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Sustainability Briefing: The future of carbon markets

Are carbon markets at a turning point?

EU policy developments, Article 6 implementation and the recently released SBTi Corporate Net-Zero Standard V2.0 are creating clearer demand signals for high-integrity credits, eligible market instruments and credible removals. But growth is not guaranteed: Markets will only scale if supply quality, accounting, claims guidance, registry transparency and buyer governance mature together. Used poorly, carbon markets can delay direct abatement and enable misleading claims: used well, they can mobilize finance for additional reductions, system-level mitigation and removals. This article explores where carbon markets can credibly support corporate climate strategies and where they cannot replace real-economy decarbonization.

 Avoid, reduce, then compensate

The hierarchy is critical: Companies should first reduce emissions in their own operations and value chains. Where emissions arise from shared systems, activity-pool measures such as lower-carbon energy, materials or logistics may help. Carbon credits sit at a different level and shall not substitute for direct decarbonization.

Corporate climate action: reduce first, use market instruments carefully, and reserve carbon credits for defined claims. 1, 2 ,3 

Corporate priority

Reduce emissions across operations, purchased energy and value chains through efficiency, electrification, renewable energy procurement, supplier engagement, product redesign and logistics optimization. These reductions remain the core of credible corporate climate action and should be prioritized before considering external instruments.

Role of instruments/credits

Credits should not replace Scope 1, 2 or 3 reductions or be used to compensate for insufficient transition action. They may sit alongside a reduction strategy only where claims are clearly separated and do not imply progress toward value-chain decarbonization.

Corporate priority

Support decarbonization of shared systems such as power, materials, fuels, transport corridors or logistics infrastructure where no single company can transform the system alone. These measures can help shift sectoral supply, unlock lower-carbon alternatives and reduce upstream or downstream emissions over time.

Role of instruments/credits

High-integrity carbon credits, based on the applied regulation, resulting in eligible market instruments may support implementation if they are activity-linked, traceable to real system changes and governed by clear accounting rules. Their use should demonstrate how the financed activity contributes to sectoral decarbonization rather than simply purchasing generic offset claims.

Corporate priority

Financing mitigation measures outside the company’s value chain where projects deliver additional climate benefits beyond the firm’s own inventory. This can mobilize finance to underserved regions, sectors or technologies to enable emissions reductions, avoided emissions under robust baselines or removals.

Role of instruments/credits

Credits may support contribution claims or broader climate-finance narratives, but should remain separate from target achievement and not be presented as neutralizing the company’s own footprint. Buyers need transparent retirement procedures, conservative accounting and clear communication on what is being claimed.

Corporate priority

Address remaining emissions during the transition or at net zero after all feasible reductions have been pursued. This includes responsibility for residual emissions that are technologically or economically difficult to abate and may require a distinct governance approach over time.

Role of instruments/credits

High-quality removals may be relevant depending on the claim, timing, durability requirements and applicable SBTi rules. Companies should distinguish near-term responsibility, ongoing emissions responsibility and net-zero neutralization, and assess permanence, reversal risk, monitoring and liability before procurement.

Demand growth with higher standards

Demand is becoming more structural, driven by sovereign Article 6 cooperation, corporate transition planning and sectoral schemes. More countries reference internationally transferred mitigation outcomes in their NDCs4, the EU’s proposed 2040 climate framework signals limited use of high-quality international credits5, and CORSIA creates sectoral demand in aviation6. Carbon markets are therefore moving from a voluntary sustainability niche into climate policy, capital allocation and proactive risk management.

The recent SBTi Corporate Net-Zero Standard (CNZS) V2.0 reinforces this shift from our view while keeping credits separate from target achievement. Companies should ideally first reduce emissions, then use eligible market instruments only where they are activity-linked, traceable and support system decarbonization. For the newly defined and later mandatory Ongoing Emissions Responsibility (OER), supported mitigation shall be ex-post, assured, conservatively quantified, additional, protected against leakage and reversal risks, transparently governed and kept separate from target progress as described in the standard. Credits used for OER shall also be retired when claimed, not double claimed, and not reused for post-2035 responsibility or net-zero neutralization.

This requires a precise classification. Emission-reduction credits may support contribution claims or eligible compliance uses, while avoidance credits face even stronger baseline and additionality scrutiny. Nature-based removals offer co-benefits but require permanence, reversal and land-rights checks. Durable removals are most relevant for residual-emissions neutralization. Article 6-authorized, CORSIA-eligible and EU Carbon Removals and Carbon Farming Certification (CRCF)-certified units each follow distinct accounting and claims rules. Under the Article 6 of the Paris Agreement, setting rules for international cooperation through bilateral carbon trading, a central UN crediting mechanism, as well as non-market approaches, Article 6 authorization reduces double-counting risk but is not a full-integrity screen. Especially when considering Article 6.2: buyers still need due diligence, safeguards review, contractual protections and claims governance.

A new market architecture is taking shape based on three pillars

The voluntary carbon market has undergone a trust reset. Concerns around additionality, permanence, leakage, weak baselines, double counting and misleading claims have pushed standards and buyers toward stronger integrity rules. The Integrity Council for the Voluntary Carbon Market’s (ICVCM) Core Carbon Principles benchmark high-integrity credits7, while the VCMI Claims Code guides credible claims beyond science-aligned emissions cuts.3

Article 6 is creating a second pillar: Article 6.2 enables country-to-country cooperation via internationally transferred mitigation outcomes, while Article 6.4 establishes the UN-supervised Paris Agreement Crediting Mechanism. The first approved Paris Agreement carbon market issuance in February 2026 marked a shift from rulemaking toward operational supply.9

Still, Article 6 authorization and corresponding adjustments are only accounting conditions. Buyers need due-diligence frameworks for baseline integrity, over-crediting, registry reliability, safeguards, reversal liability, contracts and claims: especially for forest and land-sector activities. The Article 6 framework could bridge international supply and European demand if it combines Paris Agreement accounting with integrity principles from voluntary and compliance markets. EU-level rules could reduce fragmentation and clarify criteria for origin, quality, acquisition and use.10

Alongside this, the EU CRCF framework is emerging as a quality infrastructure for adopting methodologies under the framework for permanent removals, carbon farming and carbon storage in products11.    Its overall relevance will depend on certification credibility and clarity on use cases, claims, duration and risk-sharing. 

A three-pillar carbon market architecture is emerging within Europe
Governance

Private standards, project methodologies, registries, independent ratings and buyer guidance from ICVCM and VCMI shape quality expectations. Governance is increasingly focused on additionality, conservative baselines, monitoring, safeguards, transparent retirement and credible claims rather than simple offset availability.

Typical use

Typical uses include contribution claims, beyond value chain mitigation and voluntary climate-finance commitments that complement, but do not replace, science-aligned emissions reductions. Companies may use these instruments to channel finance toward mitigation outcomes with clear quality controls and transparent communication.

Key buyer question

Is the credit genuinely high quality, independently verified and suitable for the intended claim? Buyers need to test additionality, quantification, permanence, leakage, safeguards, double-claiming risk and whether public communications avoid implying compensation where only contribution is appropriate.

Governance

Paris Agreement accounting, host-country authorization, corresponding adjustments and national reporting rules govern how internationally transferred mitigation outcomes are counted. Article 6.2 enables bilateral or cooperative approaches, while Article 6.4 establishes an UN-supervised mechanism with evolving methodologies and oversight.

Typical use

Typical uses include sovereign cooperation, NDC-linked mitigation, climate-finance partnerships and potentially corporate procurement where authorization, accounting and claims rules are clear. These units can connect international supply with policy-driven demand but still require project-level integrity checks.

Key buyer question

Is the unit properly authorized, transparently recorded and adjusted so that double counting is avoided? Buyers should also ask whether host-country approvals, registry infrastructure, contractual provisions and claims language are robust enough for the intended use.

Governance

Scheme-specific eligibility rules determine which units can be used, from CORSIA criteria in aviation to possible future EU rules for limited post-2030 international credit use. These frameworks may include requirements on origin, vintage, authorization, safeguards, methodology and registry treatment.

Typical use

Typical uses include aviation compliance under CORSIA and potential contribution to the EU 2040 climate framework from 2036, subject to strict conditions. Such use cases are narrower than voluntary claims and depend on scheme recognition, eligibility lists and compliance timelines.

Key buyer question

Does the unit meet the relevant scheme criteria on eligibility, origin, quality, safeguards, authorization and timing of use? Buyers also need to track rule changes, documentation requirements and whether units remain valid throughout the compliance or reporting period.

Quality and use-case clarity are becoming decisive

Carbon markets will depend less on volume and more on quality, claim integrity and suitability. Companies should not treat market instruments, credits, removals and offsets as interchangeable: Market instruments may support target implementation if activity-linked, credits may support contribution claims, and removals may be relevant for residual-emissions or OER claims as clarified in the CNZS V2.0.

Buyers, in our opinion, need to thoroughly test whether units are additional, conservatively quantified, independently verified, uniquely claimed, protected against double counting and matched to a permissible use case. For removals, durability, reversal risk, monitoring and liability matter. For nature-based units, safeguards, permanence, land rights and biodiversity impacts require attention.

The resulting use-case logic for different credit types is summarized in the following.2, 3, 6, 7

Companies need to match credit types to use cases
Suitable credit characteristics

High-integrity reductions or removals that are additional, conservatively quantified, independently verified, uniquely claimed and supported by credible safeguards. Priority should be given to units with transparent methodologies, robust baseline setting, clear ownership and a strong link to mitigation outcomes beyond the company’s own value chain.

Claim considerations

Claims should be framed as contribution, not compensation for the company’s own emissions. Communications should explain what has been financed, why it is outside the value chain and how the claim is kept separate from target achievement or footprint neutralization.

Key risks

Key risks include overclaiming, weak project quality, non-additional outcomes, leakage, double claiming and reputational exposure if the financed mitigation is presented as offsetting corporate emissions. Buyers need strong diligence and claims governance before public use.

Suitable credit characteristics

Durable removals with strong monitoring, reporting and verification, long-term storage confidence and clear liability arrangements. Suitable units should demonstrate permanence, conservative quantification, transparent storage pathways and credible provisions for reversal management or replacement.

Claim considerations

Use should be limited to residual emissions remaining after deep decarbonization at net zero. Claims should not imply that removals compensate for avoidable emissions before credible reduction pathways have been exhausted.

Key risks

Key risks include scarcity of durable supply, delivery delays, high costs, technology performance uncertainty, permanence risk and evolving standards. Early procurement should manage offtake risk, portfolio diversification and evidence requirements for future claims.

Suitable credit characteristics

A portfolio of high-quality credits, removals and climate-finance instruments may be needed to address ongoing emissions responsibility over time. The portfolio should balance near-term mitigation impact, durability, geographic and technology diversity, safeguards and alignment with emerging SBTi requirements.

Claim considerations

Claims should remain separate from target achievement and should make clear that the company is taking responsibility for ongoing emissions rather than using credits to meet reduction targets. Retirement, assurance and transparent reporting are essential.

Key risks

Key risks include evolving SBTi guidance, uncertainty on eligible instruments, double-use restrictions, insufficient assurance and confusion between OER, BVCM, and neutralization claims. Governance should remain flexible as standards mature.

Suitable credit characteristics

Scheme-eligible units that meet the applicable methodology, vintage, authorization, registry and safeguard requirements. Eligibility may depend on the specific compliance period, approved program list and whether host-country accounting treatment is recognized by the scheme.

Claim considerations

Claims and use should ideally follow scheme rules exactly, including surrender, reporting, documentation and communication requirements. Companies should avoid extending compliance eligibility into broader voluntary claims unless the scheme explicitly permits it.

Key risks

Key risks include changing eligibility rules, unclear authorization status, registry mismatches, timing constraints and invalid use outside the scheme’s defined boundaries. Buyers should monitor rule updates and maintain evidence for audits or compliance reviews.

Suitable credit characteristics

Strong additionality, traceability and activity-level evidence are essential, particularly where programs relate to supplier engagement, sectoral transformation or Scope 3 interventions. Units or instruments should show a clear connection to real reductions without overstating attribution to one buyer.

Claim considerations

Claims must avoid double counting with Scope 3 reductions, supplier inventories or sectoral accounting frameworks. Companies should distinguish financing, procurement, insetting-like interventions and verified inventory impacts before communicating results.

Key risks

Key risks include attribution uncertainty, complex accounting boundaries, supplier data gaps, double claiming across customers and difficulty proving additionality. Robust contractual terms, data controls and claims review are needed before scaling these programs.

Where the market goes next and why early movement matters

Carbon markets have significant potential, but the next phase will be more selective. EU policy, Article 6, CORSIA, SBTi CNZS V2.0 and transition planning point toward rising demand for high-integrity credits, eligible market instruments and credible removals.

Growth will only be credible if supply quality, accounting, claims guidance, registry transparency and buyer governance mature together. Low-integrity credits and vague offsetting claims will remain under scrutiny, while high-integrity nature-based credits, methane abatement and durable removals may see stronger demand.

For companies, this creates a practical agenda. The winners are expected to be those that build the capabilities to decide when, where and how carbon markets can support their transition strategy:

  • Define where credits, market instruments and removals fit and where they do not.
  • Keep direct reductions and value-chain transformation first.
  • Separate target implementation, BVCM, OER and neutralization claims.
  • Set your ambition level and quality thresholds before procurement starts.
  • Assess future removal needs and post-2035 responsibility sooner than later and learn during that process.
  • Track SBTi, Article 6, EU and sectoral rules.
  • Engage credible suppliers before high-integrity supply tightens.

The upcoming EU framework for high-quality international credits and possible use toward the EU’s 2040 target will be a key test. If narrow, transparent and integrity-led, it could scale Article 6 supply and climate-finance infrastructure. If perceived as weakening domestic action or relying on weak credits, it could deepen the market’s trust deficit.

Carbon markets are not returning as a license to offset. They are being rebuilt around integrity, transparency and disciplined claims. Companies need to understand where market instruments support real-economy decarbonization, where credits can finance credible climate action beyond the value chain, and how removals should be prepared for residual or ongoing emissions responsibility. Early movers that build governance, quality filters and supply strategies now will be better positioned as demand rises and credible supply tightens. The next step is a structured assessment of use cases, exposure, quality requirements and procurement options.

"Carbon markets are at the stage gate to fast-scale the transition - integrity will define their success. The organizations that act now will help shape the rules of the market, not just react to them."

Nicole Röttmer, Partner, Strategy, Risk & Transactions

 

Authors:

Frederic Wils, Senior Manager | Strategy, Risk & Transactions
Noah Winneberger, Manager | Strategy, Risk & Transactions

 1UNEP. (2025): Emissions Gap Report 2025. Accessed July 13, 2026. 

2Science Based Targets initiative. (2026): Corporate Net-Zero Standard Version 2.0. Accessed July 13, 2026. 

3Voluntary Carbon Markets Integrity Initiative. (n.d.): Claims Code of Practice. Accessed July 13, 2026. 

4UNFCCC. (2025): 2025 NDC Synthesis Report / FCCC/PA/CMA/2025/8. Accessed July 13, 2026. 

5European Commission. (2026): Call for Evidence for an Impact Assessment. Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law. Ref. Ares (2026)1416921. Accessed July 13, 2026. 

6ICAO. (2026): CORSIA Eligible Emissions Units. April 2026 edition. Accessed July 13, 2026. 

7Integrity Council for the Voluntary Carbon Market. (n.d.): Core Carbon Principles. Accessed July 13, 2026.

 8UNFCCC. (n.d.): Article 6.4 Supervisory Body / Paris Agreement Crediting Mechanism. Accessed July 13, 2026. 

9UNFCCC. (2026): UN carbon market approves first-ever issuance of credits under the Paris Agreement. Accessed July 13, 2026. 

10European Commission. (2026): Legal framework for the possible use of international carbon credits towards the 2040 EU climate law target. Reviewed stakeholder submissions. Accessed July 13, 2026. 

11European Commission. (2024): Regulation (EU) 2024/3012 establishing a Union certification framework for permanent carbon removals, carbon farming and carbon storage in products. Accessed July 13, 2026. 

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