. 

Any new VPAs/CPAs included as per the previous rules can continue until the end of their respective maximum allowed crediting period. 
  1. If a 7-year renewable crediting period project or Programme of Activity (PoA) has fewer than 24 months remaining on its current 7-year cycle on 14th August 2017, can the project/PoA complete the first 7-year cycle in full and then renew.
No. The maximum number of renewals defined in the Activity Requirements applies. In this example (assuming a standard maximum of 3 renewals is permitted), the project can complete the remainder of the 7-year cycle, then it should transition to 5-year cycles for the remaining available renewals (in this case 2).

For more clarification, you can contact us at