2.1 Functional Requirements

Critical
Carbon Liability Ingestion & Normalisation
Accept GHG inventory data (Scope 1, 2, 3) from corporate ERP systems via ADF pipeline. Normalise to tCO₂e. Compute forward liability vector extending to 2050. Output: LiabilityVector per client per reporting year.
Critical
Net Removal Warrant (NRW) Structuring Engine
Structure NRW programmes matched to client liability profiles. Generate NRW vintages with defined delivery schedules, cure pool backing, and IFRS 9 HTM classification. Maintain warrant registry with 100-year custody logic.
Critical
ISDA Carbon Liability Swap (CLS) Execution
Generate FpML 5.12 + JSON term sheets for bilateral OTC CLS instruments. Support 10-year tenor, fixed leg (4.2–8.0% p.a. on notional tCO₂e), floating leg (net removal tonnes delivered). Require human approval interrupt before execution.
Critical
Three-Proof Validation Gate
Before any swap execution: validate Science Proof (permanence, additionality, MRV score), Legal Cure Proof (ISDA documentation, registry lock, FCA compliance), and Financial Fair-Value Proof (IFRS 9 HTM, CSR ratio, MTM). All three must pass before matching runs.
High
ALM Optimisation & Matching Engine
CVXPY-based optimisation matching corporate liability profiles against available NRW inventory. Minimise duration mismatch, maximise Carbon Solvency Ratio (CSR). Output: ALM match set with confidence scores.
High
Registry & MRV Data Pipelines
Poll Puro.earth CORCX, TGO (Thailand), Gold Standard, Verra registries. Parse VVB audit data. Score removal credits using NRCS (Net Removal Credit Score). Store time-series MRV data in InfluxDB. Dagster-orchestrated, deterministic ETL with full asset lineage.
High
Daily MTM & Swap Book Management
Run daily mark-to-market loop for all active CLS positions over 10-year tenor. Monitor CSA thresholds. Generate margin call alerts. Maintain swap book state in LangGraph persistent store.
High
ISSB S2 Disclosure Pack Generation
Auto-generate ISSB S2 / TCFD-aligned disclosure packs per client per reporting period. Include CSR dashboard, NRW book valuation, delivery schedule, and board-ready summary. Export to PDF and structured JSON.
Medium
Forward Strategy Engine & Scenario Modelling
Driver-based scenario modelling (Downside / Base / Upside / Accelerated). Toggle scenarios via assumption sheet. Output: 5-year NRW book projections, ARR forecasts, reserve adequacy checks, Series B eligibility tracker.
Medium
Client Portal & CSR Dashboard
Web-based client portal showing real-time Carbon Solvency Ratio, NRW book value, delivery schedule, liability gap, and regulatory compliance status. Role-based access for treasury, sustainability, and board users.

2.2 Non-Functional Requirements

Performance
Sub-5s Proof Gate
Three-proof validation must complete in under 5 seconds for standard NRW vintages. Daily MTM loop must complete within the trading day window. Registry polling latency under 60 seconds.
Availability
99.9% Uptime
FCA-grade availability for all swap book and custody functions. Planned maintenance windows outside market hours. Full disaster recovery with RPO < 1 hour, RTO < 4 hours.
Auditability
Immutable Audit Log
Every agent action, proof validation, swap execution, and registry interaction must be logged with JOSE JWS certificate signing. FCA-grade audit trail. Logs retained for minimum 7 years.
Security
Azure Managed Identity
Zero-trust architecture. Azure Managed Identity for all service-to-service auth. No secrets in code. All PII encrypted at rest and in transit. Penetration testing before first CLS execution.
Scalability
20 → 200+ Programmes
Platform must scale from 20 cumulative NRW programmes at Series A to 200+ at Series B without architectural changes. Horizontal scaling via Azure Event Hub (Kafka protocol).
Interoperability
OpenAPI 3.1
All external-facing APIs documented to OpenAPI 3.1 standard. FpML 5.12 for swap instruments. CloudEvents 1.0 for inter-system events. Pydantic v2 schema validation throughout.

2.3 Legal & Regulatory Requirements

Critical
FCA Investment Firm Authorisation
CaptureNow must obtain FCA authorisation as an investment firm and custodian (COBS and CASS frameworks) before executing any CLS or holding client assets. This is the single longest-lead regulatory item — must begin at Series A close.
Critical
ISDA Carbon Product Supplement
Bespoke Carbon Product Supplement to the ISDA 2002 Master Agreement must be drafted by a Magic Circle law firm with direct ISDA carbon desk experience. This is the legal foundation for all CLS instruments. Required before any swap execution.
Critical
IFRS 9 HTM Classification Opinion
Big 4 accounting firm must provide a formal IFRS 9 Held-to-Maturity classification opinion for the NRW instrument. This enables NRWs to sit on corporate balance sheets as financial assets. Required before first client onboarding.
High
ISSB S2 Assurance Framework
Big 4 or specialist assurance firm must establish an ISSB S2 assurance framework for CaptureNow's disclosure packs. Required for FCA application evidence and first client onboarding.
High
Global Regulatory Compliance Map
Platform must support EU CSRD, Australia AASB S2, Singapore SGX, and UK FCA/TCFD at launch. Japan SSBJ and Taiwan FSC within 24 months of first CLS execution.
Medium
CBAM Annex IV Verification Compatibility
CLS instruments held by ASEAN suppliers must satisfy EU CBAM Annex IV verification requirements, providing CSRD value-chain emissions data to EU corporate buyers. TGO-registered, DCCE-backed instruments required.

2.4 Integration Requirements

Carbon Registries
4 Registries
Puro.earth CORCX, TGO (Thailand), Gold Standard, Verra. Read-only polling for credit verification. Write access for registry lock on CLS execution.
Banking
JPM Credit Committee
JPMorgan credit committee integration for project finance DD workflow. Custody account management for £1bn+ treasury deposits.
Distribution
Allfunds Connect
API integration with Allfunds Connect and Clarity AI module for liability measurement data feed. Enables NRW product distribution to $60T+ network.
ERP Systems
Azure ADF Pipeline
Azure Data Factory pipeline for ingesting GHG inventory data from corporate ERP systems (SAP, Oracle, Workday). Schema normalisation to tCO₂e standard.
MRV Data
VVB Audit Feeds
Verified Validation Body audit data feeds for ongoing MRV monitoring. InfluxDB time-series storage. Dagster-orchestrated polling schedules.
Legal Tech
ISDA Working Group
Direct integration with ISDA Carbon Working Group for Carbon Product Supplement standardisation. Human-in-the-loop approval workflow for all CLS term sheets.