Integrity and AccountabilityCDR DISCLOSURE
Lever last updated: 10 September 2026
Common requirements for organisations to report their carbon removal activity.
Cost
Very low to Medium
An organisation reporting its own activities pays mainly for staff time to collect, check and publish information, with costs generally modest when it can use existing records and reporting systems. A government or industry body establishing a wider reporting scheme also pays to develop reporting requirements, operate submission systems, support participants and check compliance. Costs increase with the number of organisations covered, the detail required and the extent of verification and enforcement. Reporting organisations bear their own compliance costs separately.
Complexity
Very low to Medium
A company, municipality or foundation can add disclosure through an internal reporting decision using existing records. An industry or international programme must agree common fields, submission procedures and checking expectations. Mandatory regimes may require primary legislation, data systems and supervisory capability, with responsibilities aligned across authorities. Reusing established reporting and assurance arrangements reduces the work.
Timeline
Very short to Medium
After a formal internal decision, an organisation with usable records could publish and begin using removal information in its next reporting cycle, within a year. A new voluntary programme may need one to two years for template design, testing and first participant reports. A statutory regime may take two to five years from formal initiation through legislation and preparation to disclosures that affect compliance or business decisions. Purchasing benefits depend on users acting on the information.
Integrity, Transparency & MRV
Innovation & Cost Reduction
Social & Environmental Safeguards
Energy, Transport & Storage Infrastructure
Inputs & Capacity
Demand Formation
Bankability and Cost of Capital
Policy Architecture & Coordination
Overview
Governments and reporting-standard owners can establish common requirements for organisations to explain their carbon removal activities, while companies, public bodies and foundations can adopt these disclosures voluntarily. The aim is to make credible action easy to report, understand and recognise. A company should be able to explain why it is buying removals, what it has committed to and what has been delivered, using records that also support procurement and financial decisions. Reports should distinguish emissions reductions, removals within the organisation's operations or supply chain, and credits purchased elsewhere. They should separate future commitments from delivered removals and credits retired for use, meaning permanently taken out of circulation. Reusable information can reduce repeated due diligence and give businesses a clearer reason to communicate and sustain their purchases, while allowing independent scrutiny.
Key Considerations
Reporting should start with a small common set of fields that companies can obtain from suppliers and registries, including quantity, removal method, storage duration, delivery period, verification and intended use. Additional detail should reflect the significance of the activity and the risks involved, including reversals and relevant social or environmental impacts. The organisation should explain which operations and supply-chain activities its report covers and how removal purchases sit alongside its emissions-reduction plan. A signed contract can be reported positively as a commitment to future supply, provided it is not presented as a removal already achieved. Templates should allow legitimate commercial information to remain confidential while retaining enough detail to understand public claims. Mandatory regimes need clear coverage, preparation periods and proportionate checking; voluntary programmes need a practical reporting route and a useful reason to participate.
Opportunities
A common disclosure format can make the work behind a removal purchase useful across the organisation. Procurement teams can compare delivery and durability, finance teams can understand commitments, and communications teams can explain the purchase using the same underlying records. Credible recognition from customers, investors and reporting programmes can help companies justify early purchases and continued participation. Published commitments also help suppliers understand future demand, while delivery information helps buyers learn from experience. Integrating these fields into existing reports can reduce repeated questionnaires and make smaller buyers' participation easier. These benefits can support demand without promising that transparency alone will increase spending or improve the underlying quality of a project.
Risks
Excessive reporting demands can consume the budget and staff time that smaller buyers would otherwise use to begin purchasing removals. Unclear expectations about future contracts, uncertainty or imperfect early data can also make companies reluctant to communicate useful action. Conversely, selective disclosure can exaggerate the significance of a small purchase, conceal delivery failures or obscure rising emissions. Incompatible templates multiply work and weaken comparison, while voluntary reporting may leave much of the market uncovered. Proportionate evidence requirements, clear correction procedures and a distinction between honest revisions and misleading claims are needed to sustain participation and trust.
Monitoring and Evaluation
The scheme owner should assess participation, information quality and the usefulness of reporting to companies and their audiences. Relevant indicators include staff time per report, repeated requests for the same data, the share of contracts linked to delivery and retirement records, and whether users can distinguish future commitments from completed removals. Feedback from procurement and finance teams should establish whether the information informs purchasing or investment decisions. Reporting commitments and subsequent purchases can be compared over time, while avoiding an assumption that disclosure caused every change. Material errors should inform better templates, assistance or proportionate enforcement, and persistent gaps in voluntary coverage can inform the case for mandatory reporting.
Stakeholder Engagement
Reporting organisations should bring procurement, finance, sustainability and communications teams together to identify which information they already hold and where collection creates avoidable work. Suppliers, registries and independent reviewers can agree reusable records and checking procedures. Investors, customers, donors and civil society should test whether disclosures answer their questions, while the scheme owner decides the common fields, participation conditions and treatment of corrections.
Governance Levels
International standard-setters and industry bodies can establish reporting programmes. Supranational, national and state authorities can mandate disclosure where they hold relevant powers and coordinate supervision. Companies, municipal administrations and foundations can publish their own removal activities using their organisational authority. Cities and foundations are therefore implementers when they adopt disclosure for their own operations or programmes, rather than being assumed to regulate all companies. A common standard can be designed internationally and used by these different actors without requiring a new reporting body at each level.
Implementation Strategies
The scheme owner should test a common reporting template with large and small buyers, suppliers and intended users. It should separate emissions, internal removals and external credits, then distinguish commitments, delivery and retirement so early purchases can be explained accurately before all removals arrive.
Reporting organisations should reuse procurement records, supplier evidence and registry identifiers within established sustainability reports. The scheme owner can provide worked examples and simple digital submissions, adding more detailed fields only where their decision value justifies the reporting effort.
Voluntary programmes should make participation useful through investor and customer recognition, comparable published information and support for first-time reporters. They should recognise credible reporting of both commitments and completed action without treating a report as certification of the organisation's entire climate performance.
For mandatory reporting, authorities should define coverage, material information, preparation periods and supervision. They should align requirements with existing reporting duties and provide a correction route that addresses significant errors while allowing organisations to improve data over time.
Reporting organisations and independent reviewers should reconcile published information with contracts, delivery evidence and credit retirements. The scheme owner should test whether reporting reduces duplicated work and informs purchasing decisions, then adjust fields, support and enforcement in response to the findings.
Case Studies

European Sustainability Reporting Standards
The European Sustainability Reporting Standards specify disclosures for companies covered by EU sustainability-reporting law, with climate information reported where it is material to understanding impacts or financial risks and opportunities. The climate standard separates removals within company operations or supply chains from credits purchased elsewhere. The Commission adopted revised standards on 3 July 2026. The revised climate text distinguishes cancelled credits, credits purchased but not yet cancelled and the share from removal projects. A buyer can therefore report purchasing activity before using credits for a claim, while readers can distinguish it from completed action. The adopted act provides for use from financial years beginning in 2027, with optional early use for 2026 once it enters into force following scrutiny. The mechanism embeds removal information in an established corporate report; it does not require every company to buy removals or make every disclosed claim lawful.

SBTi's revised corporate standard
The Science Based Targets initiative is an organisation that sets standards and validates corporate climate targets. Its Corporate Net-Zero Standard version 2, published on 11 June 2026 and effective from 1 February 2027, requires annual reporting of target progress. Its optional recognition programme for responsibility for ongoing emissions also requires participating companies to report supported climate contributions separately from target progress and their emissions inventory, with independent assurance of programme conformance. Credits used for recognition must be permanently retired when claimed. Companies seeking that recognition have a reason to maintain usable purchase and contribution records rather than viewing disclosure solely as an inspection obligation. The programme includes activities beyond CDR, so removal contributions must remain identifiable. At the September 2026 review date, version 2's application is forthcoming and does not yet establish a measured effect on removal demand.

CDP’s common corporate disclosure questionnaire
CDP is a nonprofit organisation that operates an environmental disclosure system used by companies and their investors and customers. Its 2026 reporting cycle uses a common questionnaire aligned with several major reporting standards, allowing companies to share one dataset with multiple audiences. Investors request participation through an annual letter to company boards. CDP's mapping of its questionnaire to transition-plan disclosures identifies questions covering retired carbon credits, the standard or methodology used, and whether the underlying activity reduces or removes emissions. This provides an existing route for removal information to enter business and financing discussions. It also illustrates the limits of reuse. The mapping identifies gaps concerning credit sales and planned use, so an organisation may need supplementary information to explain its full purchasing strategy. Disclosure through CDP is not itself certification of a removal credit.

Microsoft’s distinction between contracted and used removals
Microsoft, a technology company and large removal buyer, used its 2025 environmental data fact sheet to distinguish carbon credits applied to the reporting year from removal credits contracted for current or future delivery. It reported 21.93 million tonnes of removal credits contracted in fiscal 2024, while explaining that only delivered and retired credits were applied to its specified carbon-neutrality boundary. This let the company communicate investment in future supply without presenting all contracted tonnes as removals already used. Its 2026 fact sheet then explained a change in approach, including the end of spot-credit purchases for annual carbon neutrality in February 2025. The reporting practice demonstrates how an organisation can explain both a purchasing commitment and a subsequent strategy change. It does not establish that disclosure caused the purchases or that its accounting choices should be adopted by every buyer.
More Integrity and Accountability

Measurement, Reporting and Verification Protocols
A common rulebook specifying how projects must measure, report and verify their removals.
Cost
Very low to Low
Complexity
Low to High
Timeline
Short to Medium
Integrity, Transparency & MRV
3–5Innovation & Cost Reduction
1–2Social & Environmental Safeguards
1–2Energy, Transport & Storage Infrastructure
N/AInputs & Capacity
1–2Demand Formation
1–2Bankability and Cost of Capital
1–2Policy Architecture & Coordination
2–4
Certification schemes
Independent assurance that a removal project and its results meet defined quality standards.
Cost
Very low to Medium
Complexity
Low to High
Timeline
Short to Medium
Integrity, Transparency & MRV
3–4Innovation & Cost Reduction
1–2Social & Environmental Safeguards
2–4Energy, Transport & Storage Infrastructure
N/AInputs & Capacity
1–2Demand Formation
1–2Bankability and Cost of Capital
1–3Policy Architecture & Coordination
2–4
Carbon credit legal status
Legislation or guidance clarifying what legal rights a carbon credit holder actually has.
Cost
Very low to Low
Complexity
Low to High
Timeline
Short to Medium
Integrity, Transparency & MRV
2–3Innovation & Cost Reduction
N/ASocial & Environmental Safeguards
N/AEnergy, Transport & Storage Infrastructure
N/AInputs & Capacity
N/ADemand Formation
1–3Bankability and Cost of Capital
2–3Policy Architecture & Coordination
3–4©2026 Alexander Mäkelä and Carbon Gap.
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Headline and barrier scores based on Carbon Gap analysis.