The Six C's of COVID-19 Recovery Efforts

Co-authored by Dorjee Sun, Co-founder of AOKpass, Special Advisor to International Chamber of Commerce, WEF Young Global Leader, TIME “Hero of the Environment,” serial social and technology entrepreneur and committed conservationist, and Darren Toh, Co-founder of AOKpass, veteran regulatory lawyer for the Australian Commonwealth, senior investigator, advisor to several blockchain projects, and committed conservationist.

As the world moves toward a controlled easing of COVID-19 restrictions, the focus is now shifting from containment to recovery. In the immediate aftermath of unprecedented social and economic restrictions, a clear and practical plan for resuming commercial activity is absolutely critical. While governments and businesses explore options, the International Chamber of Commerce (ICC) has created the ICC AOKpass system and mobile application to provide a standardized approach to risk management and compliance in the context of COVID-19 recovery efforts. 

Essentially, the ICC AOKpass system creates a standardized technical framework to enable the easy verification of individuals’ specific compliance status, without infringing the privacy of their personal health data. While COVID-19 compliance criteria will almost certainly be based on individual health information, ICC AOKpass is not intended to create a medical standard, but a technical privacy-preserving standard that can be applied across all jurisdictions and industries in full compliance with local data protection laws. In short, the ICC AOKpass system is designed to implement whatever COVID-19 compliance standards are ultimately adopted, based on medical science, government regulation and best practice as they evolve. 

The importance of ICC AOKpass for international recovery efforts can be best understood with reference to the essential Five C’s. While there is considerable overlap, each provides insight into a vital area needed for the practical implementation of recovery measures.


In the absence of clear international leadership by the United States, G20, United Nations or any other global influencer, a lack of certainty is resulting in separate and conflicting approaches to the reopening of borders. For example, Japan has imposed a blanket ban on inbound travelers from 110 countries while countries such as Italy, Greece, Portugal and Spain (which rely heavily on tourism) are re-opening their borders with more limited or as yet undefined restrictions. 

Putting aside the risk of COVID-19 resurgence, this creates substantial new barriers to cross-border trade and travel. With uncertainty comes the enormous inefficiencies and duplication costs resulting from disparate and often incompatible COVID-19 compliance systems. Multinational companies with global operations are likely to be hard hit as they grapple to meet a conflicting and ever-changing range of compliance requirements.

As a credentialing tool, ICC AOKpass provides certainty by establishing a unified digital standard for verification of individuals’ COVID-19 compliance status while protecting the privacy of their personal health data; this may include self-declarations, testing results and ultimately vaccinations as these are developed. With this greater certainty, businesses can more efficiently develop and deploy their individual recovery efforts. 


Essential to all successful recovery efforts is confidence that citizens are not still exposed to an unreasonable risk of infection. The Wuhan reopening serves as a perfect example: as lockdowns were lifted many citizens remained unsure whether COVID-19 risks were sufficiently reduced, resulting in a muted transition to recovery. While the local government knew that cases of infection had been very substantially reduced, they stimulated greater confidence by administering over 6.5 million tests and publishing the results (only 200 positive cases were shown). These actions serve as a powerful confidence-builder reassuring citizens that they can more safely return to public life. 

At the national level, the easy verification enabled by ICC AOKpass creates greater confidence among compliant individuals to return to work, study, travel or other public interactions. Similarly, businesses (including events, F&B outlets, malls and other public venues) can build confidence by instituting self-declaration and/or testing requirements for their employees and customers to demonstrate that they are ‘COVID-19 safe’. 


Regardless of what recovery measures ultimately look like, the exercise of (self) control by individuals will remain essential in the absence of universally accepted testing or a vaccine. Self-assessment is integral to recovery frameworks such as the ‘Roadmap for Restarting Aviation’ framework being developed by international industry bodies such as the International Air Transport Association (IATA) and Airports Council International (ACI). A central feature is the responsibility of individuals to self-assess and abstain from travel where symptoms are observed. The World Tourism & Travel Council (WTTC) is also developing a set of standard operating procedures for travel-related businesses and customers, which applies self-assessment. 

The management of these types of self-reporting systems would be greatly simplified by the digital standards established by ICC AOKpass to allow the private verification of individuals’ COVID-19 compliance via regularly completed self-assessments. These may be validated (or ‘attested to’) by authorized medical professionals, authorities or other trusted third-parties. 


As with all modern commerce and trade, businesses and other institutions require downside protection (insurance) that recognizes and calculates the novel risks in a post-pandemic world. COVID-19 creates unprecedented legal challenges and liabilities that organizations must consider. For example, US retail giant Walmart is being sued by the family of an associate who was allegedly infected with COVID-19 while at work. In Australia, criminal prosecutions are being considered for deaths in aged facilities that allegedly resulted from infected staff. Liabilities against the risk of infection as we move toward the resumption of public life will be an ongoing concern across all sectors, communities and other ecosystems. 

How organizations factor in such new threats is now being explored by ICC AOKpass in collaboration with leading insurance players such as AONSwiss Re and the Pan-Asia Risk & Insurance Management Association (Parima). ICC AOKpass supports more informed risk management to reduce exposure to potential liabilities associated with a return to commercial and public activities. Reduced premiums based on risk mitigation enabled by ICC AOKpass may also be possible.


At the heart of all the C’s above, is the need for international and multilateral cooperation. The intrinsic inefficiencies, duplication and significant additional costs of many different standards will create new barriers to trade, commerce, travel and any cross-border activity at scale. The current breakdown in multilateral coordination presents a substantial challenge to achieving the vital cooperation needed for the other C’s above. 

This is where ICC comes to the fore as the world’s largest not-for-profit business institution representing over 45 million businesses and 1.2 billion employees in more than 100 countries. With an established role over the last 100 years in global standard-setting, promulgation and enforcement for international trade, banking and other key sectors, ICC is uniquely positioned to establish a new international consensus for a unified COVID-19 technical compliance framework. 

Already partnered with the World Health Organization (WHO) to help coordinate the private sector response to COVID-19, ICC is also formalizing partnerships with other highly influential multilateral bodies such as International Organization for Standardization (ISO), International Road Transport Union (IRU) and the plethora of others representing entire industries internationally. ICC has already also joined efforts with International SOS (the world’s largest medical and security services firm) and SGS (the world’s leading inspection, verification, testing and certification company) as founding partners to assist in development, distribution and ongoing support. 

Examples of consensus building including ongoing discussions with countries to adopt standard protocols under ICC AOKpass for the verification of inbound travelers’ swab test results. With a growing number of other countries requiring inbound passengers to be tested on arrival (currently including Austria, Czech Republic, Greece, Estonia, Iceland, Portugal, Slovakia and Slovenia), there is a clear need for an interoperable global standard for the recognition and verification of testing COVID-19 results. 

The All Important Sixth C – Confidentiality

Beyond the five essential C’s above, confidentiality is what truly sets ICC AOKpass apart. Its privacy-preserving design positions it as the world’s first practical COVID-19 compliance standard to support global recovery, which can be applied in any industry and jurisdiction immediately. Free of privacy concerns that plague other solutions and designed to integrate any compliance standards ultimately adopted by countries, businesses and organizations, it is designed to adapt to any new medical, regulatory and corporate requirements as they emerge. 

ICC has launched its Declaration for COVID-19 Health Data Protection, which outlines the commitment of ICC AOKpass to the preservation of the individual right to privacy:

“Urgent global action is needed to address the threat posed by COVID-19 to both lives and livelihoods. However, this must not be used as a pretext to infringe individuals’ health data privacy rights. Working with key industry leaders, we will strongly support COVID-19 compliance standards and systems guided by the principles of strict data privacy,” said John W.H. Denton AO, Secretary General of ICC.

In a post-COVID-19 world, private individual health data is likely to be used more transactionally (potentially multiple times daily). ICC AOKpass deploys a unified global standard to more safely and efficiently mitigate many of the social, economic and health-related risks, while preserving the individual right to privacy. 

Ultimately, as the world emerges from lockdowns, constant vigilance will be a common feature of daily life for the foreseeable future. The adoption of essential standardized tools, such as ICC AOKpass, will at least allow us to forge a safer and more efficient path to recovery.

The views and opinions expressed herein are the views and opinions of the author and do not necessarily reflect those of Nasdaq, Inc.

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