From farm to Europe: addressing the challenges of scaling carbon schemes

From farm to Europe: addressing the challenges of scaling carbon schemes D2.2 Project CREDIBLE: “Building momentum and trust to achieve credible soil carbon farming in the EU”. Funded by the European Union under the Grant Agreement nº 101112951. DISCLAIMER: This report reflects a collaborative effort among diverse stakeholders and does not imply unanimous agreement on all points. Diverging views may exist among contributors. It has been prepared on a voluntary basis by members and contributors to Focus Group 2.2 titled “What is the best scale for a carbon certification framework?” within the Horizon Europe CREDIBLE project. The report does not constitute a binding position and should be considered as a constructive contribution to the ongoing CRCF policy development process. The views expressed in this document are the sole responsibility of the authors and do not necessarily reflect the views or positions of the European Union, nor those of the institutions or organisations to which the authors or the contributors are affiliated. Neither the authors, the contributors, nor the CREDIBLE consortium can be held responsible for any use that might be made of the information contained herein. 2 Document information GRANT AGREEMENT Nº 101112951 Project title Building momentum and trust to achieve credible soil carbon farming in the EU Project acronym CREDIBLE Project duration 36 months Coordinator SAE Related work packages(s) WP2 Related task(s) T2.2 Lead organisation AC3A (Association des Chambres d'Agriculture de l'Arc Atlantique, FR) Contributing partner(s) I4CE (Institute for Climate Economics, FR) EEB (European Environmental Bureau, BE) Due date 30/09/2025 Submission date 1/10/2025 Dissemination level Public (PU) Authors ● Clara DIEBOLT, AC3A ● Claudine FOUCHEROT, Chamber of Agriculture of Normandy (CAN) ● Julia GRIMAULT, I4CE ● Simon MARTEL, I4CE History Version Date Description Reviewed by V1 13/08/2025 First draft Tristano Bacchetti De Gregoris (SAE) Dominika Skoneca (SAE) V2 01/09/2025 Second draft Hugh McDonald (Ecologic) Hannes Mollenhauer (UFZ) V3 01/10/2025 Final version Tristano Bacchetti de Gregoris (SAE) Dominika Skonecka (SAE) 3 Table of content Acknowledgements 3 Executive Summary 4 List of acronyms and abbreviation 7 Project summary 8 Introduction 10 Towards an optimal scale of governance for robust and viable schemes 11 1. Context: a developing regulatory framework 11 2. Challenges tackled by the Focus Group 2.2 12 3. Gouvernance of the Focus Group 2.2 13 4. Methodology to collect insight 14 Main outcomes from the Focus Group 16 1. Stakeholder Perspectives on Certification Governance 16 Methodology development and validation 17 GHG assessment tools and models 20 Project validation 21 Auditors accreditation and registry 23 2. Towards a Shared Vision for CRCF Governance 26 Panel and Audience Reflections 26 Key Challenges Identified 27 Recommendations from the Session 28 Outputs from the Focus Group 29 Final recommendations 30 References 32 4 Acknowledgements The authors would like to express their sincere gratitude to all members and contributors to Focus Group 2.2 of the Horizon Europe CREDIBLE project, titled “What is the best scale for a carbon certification framework?” who generously contributed their time, expertise, and perspectives. Their commitment has been instrumental in shaping the recommendations presented in this report. We particularly acknowledge the valuable insights shared by contributors during the online survey and expert consultations or workshops at the EU Carbon Farming Summits in Valencia and Dublin. Special thanks are extended to our partners from the CREDIBLE project who reviewed the deliverable: Hannes Mollenhauer from the Helmholtz-Zentrum für Umweltforschung GmbH, Hugh McDonald from the Ecologic Institute and Tristano Bachetti de Gregoris and Dominika Skonecka from Soluciones Agricolas Ecoinnovadoras. 5 Executive Summary Purpose This deliverable contributes to the CREDIBLE project’s overarching goal of fostering trust and momentum for carbon farming in the European Union. Specifically, it addresses the issue of scaling carbon certification schemes from farm to national and EU levels. The report presents the findings of Focus Group 2.2, which was tasked with exploring the optimal scale of governance for a robust and viable carbon certification framework in Europe. It aims to inform the development and implementation of the Carbon Removals and Carbon Farming (CRCF) regulation by providing stakeholder-driven recommendations on governance, methodologies, certification processes, or registry design. Intended audience This document is intended for policymakers at EU and national levels, particularly those involved in climate action, agricultural policy, and environmental governance. It is also relevant to certification bodies, project developers, researchers in climate and land-use sciences, and land managers engaged in carbon farming across agricultural, forestry, and wetland sectors. The insights and recommendations herein are designed to support decision-making processes related to the design and implementation of carbon certification schemes under the CRCF. Description of the main activities Focus Group 2.2 was coordinated by AC3A and I4CE and brought together a diverse range of stakeholders, including public institutions, NGOs, researchers, and private actors: project developers, existing standard representatives, auditors, MRV providers. The group conducted a series of consultations between September 2023 and July 2025. The methodology combined qualitative and quantitative approaches. Initial discussions explored experiences with existing schemes such as the French Label Bas-Carbone 1 . Then, a survey was designed to assess preferences and risks associated with different governance scales. The survey targeted carbon certification and carbon farming experts. The results were analysed alongside findings from another European project called VERTA 2 and debated in multi-actor settings. This iterative process ensured that the 1 The Label Bas-Carbone (‘low carbon label’) is the first voluntary climate certification framework in France, allowing to certify greenhouse gas emission reduction and carbon sequestration projects in all sectors (forestry, agriculture, transport, construction, etc.) 2 VERTA is a EU project laying out suggestions on the implementation rules and the registry of the CRCF. 6 recommendations were grounded in practical experience and reflective of diverse perspectives across Europe. Key results Result 1: The various certification governance options involve different transaction costs, which should be better assessed when designing the CRCF. This is a major issue because there is a risk that a significant share of transition funding could be diverted to these transaction costs. This issue is discussed in the context of debates on monitoring (e.g. the level of monitoring accuracy with the number of indicators collected or the tool used: model vs. direct measurement vs. remote sensing) and less in terms of the appropriate level of centralisation. A more decentralised approach—particularly regarding methodology— allows for local history and specificities to be taken into account and fosters bottom-up innovation. However, the more decentralised the approach, the higher the transaction costs. Result 2: Experience with existing carbon certification standards shows that economic operators often exploit loopholes in methodologies and comparing the adequacy of different methodologies and tools is challenging. A model/tool validation step is therefore needed to ensure compliance with the methodology. Independent consultants and researchers should play a key role in reviewing the entire process and evaluating whether the assigned objectives have been achieved—beyond the work of auditors. This role should not be underestimated by the Commission. Research and practice implications It would be useful to evaluate the transaction costs associated with the different CRCF governance scenarios in order to guide the selection of the most appropriate option. These costs should include fees for consultants and researchers responsible for reviewing methodologies and proposed MRV tools, as well as expenses for auditors— which can increase significantly in highly decentralised scenarios. Clarifying the governance process could also help existing standards identify ways of becoming part of the CRCF, for example as certification schemes. 7 Policy implications DG CLIMA should ensure that the CRCF remains sufficiently centralised to provide harmonised rules across the EU while still taking local contexts into account. It should also assess the associated transaction costs, which tend to increase with the level of flexibility granted to stakeholders. In addition, it is crucial to allocate an adequate budget to remunerate independent experts and consultants for scrutinizing methodologies, conducting project checks, and overseeing certification bodies (auditors). Conclusion The analysis showed that there are several levels of governance for the different components of carbon certification (methodology, tools, auditing, project validation, registry). An assessment of the benefits and risks associated with these scenarios was carried out, and the findings suggest that transaction costs and the need to limit loopholes argue in favor of a centralised framework. However, safeguards have been proposed with a view to adapting to local contexts and promoting innovation. 8 List of acronyms and abbreviations CF: Carbon Farming CRCF: Carbon Removals and Carbon Farming DG CLIMA: Directorate-General for Climate Action EC: European Commission EU: European Union FG: Focus Group GA: Grant Agreement GHG emission tools: Greenhouse gas emissions reduction calculators using models and parameters provided by methodologies and protocols. Label Bas-Carbone: a voluntary climate certification framework in France, led by the Ministry for the Environment, certifying GHG emission reduction and carbon sequestration projects in all sectors (forestry, agriculture, transport, construction, etc.). LULUCF: Land Use, Land Use Change and Forestry MRV tools: Monitoring-Reporting-Verification tools, interface integrating the certification rules defined in the methodology: additionality, quantification, permanence management tools, monitoring over time, audit reports, etc. MS: Member State NGO: Non-Governmental Organisation SO: Specific Objective UNFCCC: United Nations Framework Convention on Climate Change VERTA: CRCF VERification Technical Assistance. The VERTA project has been conducted throughout 2024 to support the Commission to develop implementation rules for the verification of carbon removals under the CRCF and to start the process of scoping an EU-wide registry for carbon removals WP: Work Package 9 Project summary This deliverable is part of the EU-funded project under the topic HORIZON-MISS-2022SOIL-01-06, titled: Building momentum and trust to achieve credible soil carbon farming in the EU (project acronym: CREDIBLE, Grant Agreement #101112951). The main goal of the CREDIBLE project is to build momentum and trust for the implementation of carbon farming in the EU. This has been primarily achieved by setting up and moderating a network of initiatives/projects/stakeholders for favouring transparency, environmental integrity, and methodology standardisation in soil carbon accounting. Such a network is responsible for pushing forward multiple discussions (articulated around three main themes: which practices; what standards; how to monitor) and is expected to evolve from a mostly technical/scientific network at the onset of the project, into a process catalysing policy making and business innovation toward its end. The transparent, open access, multi actor dialogues required to build trust and co-create solutions is orchestrated around three annual European Carbon Farming Summits, which present opportunities for the network to interact with the broader stakeholder community and grow to the point it would attract further fundings for long term sustainability. Through the action, four specific objectives (SO) are achieved: SO1) to build and disseminate a practical toolbox for promoting carbon farming, capable of taking into account local land uses, best practices, and multi-actor interests; SO2) to identify options for benchmarking and selecting standards, certification mechanisms, and policy instruments for carbon farming; SO3) to favour the establishment of a network of soil carbon data collectors and repositories to improve measuring and monitoring carbon dynamics; SO4) to build up processes and tools to drive conversations for the upscaling of carbon farming. CREDIBLE’s ambition is to support the European Commission and the Expert Group on Carbon Removal in the identification and upscale of solutions for soil carbon farming. Tables 1 and 2 provide further information on the structure and composition of the project. 16 May to October 2024 – Survey dissemination: Online survey completed by 23 experts from 13 countries on governance preferences and risks. Objective: Identify consensus areas, tensions, and paths forward for CRCF governance. February 2025 – Cross-analysis of survey results: Integration of survey findings with conclusions from the VERTA7 project. Objective: Refine recommendations using the latest technical and policy insights. 10 February 2025 Session with FG members to validate and finalize policy recommendations. Objective: Prepare contributions for the EU Carbon Farming Summit in Dublin. March 2025 – Presentation at the EU Carbon Farming Summit in Dublin: Public presentation of FG 2.2’s recommendations. Objective: Influence the development of the CRCF with stakeholder-informed proposals. June – July 2025 – Feedback on the CRCF draft implementing regulation: FG 2.2 contributed to a collective feedback note analyzing the EC draft regulation. Objective: Provide concrete recommendations on governance, methodologies, MRV tools, project validation, and registry design. July - September 2025 - Final deliverable from the FG Objective: assess the implications of different levels of governance (European, national, local) for carbon certification, by analysing the strengths and limitations of centralised and decentralised approaches and providing concrete recommendations Main outcomes from the Focus Group 1. Stakeholder Perspectives on Certification Governance This section presents the main findings and recommendations of Focus Group 2.2 for each key component of the carbon certification framework. To explore these questions, the group analysed the risks and benefits of three theoretical governance scenarios under the future European framework, across key certification components: 7 This VERTA project has been conducted throughout 2024 to support the Commission to develop implementing rules for the verification of carbon removals under the CRCF and to start the process of scoping an EU-wide registry for carbon removals. https://climate.ec.europa.eu/document/download/45708194-a447-46c7-8f81cc96d621b490_en?filename=event_20250205_crcf_registry_rules_report_en.pdf 17 ● Methodology development and validation, ● GHG assessment tools, ● Project validation, ● Auditors’ accreditation ● and registry management. The three scenarios (from most centralised to most decentralised) are: Scenario A | European Level A highly centralised model where most certification components are developed and approved at EU level. Common methodologies, tools, and a single registry are used across Europe. Existing standards may either act as validators under EU methodologies or compete with the European framework on overlapping scopes (e.g. carbon sequestration, N₂O emission reductions). Scenario B | National Level Member States play a central role. Methodologies, project validation, auditor accreditation, and registry management are delegated to national authorities. This mirrors the current French Label Bas Carbone (LBC) model, which would need to evolve to align with CRCF rules. Other Member States would also need to engage similarly. Scenario C | Existing Standards A decentralised model where eligible public or private standards manage certification components. This resembles the CORSIA framework, which recognises standards that meet its criteria under an umbrella system. These scenarios represent extreme models, and hybrid approaches combining elements from each scenario across different certification components are also possible. 18 The survey collected answers from 23 respondents representing 11 different EU Member States, and 2 from outside the EU. The majority of respondents were involved in carbon certification schemes, mainly as: ● Entity managing a certification scheme ● Intermediary between project holders and funders ● Project developer ● Methodology developer Type of organisations Other 1 Corporation 2 Private non-profit organisation 3 Public entity / Government body 2 Research Institute / University 4 Small and medium Enterprise 4 NGO/ Civil society 7 Scale of the organisation Local 2 International 5 European 6 National 10 19 Methodology development and validation Methodologies set baselines, additionality and GHG accounting rules, making their governance critical for consistency and cost‑efficiency across the EU. The survey asked respondents to rate the viability of three governance options (EU, national, existing standards) for developing and validating methodologies, select their preferred option (see figure on the right), and explain their choice. Scenarios considered and feedback from respondents Scenario A - EU level European methodologies are developed by the EC, with possible input from a panel of European experts, and adopted through delegated acts; their validation is also carried out by the EC, potentially following European public consultation. Feedback: A single EU methodology ensures strong comparability and economies of scale, but reaching consensus can be time‑consuming. Scenario B - National level The EC publishes overarching methodologies for each sector, which are then adapted by public or private entities in each MS to reflect territorial specificities; these adjusted methodologies are validated by national authorities to ensure compliance with EU rules. Feedback: National adaptation enables innovation and responsiveness, yet risks fragmentation and unequal capacities across Member States. Scenario C – Existing standards The Commission provides global methodological guidelines, while existing public or private standards adjust their methodologies accordingly; validation is performed by these standards, subject to compliance with EU requirements and, where relevant, national consultations. Feedback: Leveraging existing methodologies accelerates deployment (shorter validation time, methodologies already existing) but does not resolve credibility issues or method proliferation. 20 Implications for the CRCF According to the CRCF Regulation, methodologies will be developed by the European Commission, which aligns with the survey results showing a clear preference among respondents for public-sector leadership in both the development and validation of methodologies. FG 2.2 Recommendations 1. Define precise EU-level rules within CRCF methodologies to avoid leaving room for interpretation by project developers in order to ensure consistency. These rules should establish the broadest possible common base, covering baseline scenarios, additionality tests, and GHG monitoring requirements (emission factors, equations, models, etc.). The more prescriptive the methodology, the lower the transaction costs (e.g., for project development and auditing). 2. Allow controlled flexibility through specific protocols proposed by certification schemes, under strict conditions: ● The developer must demonstrate the added value of the proposed protocol compared to the EU-defined methodology. ● Member States must be involved to ensure credibility, robustness, independence, and alignment with national regulations. ● Protocols from different schemes operating in the same Member State must meet equivalent requirements to prevent “forum shopping”, namely operators exploiting the system by choosing the most favourable scheme. ● All protocols must be validated by the European Commission, based on technical expert advice. ● Methodology developers may go beyond EU rules by introducing additional criteria where relevant. 3. As UNFCCC LULUCF reporting methodology differs among Member States, enable them to refine methodologies by using models or emission factors from their LULUCF reporting, provided these parameters are at least as stringent as CRCF requirements, to ensure consistency across regulations. 4. Establish regular review cycles for methodologies to keep them aligned with scientific progress, involving independent researchers, consultants, and technical experts. 5. Include an MRV cost estimate for each methodology to ensure that high accuracy does not lead to disproportionate costs, which could divert funding away from the transition. 21 GHG assessment tools and models GHG assessment tools operationalise methodologies and directly affect comparability, costs, and user uptake. The survey asked respondents to rate the viability of governance options for developing, validating, and approving tools/models (EU, national, existing standards), select their preferred option (see figure on the right), and explain their choice. Scenarios considered and feedback from respondents Scenario A – EU level (option 1) A single public EU tool, available in multiple languages, is used across the Union. Feedback: This offers economies of scale, but updating and sustaining a free tool is challenging given the diversity of existing tools already in use by advisors. Scenario A – EU level (option 2) Multiple tools (public or private) can coexist; the EC approves tools that comply with EU methodological specifications. Feedback: This model balances consistency and innovation, but requires adequate resources and time for the approval process. Scenario B – National level Multiple tools coexist; Member States approve tools that comply with the methodological specifications Feedback: Encourages innovation and local fit, giving room for improvement, yet risks disparities and uneven capacity across countries. Scenario C – Existing standards Multiple tools coexist; Standards approve the tools used within their scope. Feedback: Already operational in many contexts, but carries a risk of inconsistent outputs across tools and schemes. 22 Implications for the CRCF The survey indicates that a unique EU tool is not seen as credible, yet any tool should be EC‑approved to ensure equity and comparability. Respondents also favour describing the role and expected behaviour of tools/models directly within EU methodologies. FG 2.2 Recommendations 1. Validate tools through the EC based on technical expert advice, benchmarking tests, and consultation with MS (especially for local tools). 2. Audit tools regularly to ensure they remain aligned with evolving methodologies and produce consistent outputs. 3. Specify within methodologies how tools/models must implement rules and parameters (e.g., equations, emission factors, boundary conditions). 4. Anticipate and budget tool costs (development, maintenance, approvals) to avoid bottlenecks and ensure long‑term operability. 23 Project validation Project validation confirms that a project complies with the referenced methodology and that the application is complete (checks performed by the competent authority or a verification body). Under the CRCF, it results in a certificate of compliance. Therefore, the survey asked respondents to rate the viability of three governance options (EU, national, existing standards) for this step, select their preferred option (see figure on the right), and explain their choice. Scenarios considered and feedback from respondents Scenario A – EU level A European body (the Commission or an appointed agency) evaluates all project proposals in a single EU format (likely in English). Feedback: Ensures uniformity but raises language barriers and risks limited local representation. Scenario B – National level A national body (ministry or national agency) evaluates proposals written in the national language and ensures compliance with EU rules. Feedback: Proximity improves relevance and access, yet there may be longer timelines for validation process and divergent interpretations between MS. Scenario C – Existing standards Existing standards can evaluate projects submitted in their geographic areas 8 , ensuring compliance with European rules. As there are possible overlaps between existing standards, in a given area, a project developer may have to choose to which standard to submit the project. Feedback: Shorter validation times are possible thanks to experience and fee‑funded capacity, but double validation can occur without a unique registry. 8 As for the verification step, the standards often do not carry out the validation themselves, but appoint independent auditors instead. 24 Implications for the CRCF Survey results point out Member States as key players in project validation. While the CRCF foresees validation by certification bodies, Member States can work alongside schemes to adapt validation rules to their context. FG 2.2 Recommendations 1. Tighten rules at methodology/protocol level to gain precision, reduce ambiguity, and lower validation costs. 2. Specific baselines: where standardised baselines cannot be implemented in the first years, developers will use project‑specific baselines and must demonstrate baseline choice and additionality. This issue requires more scrutiny from certification bodies and the CRCF should set detailed requirements for establishing such baselines. 3. Member States could play a role here to define parameters for additionality tests or to provide a list of credible specific scenarios to guide certification bodies and ensure consistency within the country. 25 Auditors’ accreditation and registry Auditors' accreditation and registry management are key to ensuring verification quality, transparency, and traceability under the CRCF, which defines certification bodies as auditors and requires robust governance to prevent double counting and ensure market integrity. In this context, the survey invited respondents to assess the viability of different governance scenarios for (i) auditor accreditation and (ii) registry management, indicate their preferred options (see figures below), and explain their reasoning. Scenarios considered and feedback from respondents Auditors’ accreditation Scenario A – EU level A single EU list of accredited auditors decided by the Commission. Feedback: Creates economies of scale for EU‑wide actors and avoids repeated national accreditations. Scenario B – National level National lists of accredited auditors. Feedback: Lower entry barriers for smaller auditors operating in a single country. Scenario C – Existing standards Lists of accredited auditors decided by existing standards. Author’s note: This scenario was not considered sufficiently viable by the participants 32 ● Independent experts and consultants must be commissioned and adequately funded to assess the framework. Their role is essential to ensure methodological integrity, validate tools, and oversee certification bodies. A centralised CRCF should enable economies of scale to support this. ● Clarify the full certification process, from methodology development to emission reduction validation. This includes defining the final governance scenario to provide visibility for existing standards and their potential integration into the CRCF. ● Design a robust and viable CRCF business model, including funding sources, transaction costs, and minimum viable project size. This will ensure long-term sustainability and accessibility for diverse stakeholders. ● Anticipate the transition phase between existing frameworks and the CRCF. Farmers already engaged in certification schemes need visibility and continuity — for example, through a transitional period during which existing credits are recognised under the CRCF. ● Ensure continuous review and improvement of methodologies and tools, involving both scientific experts and field-level stakeholders. This will help maintain credibility and adapt to evolving practices and technologies. ● Promote group certification models to reduce administrative burden, especially for fragmented or small-scale farms. 33 References CREDIBLE project. The issue of scale for the carbon certification framework, March 2024. CREDIBLE project. Survey on the optimal scale of governance of the certification schemes under the CRCF. February 2025. CREDIBLE project. From single farms to nations: is there an optimal scale for robust and viable schemes? June 2025. CREDIBLE project. Feedback on the Draft Act Implementing Regulation on Carbon Removals Certification (CRCF), July 2025. VERTA project. Final report on Scoping of the CRCF registry and minimum requirements for certification scheme registries, February 2025. VERTA project. Final report on Verification rules under the CRCF regulation. Regulation (EU) 2024/3012 of the European Parliament and of the Council of 27 November 2024 establishing a Union certification framework for permanent carbon removals, carbon farming and carbon storage in products. Verification of carbon removals, carbon farming and carbon storage in products (implementing rules). 34