I think I have the answer to this.
The first thing to note is that the first category of persons is really the 700 large final emitters that are spelled out elsewhere.
However, if one goes back to proposed paragraph 94.1(1)(b), which prescribes the creation of the domestic offset system that includes the requirement for and the issuing and trading of transferrable carbon credits for incremental and verifiable annual greenhouse gas emissions reductions, those credits are beyond the 700 polluting entities and may come from a not-for-profit organization or municipality, but they are subject to a couple of constraints. First they have to be incremental and verifiable. Second—and this is in anticipation of one of the comments that was made earlier about the European system—the government may wish to make sure that in the total issuing of credits, it doesn't inadvertently flood the market, which is what happened in Europe.
So I think the answer to your question is yes, because of the offset provision, credits will not be issued to just any old entity or person. They will have to demonstrate that they are incremental and verifiable.
I hope that helps.