Migrate to Greentruth Registry: The Cutover Playbook for Legacy Certificates

For companies running their environmental-attribute programs on legacy registries (M-RETS, APX, Green-e), on producer-direct attestations, or on spreadsheets that auditors are increasingly asking to re-paper, the decision to migrate to Greentruth registry — or specifically to switch from M-RETS to Greentruth, APX, Green-e, or a producer-direct program — is rarely about features. It's about whether the documentation an auditor or regulator opens in 2027 will hold up. This page is the practical guide to how the cutover works: what to bring, how legacy claims are reconciled, what gets verified, what gets stamped where, and — critically — what stays portable after.

Migrating to Greentruth, in one paragraph. Migration is a structured cutover that moves existing project registrations and unsold certificate inventory from external registries (M-RETS, APX, Green-e, Verra, Gold Standard) — or from spreadsheet and producer-direct attestations — onto the EarnDLT registry under the QET framework. The process is governed by Section 6.1.6 of the EarnDLT Platform and Greentruth Marketplace Governance Framework: a program-specific migration methodology, independent third-party verification under ISO 14064-3 reasonable assurance, permanent retirement or cancellation in the origin registry, and blockchain-recorded chain of custody that preserves original vintage, carbon intensity, and verification status without modification. Migration is also additive — export back to external registries remains supported under the Framework's Migration-OUT procedures.

Read the full Governance Framework

What a QET is in the first place

The cutover is a defined, governed process — not a re-import, not a re-issuance, not a re-statement of claim. The EarnDLT Platform and Greentruth Marketplace Governance Framework treats it as a transfer of project registration and unsold certificate inventory between registries, anchored by three non-negotiable properties:

• Environmental integrity preservation. Original carbon intensity values, environmental attributes, vintage years, and verification status transfer without modification. Whatever was true in the origin registry remains true on Greentruth — the registry layer changes, the underlying environmental claim does not.
• Double-counting prevention. A certificate exists in one active registry at any moment. Retirement or cancellation in the origin registry must precede issuance on Greentruth. There is no window during which the same MMBtu, kWh, or tonne is live in both places.
• Transparency and traceability. Every transfer is publicly documented on the blockchain with a complete audit trail that links the Greentruth-issued token back to the origin-registry serial number, the cutover date, the verification body, and the origin retirement documentation.

These three properties are what make a transferred QET defensible against the kind of auditor or regulator scrutiny that's becoming standard practice for corporate disclosures in 2026 and beyond.

How double counting is structurally prevented

Three regulatory and disclosure forces are driving the current wave of cutovers to Greentruth.

EU Methane Regulation documentation requirements. Importers and downstream consumers face country-of-origin and source-attribution disclosure obligations on the natural gas they consume — and increasingly, the documentation they have on hand from legacy registries does not meet the chain-of-custody bar Article 28 contemplates. Moving onto Greentruth, paired with the platform's Physical Flow Certificate workflow, produces the segment-level evidence Article 28 expects.

Updated GHG Protocol Scope 2 guidance and analogous Scope 1/Scope 3 disclosure tightening. The major frameworks have been steadily raising the evidentiary bar for what counts as a valid market-based instrument. Spreadsheet-based attestations and producer-direct attestations that survived audits five years ago are no longer surviving 2026 audits. Transferring onto a blockchain-anchored, ISO 14064-3 verified registry resolves that evidentiary gap.

Auditor-driven re-papering of existing attestations. Beyond regulation, the assurance firms running corporate ESG audits have begun explicitly asking for blockchain-anchored chain of custody, third-party verification under ISO 14064-3 reasonable assurance, and machine-readable export of the underlying retirement evidence. Companies that previously held attestations as PDFs in a SharePoint folder are now being asked to upgrade.

For procurement and sustainability teams, the practical question is: do you act proactively while you control the timeline, or do you re-paper reactively when an auditor or regulator forces the issue? Most teams that have started the conversation have concluded the first option is cheaper, faster, and far less stressful.

How to comply under EU Methane

How to comply under LCFS

Migration INTO Greentruth from an external registry follows a five-step procedure defined in Section 6.1.6 of the Governance Framework. Each step has documented authority, defined timelines, and required artifacts.

Step 1 — Program-specific cutover methodology. Each certificate class (QET-RNG, QET-Ethanol, carbon credits, etc.) operates under a dedicated migration methodology that establishes certificate inventory audit procedures, verification-status review requirements, carbon-intensity reconciliation protocols, metadata standardization rules, and double-counting prevention controls. The methodology is approved by Earn's Chief Product Officer, Compliance Officer, and an External Technical Advisor under the Framework's program-onboarding procedures.

Step 2 — Inventory audit and origin-registry retirement. All certificates in scope must be permanently retired, cancelled, or deactivated in the origin registry before issuance on Greentruth. The Framework requires written confirmation from the origin registry administrator, public verification of retirement status, immutable documentation preventing reversal, and a notation that the retirement is “for migration to EarnDLT” (or similar designation that distinguishes such retirements from retirements made against an environmental claim).

Step 3 — Independent third-party verification of the cutover itself. A verification body accredited to ISO 14065:2020 verifies the transfer under ISO 14064-3 reasonable-assurance procedures, confirming completeness and accuracy of the inventory, proper retirement or cancellation in the origin registry, data-transformation integrity (the CI and attributes have transferred without modification), effectiveness of the double-counting prevention controls, and compliance with the applicable methodology. The verifier issues an unmodified opinion meeting materiality thresholds before any Greentruth issuance proceeds.

Step 4 — Blockchain issuance and recordation. Once verification is complete, the transferred certificates are issued on the EarnDLT registry with metadata explicitly recording the origin: origin registry name, original serial numbers, transfer date, verification body, original vintage year preserved without modification, original carbon-intensity or attribute values, a link to the origin-registry retirement documentation, and the verification opinion itself. Every transferred QET is therefore recoverable to its legacy ancestor — and a verifier or regulator can re-trace the entire chain from a Greentruth retirement back to the original registry record.

Step 5 — Program-owner approval and post-cutover monitoring. The methodology requires approval from Earn's program-onboarding decision authority (and, for third-party programs, from the relevant Program Owner). After issuance, the transferred certificates participate in the standard post-issuance monitoring — annual reviews, random batch audits, and verification body performance checks — that apply to every QET on the platform.

Most cutovers run on a 6–10 week timeline from initial scoping through verification and issuance. Complex transitions involving multiple registries, novel certificate types, or aggregated portfolios may take longer.

The completeness of your origin-registry records is the single biggest driver of cutover timeline. Companies that come to the scoping call with organized inventory records typically move faster through verification.

For each certificate or attestation in scope, the cutover packet generally needs to surface:

• Origin-registry serial number (or, for spreadsheet/producer-direct attestations, the original producer attestation document and its identifier).
• Vintage and accounting period for which the attribute was generated.
• Energy quantity (MMBtu, MWh, gallons, kilograms — whichever unit the certificate class uses).
• Carbon intensity or environmental attribute value, with the methodology and version under which it was determined.
• Verification status — whether the original certificate was verified under ISO 14064-3, under a program-specific protocol, or whether it was self-attested.
• Producer information — facility name, location (at the appropriate level of specificity), pipeline operator and injection point if applicable to the certificate class.
• Environmental-attribute rights documentation — producer attestation, power purchase agreement, gas supply contract, or other legal documentation establishing that the migrating entity holds the rights to the attribute.
• Confirmation of no prior environmental claims — written attestation that the certificates have not been retired against a Scope 1, Scope 2, or Scope 3 claim in another reporting cycle.
• Bulk-import workflow access — for portfolios above a threshold size, Greentruth's bulk import workflow handles standardized record formats; below the threshold, individual certificate handling is faster.

For spreadsheet-based attestations or producer-direct programs (no registry of record), the same data still needs to be present — it just sits in less-structured form. Part of the scoping call is determining how that data is organized today and how it maps to the QET schema.

For the QET-RNG product

For the QET-NG product

Every external registry has a slightly different attribute schema. M-RETS RNG certificates carry one set of fields; APX REC-style certificates carry another; Green-e–accredited renewable claims carry a third; producer-direct attestations carry whatever the producer chose to document.

Greentruth's attribute schema is published, versioned, and JSON-machine-readable. The cutover methodology for each certificate class specifies the field-by-field mapping from legacy schema to the QET schema. The mapping preserves:

• Vintage and energy quantity (one-to-one with the legacy field).
• Carbon intensity in kgCO₂e/MMBtu (or per appropriate unit), with IPCC AR5 GWP100 conversions applied where the legacy methodology used a different GWP basis — the original value is preserved alongside the converted value, and the conversion methodology is recorded.
• Verification status — if the legacy certificate was ISO 14064-3 verified, that status carries; if it was attested under a different protocol, that protocol is recorded explicitly so downstream consumers can reason about assurance level.
• Producer and facility identifiers — original facility identifiers are preserved as cross-reference fields on the migrated QET, so a buyer or regulator can confirm the underlying source.
• Program-specific attributes that have no direct QET equivalent — captured as legacy-metadata fields on the migrated token, available for export but not surfaced in default views.

The mapping is reviewed by the verifier before any Greentruth issuance proceeds. Any ambiguity in the legacy schema (a common occurrence with older M-RETS certificates and most spreadsheet attestations) is resolved during the verification step and documented in the verification opinion.

How the QET schema is structured for machine-readability

M-RETS public documentation

The cutover is not a self-service operation. Every transition onto Greentruth — and every transition off of Greentruth — requires independent third-party verification by an accredited verifier under ISO 14064-3 reasonable assurance.

The verifier's scope on a Migration-IN:

• Confirm the completeness and accuracy of the inventory against the origin-registry record.
• Confirm proper retirement or cancellation in the origin registry, including the public retirement record and the “for migration” notation.
• Confirm data-transformation integrity — that the CI, vintage, attributes, and verification status have transferred without modification.
• Confirm the effectiveness of the double-counting prevention controls.
• Confirm compliance with the applicable program-specific methodology.
• Issue an unmodified verification opinion meeting the program's materiality threshold.

The verifier must be accredited to ISO 14065:2020 by an acceptable accreditation body (ANAB, UKAS, DAkkS, INMETRO, or another International Accreditation Forum signatory), with sector-specific accreditation appropriate to the certificate class being transferred. Verifier independence is enforced under the Framework's separation-of-functions rules: no consulting services to the same client within 2–3 years, lead-verifier rotation every 3 years, fixed-fee compensation that is not contingent on the outcome.

The cost of verification is part of the cutover economics. For most cutovers, the verification cost is a small fraction of the value retained by upgrading the documentation — and it's a cost that auditor-driven re-papering would have produced eventually anyway, but on the auditor's timeline rather than yours.

How ISO 14064-3 verification works generally

The retirement-in-origin step is where most questions land, because it's where the double-counting prevention has to actually work. The Framework is explicit: certificates exist in only one active registry at any time. The retirement in the origin registry must be complete, immutable, and publicly verifiable before the Greentruth issuance proceeds.

Practically, this means:

• The origin registry administrator (M-RETS, APX, Green-e, Verra, Gold Standard, or whoever) issues a written confirmation that the certificates in scope have been permanently retired, cancelled, or deactivated.
• The origin registry's public record reflects the retirement — anyone querying the origin registry sees the certificates marked retired, not active, not transferred.
• The retirement is immutable; the origin registry cannot reverse it once recorded.
• The retirement carries a notation indicating it is for transfer to EarnDLT (or analogous wording), distinguishing it from a retirement that was made against an environmental claim. This matters because the retirement-for-transfer is not itself an environmental claim — the underlying attribute is being moved, not consumed.

The verifier reviews the origin-registry retirement documentation as part of the verification scope. The Greentruth issuance does not proceed without it.

Once verification is complete and origin retirement is confirmed, the transferred QETs are issued on the EarnDLT registry on Hedera Hashgraph. Each transferred certificate carries the full chain of custody as immutable on-chain metadata:

• Origin registry name and original serial number(s). The exact identifier from the legacy registry, preserved as a permanent cross-reference field.
• Transfer date and verification body. When the cutover occurred and which accredited verifier signed off.
• Original vintage year. Preserved without modification — vintage is what it was.
• Original carbon-intensity or attribute values. Preserved without modification. If a conversion to current methodology basis was applied, both the original and the converted value are stored.
• Link to origin-registry retirement documentation. The public record proving the origin retirement is referenced directly from the transferred QET.
• Verification opinion. The verifier's opinion itself is anchored to the QET on-chain.
• Producer attestation that no environmental claims have been made against the certificates prior to transfer.

For an auditor opening a Greentruth retirement record three years after the fact, the full chain — origin registry → retirement in origin → independent verification → Greentruth issuance → Greentruth retirement against the specific reporting claim — is a single navigable trail. There is no “trust us”; there is only “here is the data.”

For the retirement step · For the marketplace lifecycle generally

A concern that comes up in every migration scoping call is portability. If we migrate to Greentruth and then later need to operate in a registry we left behind, can we get back? The Framework's answer is yes — and the QET-RNG methodology §12.3 underwrites the principle.

Migration OUT of Greentruth to an external registry follows a five-step procedure that parallels Migration IN:

• Request and documentation. The Project Owner submits a written request specifying the certificates in scope (serial numbers, quantities, vintages, CI values), the destination registry, verification that the destination accepts these certificates, a written attestation of sole ownership, confirmation that no environmental claims have been made against the certificates, and the rationale.
• Platform Operator review and approval (15 business days). Greentruth reviews ownership, the absence of outstanding disputes, compliance with any program-specific restrictions, and the standing of outstanding platform fees.
• Pre-transfer verification. An independent third-party verifier (paid by the Project Owner) confirms certificate inventory accuracy, that no environmental claims or retirements have occurred, that certificates are freely transferable with no encumbrances, that chain of custody is complete, and that CI and attribute data remain accurate.
• Certificate cancellation on EarnDLT. Upon confirmation of successful registration at the destination registry, the EarnDLT certificates are permanently cancelled with a “transferred to [Registry Name]” notation, recorded immutably on the blockchain with timestamp, surfaced in the public transparency record, and documented in a cancellation certificate issued to the Project Owner.
• Documentation and audit trail. Greentruth retains the request, the verification opinion, the destination-registry receipt confirmation, the cancellation certificates, and the post-transfer reconciliation for a minimum of seven years.

The practical implication: Greentruth is not a one-way trip. Customers retain the ability to operate with legacy registries when business or compliance requirements call for it, and the same environmental-integrity preservation, double-counting prevention, and transparency principles that govern Migration IN also govern Migration OUT.

For the marketplace flow that surrounds these transitions