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E1-9 – GHG removals and GHG mitigation projects financed through carbon credits

Revised ESRS 2026

ESRS Standard

32. The objective of this DR is to enable an understanding of the undertaking's actions to reduce and permanently remove GHGs from the atmosphere and of the amount and quality of carbon credits it has purchased or intends to purchase from the voluntary market.

33. If it has implemented GHG removal and storage projects, the undertaking shall disclose information about the projects it has developed in its own operations or contributed to in its upstream and downstream value chain, including:

  • (a) a brief description of the GHG removal and storage projects;

  • (b) the amount of GHG removals and storage resulting from each project;

  • (c) how the risk of non-permanence is managed, including assumptions and determining and monitoring leakage and reversal events if applicable; and

  • (d) disclose any reversals (in tCO2eq) that may have occurred in the reporting period and decrease the amount of CO2 removed and stored by the same amount.

34. The undertaking shall disclose information about any projects outside its own operations and its upstream and downstream value chain that it has financed or intends to finance through any purchase of carbon credits, including:

  • (a) the amount of carbon credits in tCO2eq that are verified against recognised quality standards for carbon credits and cancelled in the reporting period;

  • (b) the amount of carbon credits in tCO2eq purchased in the reporting period and not cancelled yet; and

  • (c) the share of carbon credits from removal projects (percentage of total carbon credit volume), with an explanation of whether they are from nature-based or technological sinks.

35. In the case where the undertaking has made public claims of GHG neutrality that involve the use of carbon credits, it shall explain:

  • (a) whether and how these claims and the reliance on carbon credits neither hinder nor undermine the achievement of its GHG emission reduction targets; and

  • (b) the credibility and integrity of the carbon credits used by referring to recognised quality standards for carbon credits and any other factors necessary to understand the credibility and integrity of the carbon credits the undertaking plans to use.


Application Requirements (AR)

AR 27 for para. 33 (GHG removals and storage)
GHG removals and storage include both nature-based solutions as well as technological removals and storage. When preparing information on its projects, the undertaking shall:

  • (a) apply consensus methods on accounting for GHG removals, such as the EU Carbon Removals and Carbon Farming Certification (CRCF) Regulation (Regulation (EU) 2024/3012);

  • (b) include in the calculation the removals from operations that it owns, controls or contributes to that have not been sold to another party through carbon credits, and that are not double counted or reported;

  • (c) account for the GHG emissions associated with a removal activity, including transport and storage, under ESRS E1-8; and

  • (d) include in the calculation the removal activities in the upstream and downstream value chain that the undertaking is actively contributing to, e.g., through a cooperation project with a supplier.

AR 28 for para. 34 (Carbon credits)
When preparing the information on carbon credits, the undertaking shall:

  • (a) consider recognised quality standards for carbon credits;

  • (b) in order to avoid double counting, not include carbon credits issued from GHG emission reduction projects nor GHG emission removal projects within its own operations or upstream and downstream its value chain; and

  • (c) calculate the amount of carbon credits to be cancelled in the future as the sum of carbon credits in metric tonnes of CO₂eq over the duration of existing contractual agreements.


This article has been machine translated. In case of errors, please contact [email protected].

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