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RC/CF/2026/L.1Draft · not yet adopted

Draft resolution: the 15‑Day Pay Standard

21 July 2026 · Resolution Circulated

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Cashflow Council

RC/CF/2026/L.1Circulated

Draft resolution: the 15-Day Pay Standard

Draft for consultation and Assembly action

The Founders Assembly,

Recalling the Founders Charter of the Assembly, adopted on 10 February 2026, and the Rules of Procedure of the Founders Assembly, adopted on 19 March 2026,1

Recalling the call for evidence on agenda item CF-001, issued on 10 February 2026, and the Cashflow Council’s interim pattern review on late payment to small suppliers, dated 14 May 2026,2

Taking note of the Cashflow Council’s certification, dated 23 June 2026, that the pattern test for CF-001 had been met across its five dimensions of Volume, Frequency, Consistency, Spread and Corroboration,3

Taking note of evidence gathered by the Cashflow Council, including reports of delayed payment by clients and of supplier terms that require small businesses to wait for payment, and recognizing that these accounts describe practices and patterns and do not, by themselves, establish findings about any particular buyer or supplier,

Recognizing that micro, small and medium-sized enterprises account for approximately 90 per cent of businesses, 60–70 per cent of employment and approximately 50 per cent of gross domestic product worldwide,4

Noting the International Labour Organization’s estimate that micro, small and medium-sized enterprises account for approximately 70 per cent of employment worldwide and that approximately 80 per cent operate in the informal economy,5

Noting that the United Kingdom’s Late Payments Bill was introduced in the House of Lords on 19 May 2026, and that the bill provides for a maximum payment term of 60 days, mandatory interest at 8 per cent above the Bank of England base rate, and

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adjudication and fine powers for the Small Business Commissioner, while exempting import and export contracts from the payment-term cap,6

Noting the European Union’s proposal for a Late Payment Regulation, published in September 2023, which proposed a 30-day cap, the European Parliament’s position adopted in April 2024, and the proposal’s subsequent blockage in the Council,[7]

Noting that, in India, section 15 of the Micro, Small and Medium Enterprises Development Act provides for payment within 15 days where there is no written agreement and within the agreed period, not exceeding 45 days, where there is a written agreement, and that section 43B(h) of the Income-tax Act links deduction of certain sums payable to micro and small enterprises to payment within the applicable period; late payment may also attract compound interest at three times the notified bank rate,[8]

Concerned that delayed payment transfers the cost of financing a buyer’s operations to a supplier that may have less capacity to absorb uncertainty, meet payroll, purchase inputs or continue trading,

Concerned also that contractual terms alone do not ensure timely payment where a supplier has limited bargaining power, where the date on which an invoice is accepted is unclear, or where a dispute is raised without a clear process and timetable,

Recognizing that a payment standard should distinguish a genuine, documented dispute from an attempt to delay payment, and should not prevent a buyer from raising a legitimate concern about an invoice, the goods or services supplied, or the amount due,

Recognizing further that prompt payment is a matter of business practice and operational design as well as contract wording, and that accurate invoice handling, clear contacts, traceable decisions and predictable payment runs can reduce avoidable delay,

Acknowledging the Cashflow Council’s internal evidence as of 21 July 2026: 280 Council members from 48 countries; 905 reports from 50 countries; a median amount at stake of approximately US$4,716; and 743 reports concerning a client that pays late and 162 concerning supplier terms,[9]

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Acknowledging that the reported evidence is not a census of all small businesses, does not establish the prevalence of late payment in every country or sector, and is used by the Assembly to identify and assess a reported pattern rather than to make findings against named businesses,

Recognizing the need for a practical standard that can be adopted by buyers across different jurisdictions, while preserving stronger protections available under applicable law and avoiding any suggestion that voluntary adoption displaces statutory rights,

1.Adopts, subject to the Assembly’s decision, the 15-Day Pay Standard set out in the annex to the present resolution;

2.Invites large buyers, including businesses operating marketplaces, retail, payment, procurement and other commercial services, to adopt the Standard for payments to small suppliers and to publish their adoption status;

3.Calls upon adopters to implement the Standard through their contracts, invoice-processing arrangements, dispute procedures and payment systems, and to ensure that the people responsible for those arrangements are informed of the obligations set out in the annex;

4.Affirms that the Standard is a minimum practice commitment and does not reduce, replace or waive any right or protection that a supplier has under applicable law or under a more favourable contractual term;

5.Encourages buyers to offer a shorter payment period where their operational capacity permits, and not to use the 15-day period as a reason to lengthen an existing shorter term;

6.Requests the Cashflow Council to conduct public consultation on the draft, publish a summary of the issues raised and proposed revisions, and return the text for Assembly consideration in accordance with the Rules of Procedure;

7.Requests the Secretariat, following adoption, to transmit the Standard to the chief executives of the buyer organizations selected through the Assembly’s process, record the status of each seat, and publish the record without implying a response or endorsement where none has been received;

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8.Invites buyers that adopt the Standard to identify an accountable senior owner, make an accessible route available for suppliers to raise payment concerns, and provide sufficient information for suppliers to understand the status of an invoice;

9.Calls upon adopters to apply the Standard consistently across relevant supplier relationships, and to avoid discriminatory treatment, retaliation or loss of commercial access because a supplier requests payment in accordance with the Standard or raises a good-faith dispute;

10.Encourages buyers to review their internal processes for purchase-order matching, invoice receipt, approval, dispute notification, payment authorization and remittance information, so that administrative steps within the buyer’s control do not cause payment to exceed the agreed period;

11.Requests that the implementation framework distinguish payment performance from the existence of a dispute, record the timing and outcome of disputes, and support the identification of recurring process failures without requiring the public disclosure of a supplier’s confidential commercial information;

12.Decides that the Standard should be reviewed after its first 12 months of operation following adoption, with further review at intervals set by the Assembly, and that the review should consider consultation evidence, uptake, reported implementation difficulties, the operation of the dispute safeguards and relevant changes in law;

13.Requests that the Cashflow Council prepare the review for the Assembly and recommend any amendments through the applicable procedure.

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Annex

15-Day Pay Standard

1. Purpose and application

1.1. The Standard establishes a common practice commitment for a large buyer paying a small supplier for goods or services supplied in the course of business. Its purpose is to make payment timing predictable, reduce avoidable delay and ensure that a genuine invoice dispute is raised promptly and handled transparently.

1.2. The Standard applies to an adopter’s business-to-business transactions with small suppliers. An adopter should apply it to the entities and purchasing arrangements it controls and should state clearly any material limitation in the scope of its commitment.

1.3. Adoption is voluntary under this resolution. Once a buyer publicly states that it has adopted the Standard, the buyer is expected to apply it in good faith and to report its implementation as provided below. The Standard does not create a legal rule in any jurisdiction and does not replace applicable law.

1.4. Where the law applicable to a transaction requires payment sooner, grants a supplier a more favourable right, or otherwise provides stronger protection, the adopter shall comply with that law or protection. Nothing in the Standard authorizes a longer payment period than the one required by law or agreed on more favourable terms.

2. Definitions

2.1. For the purposes of the Standard:

  • “Adopter” means a buyer that has publicly committed to apply the Standard.
  • “Buyer” means a person or organization purchasing goods or services from a supplier in the course of business.
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  • “Large buyer” means a buyer that is not itself a small supplier for the transaction in question and has the operational capacity and commercial position to apply the Standard. The Standard does not prescribe a single global threshold for size; an adopter shall describe the basis on which it determines the scope of its commitment.
  • “Small supplier” means a micro, small or medium-sized business supplying goods or services to a buyer. The term includes a supplier acting through an intermediary where the adopter’s procurement or payment arrangement determines the timing of payment to that supplier.
  • “Invoice” means a payment request that identifies, at a minimum, the supplier, the buyer, the goods or services supplied, the amount claimed and the date of issue, together with information reasonably required by the buyer and communicated to the supplier in advance.
  • “Receipt” means the date on which an invoice is delivered to the buyer through the designated channel or, if no channel has been clearly designated, the date it reaches a communication address the buyer uses for invoices or supplier communications.
  • “Undisputed invoice” means an invoice for which the buyer has not, within the dispute-notification period in paragraph 4.2, sent the supplier a notice that identifies a specific and reasonable basis for disputing all or part of the amount claimed.
  • “Disputed amount” means only the portion of an invoice that is covered by a timely, specific and good-faith dispute notice. A dispute about one portion does not make an undisputed portion disputed.
  • “Payment date” means the date on which the funds due are made available to the supplier, or the date on which the buyer initiates an irrevocable payment that cannot reasonably be reversed in the ordinary course.
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  • “Calendar day” means a day counted consecutively, including weekends and public holidays. If the payment date falls on a day when the relevant payment system does not operate, the buyer shall arrange payment so that funds are made available no later than the next operating day, without using that circumstance to extend the period beyond what is reasonably necessary.

2.2. If a local law defines any of these terms, the adopter shall follow that law where it governs the transaction. Where the Standard and applicable law use different terminology, the adopter shall apply the substance of the Standard to the extent consistent with the law.

3. Core payment obligation

3.1. An adopter shall pay an undisputed invoice from a small supplier within 15 calendar days of receipt.

3.2. Where a buyer has not provided a clearly identified invoice channel, it shall not treat the invoice as unreceived solely because the supplier used another reasonable channel already used by the parties for business communications.

3.3. An adopter shall not make the start of the 15-day period conditional on an internal approval, payment run, reconciliation, resale, customer payment, or other step that is within the buyer’s control or risk.

3.4. An adopter shall not require a supplier to accept a new, longer payment term as a condition of continuing an existing supply relationship, receiving payment for an invoice already due, or resolving a payment query.

3.5. A shorter period agreed between the buyer and supplier shall remain in force. The Standard shall not be cited as a basis for replacing a shorter statutory, contractual or customary payment period with 15 days.

4. Invoice handling and disputes

4.1. Before a supplier begins providing goods or services, or as soon as practicable when a relationship is already in place, the buyer shall communicate the invoice channel, the information reasonably required to process an invoice, the payment contact and the applicable payment period.

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4.2. If the buyer disputes an invoice, it shall notify the supplier within five calendar days after receipt. The notice shall identify the invoice and the amount disputed, state the specific reason for the dispute, identify any information or corrective action reasonably required, and provide a contact or process through which the supplier can respond.

4.3. A notice that does not identify a specific basis for dispute, or that merely states that an invoice is under review, shall not suspend the payment period under the Standard.

4.4. A dispute shall be raised and handled in good faith. A buyer shall not raise a dispute for the purpose of extending payment, and a supplier shall not be required to accept a deduction or credit note that it has not agreed to or that is not otherwise authorized by applicable law.

4.5. The buyer shall pay any undisputed portion of an invoice within the applicable period. It shall not withhold the entire invoice where the dispute concerns only a separable part of the amount claimed.

4.6. The buyer and supplier should make a reasonable effort to resolve a dispute promptly. The existence of a dispute does not, by itself, determine whether the disputed amount is payable. The parties’ legal rights and any applicable contract or law continue to govern that question.

5. Interest when payment is late

5.1. Where an undisputed amount is not paid by the applicable due date, the adopter shall calculate and pay interest automatically on that amount for the period of delay, without requiring the supplier to make a separate demand.

5.2. The interest rate shall be no less favourable to the supplier than the rate required by applicable law or agreed in a more favourable contract. If neither applicable law nor the contract provides an interest rate, the adopter shall publish the rate it will apply under its commitment, together with the method and period used to calculate it.

5.3. Interest under this Standard shall not limit a supplier’s right to any statutory interest, compensation, cost recovery or other remedy available under applicable law. Where the law requires a different method of calculation, the adopter shall follow that law.

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5.4. The adopter shall show the principal amount, the period of delay, the rate and the interest paid in the remittance information or other account record made available to the supplier.

6. Continuation in Part 2

The annex continues with transparency and reporting obligations, a comparison of the legal and policy frameworks identified in the evidence before the Council, an implementation timeline and a review clause.

Footnotes

  1. Founders Assembly, Rules of Procedure, RC/A/2026/2. The Founders Charter is RC/A/2026/1.
  2. Cashflow Council, Call for evidence: Cashflow Council agenda item CF-001, RC/CF/2026/1; Interim pattern review: late payment to small suppliers, RC/CF/2026/N.1.
  3. Cashflow Council, Certification of the pattern test for CF-001, RC/CF/2026/N.2.
  4. United Nations, Micro-, Small and Medium-sized Enterprises Day.
  5. International Labour Organization, Micro, Small and Medium-sized Enterprises.
  6. Small Business Commissioner, “Late Payments Bill: what it could mean for your business”.
  7. European Parliament, Legislative Train, “Late payments: revision of the Late Payment Directive”.
  8. Legal 500, “Payments to Micro and Small Enterprises (MSEs): Implications under Section 43B(h) of the Income-tax Act, 1961”.
  9. Cashflow Council internal data as of 21 July 2026, as provided in the CF-001 evidence record.

7. Transparency and publication

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7.1. An adopter shall publish, in a place reasonably accessible to its small-business suppliers, the payment terms and practices that apply to those suppliers. The publication shall identify the relevant supplier category, the event from which the payment period runs, the process for raising an invoice query, the method for notifying a supplier of a dispute and the contact route for payment enquiries.

7.2. An adopter shall publish its standard payment period for undisputed invoices issued by small-business suppliers and state whether that period meets the 15-day commitment in this Standard. Where the adopter applies different terms to different supplier categories or transactions, it shall describe those differences in plain language and identify which terms govern each category.

7.3. An adopter shall publish the method it uses to calculate its payment-time figures. At a minimum, it shall explain the start and end points used, how it treats partial payments, credit notes, disputed invoices and invoices cancelled or reissued, and whether the published figure covers all small-business suppliers or only a defined group.

7.4. An adopter shall publish the proportion of eligible undisputed invoices paid within 15 days, the proportion paid later than 15 days, and the average and median number of calendar days between receipt of a valid invoice and payment. The adopter shall disclose the reporting period and number of invoices included. It shall not present a subset as representative of its full supplier base unless the basis for that representation is stated.

7.5. An adopter shall publish the amount of interest paid under section 5 during the reporting period and the number of invoices for which interest was due. If no interest was paid, the adopter shall state whether no late payment occurred or whether interest was not paid, and shall explain the distinction.

7.6. Publication shall protect personal information, confidential commercial information and information whose disclosure is prohibited by law. Any exclusion shall be limited to the information requiring protection. The adopter shall state that an exclusion was made and describe its scope without disclosing the protected information.

7.7. An adopter shall not describe itself as meeting this Standard solely because its written terms provide for payment within 15 days. Its public statement shall distinguish between its commitment, its measured performance and any limitations in the data.

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8. Records, reporting and supplier access

8.1. An adopter shall keep records sufficient to demonstrate how it has applied this Standard. Records shall include, as applicable, the date an invoice was received, the date it was accepted as valid, the date and nature of any dispute notice, the amount and date of each payment, and the calculation and payment of interest.

8.2. The adopter shall make a supplier’s own invoice and payment information available to that supplier in an accessible form. On request, it shall provide a clear account of the due date, any amount treated as disputed, the reason for that treatment, payments made and interest calculated. This obligation does not require disclosure of another supplier’s information.

8.3. The adopter shall designate a responsible contact or function for questions about the Standard. It shall acknowledge a supplier’s question within five business days and provide either a substantive response or a reasoned notice of when a substantive response can be expected. This acknowledgement period does not alter a payment due date or suspend any legal right or remedy.

8.4. The adopter shall review a supplier’s query concerning non-payment or underpayment of an undisputed amount promptly and in good faith. A request for information shall be relevant to resolving the query and shall not be used to restart the payment period or impose a new condition on payment.

8.5. At least once in each reporting year, the adopter shall make a public report addressing its performance against this Standard. The report shall state the reporting period, the coverage and method described in section 7, its results, and material steps taken to correct missed deadlines or recurring process failures. Where the adopter does not yet have a complete year of data, it shall identify the shorter period covered.

8.6. An adopter shall retain records supporting each public report for a period sufficient to permit meaningful review, subject to applicable law. It shall correct a material error in a published report without undue delay and preserve an accessible record of the correction and its date.

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8.7. Nothing in this section requires an adopter to publish a supplier’s identity, invoice, contract, bank details or other personal or commercially sensitive information. Public reporting shall ordinarily be aggregated. The adopter shall take reasonable steps to avoid disclosure by inference where a small number of transactions could identify a supplier.

9. Relationship to applicable law and voluntary commitment

9.1. This Standard is a voluntary benchmark for adopters. It does not amend, replace or determine the interpretation of any statute, regulation, contract or judicial decision. Compliance with this Standard does not establish compliance with applicable law, and a failure to meet this Standard does not by itself determine liability under law.

9.2. Where applicable law or a contract gives a supplier a more favourable payment term, interest entitlement or other protection, the adopter shall respect that protection. An adopter shall not rely on this Standard to reduce an existing legal or contractual right.

9.3. Where legal requirements differ between jurisdictions or transactions, the adopter shall identify and apply the governing requirements. The 15-day commitment in this Standard is not a representation that every legal system imposes a 15-day deadline.

9.4. The comparison below is limited to the legal and policy information identified in the evidence before the Cashflow Council. It is not a comprehensive survey, legal opinion or account of every rule that may apply in a jurisdiction. The frameworks described are not identical in scope, status or effect.

10. Comparison with frameworks identified in the evidence

Jurisdiction or frameworkPosition described in the evidenceRelationship to this Standard
European UnionThe evidence identifies a 2023 proposal for a Late Payment Regulation providing for a 30-day maximum period. The European Parliament set out its position in April 2024; the proposal was blocked in the Council. The evidence does not describe the proposal as an adopted regulation in force.4The proposal’s 30-day period is longer than the 15-day voluntary commitment. The proposed 30-day cap and this Standard are different instruments; the Standard does not assert that the proposal has become law.
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Jurisdiction or frameworkPosition described in the evidenceRelationship to this Standard
United KingdomThe Late Payments Bill was introduced in the House of Lords on 19 May 2026. As described in the cited material, it provides for a 60-day maximum term, mandatory interest at 8 per cent above the Bank of England base rate, and Small Business Commissioner adjudication and fine powers; import and export contracts are exempt from the cap.36The Bill, as introduced, is a legislative measure with a proposed 60-day maximum. The Standard’s 15-day commitment is shorter and voluntary. The Standard does not alter the Bill’s scope, status or any rights under applicable law.
Jurisdiction or frameworkPosition described in the evidenceRelationship to this Standard
IndiaThe evidence identifies section 15 of the Micro, Small and Medium Enterprises Development Act and section 43B(h) of the Income-tax Act. Micro and small enterprises are to be paid within 45 days where there is a written agreement and within 15 days where there is no such agreement. The evidence also describes a tax-deduction consequence under section 43B(h) and compound interest at three times the RBI bank rate for delay under the MSMED framework.5The statutory period described depends on whether there is a written agreement and may be longer than 15 days. The Standard makes a separate voluntary commitment for adopters and does not displace statutory interest or tax consequences.
Jurisdiction or frameworkPosition described in the evidenceRelationship to this Standard
JapanThe evidence before the Cashflow Council does not set out a Japanese payment deadline or other relevant legal requirements.No substantive comparison is made. Adopters operating in Japan remain responsible for identifying and complying with applicable Japanese law.
Jurisdiction or frameworkPosition described in the evidenceRelationship to this Standard
AustraliaThe evidence before the Cashflow Council does not provide a dated account, as of 21 July 2026, of an Australian statutory invoice deadline or a framework that can be compared on equivalent terms.No substantive comparison is made. Adopters operating in Australia remain responsible for identifying and complying with applicable Australian law.

10.1. The comparison is included to clarify the distinct purpose and level of commitment of this Standard. A national or regional rule may apply to a different class of transaction, supplier or buyer, and may provide enforcement mechanisms not created by this voluntary Standard.

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10.2. The Council shall not infer from the absence of detail in the table that no relevant law or policy exists in a jurisdiction. The table records only what was established in the material available to the Council.

11. Implementation timeline

11.1. An adopter that accepts this Standard shall identify a responsible executive or governing function and publish the scope of its commitment within 30 calendar days of acceptance. The publication shall identify the supplier categories covered, the effective date and a contact route for questions.

11.2. Within 90 calendar days of acceptance, the adopter shall review its invoice-receipt, validation, dispute, payment and interest processes against the Standard. It shall identify any operational changes required, including changes to supplier-facing terms, accounts-payable procedures, record keeping and reporting.

11.3. Within 180 calendar days of acceptance, the adopter shall apply the 15-day payment commitment to new and outstanding undisputed invoices within the scope of its commitment, subject to applicable law and the terms of this Standard. Where a material operational change cannot reasonably be completed within that period, the adopter shall publish the affected process, the reason for the delay and a dated plan for completion. A plan shall not be presented as achieved compliance.

11.4. Within 12 months of the effective date, the adopter shall publish its first performance report under sections 7 and 8. That report shall use the longest complete reporting period available after implementation and shall identify any period during which the adopter’s systems did not capture the required data.

11.5. An adopter may implement the Standard earlier. It may also make a public commitment covering only a defined part of its business, provided that the scope is clearly stated and the adopter does not imply that excluded operations are covered.

11.6. A supplier’s rights under applicable law or contract continue during implementation. The timeline does not defer a legal payment deadline, a contractual due date, or an obligation to pay interest that has already arisen.

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12. Review and revision

12.1. The Cashflow Council shall review this Standard no later than 12 months after its adoption by the Founders Assembly and at least once every two years thereafter. The review shall consider evidence received through reports, submissions, consultations, adopter reporting and other material made available to the Council.

12.2. A review shall assess whether the 15-day period remains clear and workable across different business sizes and transaction types; whether the definition and treatment of a dispute are preventing payment of undisputed amounts; whether interest is being calculated and paid as intended; whether transparency reports are comparable and useful; and whether implementation has created unintended burdens for small suppliers.

12.3. The Council shall apply the Assembly’s five-part pattern test—Volume, Frequency, Consistency, Spread and Corroboration—to any proposed material revision based on a claimed recurring problem. A review may also identify matters for which the evidence is insufficient and recommend further reporting or consultation rather than draw a conclusion.

12.4. Any proposed amendment shall be published as a draft, opened to public consultation, considered in light of the submissions received and submitted to an Assembly ballot in accordance with the Rules of Procedure. An amendment shall not be represented as adopted before the ballot has concluded.

12.5. The review shall preserve the distinction between a voluntary standard and legal requirements. It shall not state or imply that the Standard has been incorporated into law unless a competent legal instrument has in fact done so.

13. Interpretation

13.1. The headings in this annex are for ease of reference and do not alter the meaning of its provisions.

13.2. In this annex, “calendar day” means a day counted consecutively, including weekends and public holidays. Where the applicable legal system prescribes a different calculation for a legal deadline, that rule governs the legal deadline.

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13.3. If a provision of this Standard conflicts with applicable law, the adopter shall comply with the law and shall apply the Standard to the fullest extent consistent with that law. The adopter shall explain any resulting limitation in the scope or operation of its commitment.

14. Review of adoption and public claims

14.1. An adopter may state that it has adopted the Standard only after it has made a clear commitment identifying the scope and effective date. It shall distinguish adoption from demonstrated performance and shall not claim that adoption alone proves that invoices are consistently paid within 15 days.

14.2. The Secretariat may maintain a public record of commitments and published reports. Any such record shall distinguish the stages of commitment and reporting and shall not imply independent verification unless verification has occurred and its method is disclosed.

14.3. A claim concerning an adopter’s performance shall be supported by the adopter’s published reporting period and methodology. Where information is incomplete, the claim shall state that limitation. The Standard does not authorize the use of a supplier’s confidential information in public claims.

15. Commencement

15.1. This annex shall take effect for an adopter on the effective date it publishes under section 11.1, or on an earlier date it expressly identifies. Adoption by the Founders Assembly shall establish the Standard as the Assembly’s recommended benchmark; it shall not, of itself, create an obligation for a buyer that has not adopted it.

15.2. An adopter may withdraw its commitment by giving public notice and stating the effective date of withdrawal. Withdrawal shall not erase obligations that accrued before that date, alter a supplier’s existing rights or excuse the adopter from publishing its performance for the period during which the commitment applied.

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