Event:16 September | Carbon Removal Policy Summit
Corporate Public-Benefit Spending Requirements for CDRStandards and Obligations

CORPORATE PUBLIC-BENEFIT SPENDING REQUIREMENTS FOR CDR

Lever last updated: 14 September 2026

A mandated public-benefit spending duty that companies can partly meet through CDR activities.

Cost

Very low to Low

Public administration could cost under EUR1 million annually when existing reporting handles CDR eligibility, or EUR1–10 million for national supervision, data and enforcement. These planning estimates exclude companies' mandatory expenditure, an imposed private cost reported separately.

Complexity

Low to High

Existing duties need eligibility amendments and guidance; a new duty can require company-law changes and coordinated corporate, financial and environmental supervision. India's annual plans, financial certification and reporting requirements illustrate the work authorities must require and oversee.

Timeline

Short to Medium

Existing duties could support changed company allocations and expenditure within one to two years of formal policy initiation. New legislation, reporting and delivery arrangements could require two to five years before a material funding decision.

Integrity, Transparency & MRV

1–2

Innovation & Cost Reduction

1–3

Social & Environmental Safeguards

1–3

Energy, Transport & Storage Infrastructure

N/A

Inputs & Capacity

1–3

Demand Formation

1–4

Bankability and Cost of Capital

1–3

Policy Architecture & Coordination

2–3

Overview

Government requires qualifying companies to spend a defined amount on activities benefiting society or the environment, while allowing company boards to choose eligible projects and delivery partners. CDR can enter this system in two ways. Authorities can recognise qualifying removal activities within an existing public-benefit spending list, allowing companies to direct their required budgets towards them. Alternatively, they can reserve a minimum share specifically for CDR-related activities, creating a recurring funding obligation. The lever mobilises corporate expenditure rather than collecting a tax or making a public grant. Its compliance measure is eligible spending, not tonnes removed, and it differs from a requirement to purchase removal credits. Existing mandatory corporate social responsibility systems provide precedents; a dedicated CDR allocation would be an adaptation.

Key Considerations

Authorities should decide which companies qualify, how the spending requirement is calculated and whether CDR is merely eligible or receives a protected allocation. Eligible activities could include removal projects, public-interest research and community delivery programmes, with separate rules for each. A company should know whether it may deliver activities itself, contract an eligible organisation or contribute to an approved fund. Ordinary business expenditure and work already required by other laws should not automatically qualify. India's corporate social responsibility rules exclude both categories, so a commercial CDR investment or compliance purchase cannot simply be relabelled. Rules should also settle project income, ownership of any credits, permitted climate claims, unspent balances and the funding of maintenance beyond an annual spending deadline.

Opportunities

Recognising CDR can give company boards a lawful route to support eligible removal activities from budgets they already have to spend. A dedicated allocation could create a more dependable source of funding for activities with public benefits that buyers of carbon credits may overlook, such as open research, community delivery capability or long-term stewardship. Companies could combine contributions to support larger projects while retaining separate accountability for their spending. Multi-year agreements could help recipients plan staff, maintenance and delivery. The strongest funding effect requires a meaningful CDR allocation and enforceable commitments; broad environmental eligibility alone leaves CDR competing with many other causes.

Risks

A spending target can reward exhausting a budget rather than delivering useful outcomes. Companies may prefer visible planting campaigns over maintenance, native ecosystems or less photogenic removal methods. A protected CDR share can displace spending on health, education and other priorities, while profit-linked budgets may fall during downturns. Corporate foundations or favoured contractors can absorb funds without demonstrating additional public benefit. Weak rules could allow normal business costs, legally required remediation or misleading offset claims to qualify. Annual deadlines can encourage rushed projects, and a continuing national spending obligation does not guarantee that any particular recipient will receive renewed funding.

Monitoring and Evaluation

The company regulator should distinguish required expenditure, committed funds, money actually used for eligible activities and unspent balances. Environmental authorities should separately assess project quality, maintenance, community benefits and any verified net removals. Evaluation should establish whether CDR eligibility changed company allocations, whether a dedicated share produced additional support or displaced existing contributions, and how spending varied with profits. Concentration among recipients, repeated related-party awards or low delivery quality should trigger changes to eligibility and oversight. Funding acknowledgements should be checked separately from claims to have offset emissions or acquired removal credits.

Stakeholder Engagement

Company-law and environmental authorities should agree the spending duty, eligible activities and the evidence needed to demonstrate compliance. Corporate boards and finance teams should test the calculation, budgeting and reporting requirements. Eligible charities, research bodies, public agencies and removal providers should identify delivery costs and realistic maintenance periods. Affected communities and Indigenous peoples should shape activities on their land and the distribution of benefits. Independent auditors should check spending and conflicts of interest, while qualified environmental assessors examine outcomes. Organisations receiving other public-benefit funding should help assess the consequences of reserving part of that funding for CDR.

Governance Level

National

National legislatures and company regulators can establish mandatory spending duties and amend the activities that qualify, working with environmental authorities on CDR eligibility. India's government confirms that company boards choose and manage projects within the statutory framework. Boards therefore comply with the duty and allocate their budgets, but do not independently impose this policy lever. A lower-level government would need a specific devolved or delegated power to establish an equivalent requirement; receiving corporate support or coordinating projects is insufficient.

Implementation Strategies

  • Authorities should decide whether the objective is to open existing spending budgets to CDR or require a dedicated allocation. They should model eligible company profits, likely CDR funding and effects on other public-benefit activities before choosing the spending base and minimum share.

  • The rules should distinguish project delivery, research and community support, then specify eligible recipients and expenditure for each. They should prevent ordinary operating costs and other legal duties from qualifying automatically, and explain the treatment of project income, assets and any carbon credits.

  • Companies should be able to support credible multi-year work within clear spending and carry-forward rules. Authorities should distinguish a budget commitment from expenditure actually used by a delivery partner, while allowing funded maintenance to continue after initial planting or installation.

  • Public-benefit conditions should protect consent, land rights and environmental quality, with affected communities able to influence project design and raise concerns independently. Corporate reporting should identify related-party relationships and make the use of funds traceable without imposing disproportionate burdens on small recipients.

  • The regulator should apply proportionate audits and meaningful consequences for unfulfilled duties, then review whether expenditure changes delivery outcomes. Where eligibility produces little CDR support, authorities should assess a dedicated share against its cost to other priorities rather than assume that expanding the list was sufficient.

Case Studies

India's mandatory corporate social responsibility budget

India's corporate social responsibility system makes public-benefit spending a legal obligation for qualifying companies. In March 2026, the government confirmed that companies covered by the law must spend at least two per cent of their preceding three-year average net profits on eligible activities, with boards choosing the projects. Reported expenditure in 2023–24 included INR744.7 million on agroforestry and approximately INR24.3 billion on environmental sustainability. These categories establish an operational funding route relevant to land-based removal, but include activities that are not CDR. The government also requires financial certification, annual reporting and independent impact assessments for larger qualifying projects. India therefore illustrates both a spending floor and decentralised project selection.

Indonesia's corporate social and environmental responsibility duty

Indonesia requires companies operating in or connected with natural resources to fulfil social and environmental responsibilities. Its 2012 implementing regulation, listed as in force in the government's legal database, requires directors to include activities and the necessary budget in an approved annual work plan, with implementation reported to shareholders. Spending is treated as a company cost, and the budget must reflect appropriateness and reasonableness. The regulation does not prescribe India's uniform percentage of profits. This provides a second design route, requiring a justified corporate budget while retaining flexibility over its amount and activities. A CDR adaptation would need explicit eligibility and an enforceable funding requirement if a minimum CDR allocation were intended.

Oil India's forest restoration programme in Assam

Oil India, an Indian oil and gas company, uses its corporate social responsibility programme Vasundhara to support environmental activities. In April 2022 it signed an agreement with Assam's Digboi Forest Division for carbon sequestration and restoration on 100 hectares of degraded reserved forest. The company reports that plantation activity began on 11 June 2022, and its current programme page continues to describe the forest restoration and associated bamboo conservation area. The corporate budget funds work delivered with a public forest authority, demonstrating a practical route from a public-benefit programme to removal-related activity. The sources do not establish verified net removals, survival rates or the amount of expenditure caused by the statutory duty. A CDR application would need those outcome checks and funded maintenance, rather than treating hectares or planted saplings as tonnes removed.

More Standards and Obligations

©2026 Alexander Mäkelä and Carbon Gap.
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