Another reason why PoAs have had limited success so far is that the framework still depends on CDM methodologies which are developed mostly with a project design in mind. Thus, in most of the cases these involve complex monitoring and a relatively fixed baseline, which is often difficult to translate into a "programmatic" approach.
Another complexity is to define a suitable entity that represents the whole program, such as a program sponsor, that connects the technology providers with the users and is able to both handle the transfer of the legal title to the emission reductions as well as the monitoring of these reductions. Often, companies or institutions will face barriers to handle efficiently all the actors involved in this process.