TL;DR
Article 6.2 ITMOs = หน่วยลดการปล่อยที่โอนข้ามประเทศโดยมี corresponding adjustment ทั้งสองฝั่ง: Thailand–Switzerland MOU 2565, Thailand–Singapore Implementation Agreement 2567, Thailand–Japan ในการเจรจา; ราคา premium USD 25–60/tCO₂; TGO authorise + Cabinet approve รายโครงการ; 5% Share of Proceeds + 2% OMGE หักก่อนโอน
Article 6.2 ITMOs are emission units transferred internationally with corresponding adjustments on both sides. Thailand has a live MOU with Switzerland (2022), an Implementation Agreement with Singapore (2024), and a bilateral with Japan in negotiation. Each ITMO trades at USD 25–60 premium over voluntary equivalents. Authorisation requires TGO recommendation + Cabinet approval per project, with 5 % SOP-A and 2 % OMGE deductions before transfer.
What an ITMO actually is
An ITMO = mitigation outcome (tCO₂e reduced or removed) **authorised** by the host country for international transfer under Paris Agreement Article 6.2, with the host country applying a **corresponding adjustment** (CA) to its NDC inventory so the same tonne is not counted twice.
Without authorisation + CA, the credit is voluntary-only. With authorisation, it can be used by the buyer-country government, CORSIA-obligated airlines, or jurisdictions with mandatory schemes that accept ITMOs (Switzerland's CO₂ Act amendment 2024; Singapore's carbon tax compliance from 2024).
The CMA decisions 2/CMA.3 (Glasgow) + 5/CMA.4 (Sharm el-Sheikh) + 12/CMA.5 (Dubai) fixed the rulebook: initial transfer report, annual information report, first review report, and the structured data exchange format (ITMO Identifier).
Thailand's bilateral pipeline (June 2026 snapshot)
**Switzerland — MOU signed 24 June 2022.** First ITMO transfer authorised 2024 (waste-to-energy project, Saraburi). KliK Foundation is the principal buyer.
**Singapore — Implementation Agreement signed October 2024.** Bilateral commission established; pilot projects in waste sector + mangrove (with shared methodology approval from TGO + NCCS).
**Japan — JCM upgrade negotiation underway.** Thailand was an original JCM partner (2015); the 2026 upgrade aligns JCM with Article 6.2 mechanics, expected MOU signature Q4 2026.
**South Korea, Germany, Sweden — exploratory.** No signed instruments yet; Thailand's Department of Climate Change (newly elevated, 2024) handles the negotiations under MNRE.
The authorisation workflow
**Step 1 — Methodology approval.** Project must use a methodology jointly approved by both Designated National Authorities (TGO for Thailand + the buyer-country DNA).
**Step 2 — Letter of Authorisation (LoA) from TGO,** specifying volume, vintage, purpose (NDC use vs OIMP — Other International Mitigation Purpose vs CORSIA).
**Step 3 — Cabinet Resolution** for any transaction exceeding the TGO-delegated threshold (currently 500 ktCO₂e per project). Cabinet approval is the political circuit-breaker — projects with social-licence concerns can stall here.
**Step 4 — Initial Transfer Report** lodged by Thailand's UNFCCC focal point.
**Step 5 — Corresponding adjustment** booked in Thailand's BTR (Biennial Transparency Report) submitted every two years from Dec 2024.
**Step 6 — Share-of-proceeds deductions:** 5 % to the Adaptation Fund (SOP-A) + 2 % cancellation for Overall Mitigation in Global Emissions (OMGE) before the transfer is registered.
Pricing economics
Switzerland's KliK has paid CHF 35–60 / tCO₂ in published deals — at the upper end for high-permanence, MRV-verified, gender + livelihood co-benefit profiles.
Singapore's carbon-tax-compliance ITMOs trade closer to SGD 25–35 / tCO₂ (the carbon tax is SGD 25 in 2024–2025, rising to SGD 45 by 2026 and SGD 50–80 by 2030).
Out of the headline price, deduct: 7 % SOP+OMGE; up to 30 % to landowner / community; project-developer margin; verification cost (USD 0.5–1.5 / t). Government share is captured in policy via TGO retention + 'profit' tax under Revenue Code § 65 on project SPVs.
Documentary + notarial chain
**Mitigation Activity Design Document (MADD)** — bilingual TH/EN, validated by TGO + buyer-country DOE.
**Letter of Authorisation (TGO + Buyer DNA)** — Apostilled for cross-border evidential weight.
**Cabinet Resolution + Royal Gazette publication** — certified true copy by Notarial Services Attorney; Apostille at Department of Consular Affairs.
**ITMO Transfer Agreement** — governing law clauses must address: corresponding-adjustment failure, reversal events, sanctions on host-country list, force-majeure including grid emission factor changes.
**Director's Compliance Certificate** signed before notary annually — confirms ongoing methodology adherence + MRV data integrity.
คำถามที่พบบ่อย
Can a private developer sell ITMOs without TGO involvement?+
No. TGO is the Thai DNA under the UNFCCC. Any cross-border transfer claiming Article 6.2 status without TGO authorisation is voluntary-only and will be rejected by buyer-country compliance systems (Switzerland, Singapore, future Japan). Attempting to label it as ITMO is misleading marketing — exposed under Consumer Protection Act + EU CSRD anti-greenwashing rules.
What is the difference between Article 6.2 and Article 6.4?+
Art. 6.2 = bilateral / cooperative approaches between countries (decentralised). Art. 6.4 = centralised UNFCCC mechanism (successor to the CDM), Supervisory Body in Bonn. Thailand has both pathways open; 6.2 is operationally live, 6.4 awaits methodology adoption in 2026–2027.
How does an ITMO sale affect our CSRD / IFRS S2 disclosures?+
ITMOs sold are NOT a Scope 1/2/3 reduction for the seller's group — they are sold to another party. The seller must disclose the transaction value + the fact that the emission reduction has been transferred. IFRS S2 paragraph 36 (Carbon Credits) requires the disclosure.
Can we Apostille the Cabinet Resolution for an EU buyer?+
Yes — from 28 February 2027 Thailand is a HCCH Apostille party. The Cabinet Resolution + Royal Gazette extract can be certified by a Notarial Services Attorney and Apostilled at the Department of Consular Affairs in 1 working day. Acceptance is automatic in all 27 EU Member States.
