FINANCIAL ACCOUNTING FOR REMOVAL ASSETS AND OBLIGATIONS
Lever last updated: 14 September 2026
Accounting rules clarifying how companies record removal credits and obligations in financial statements.
Cost
Very low to Low
A focused interpretation can use an existing technical team for less than EUR 1 million annually; developing and maintaining a comprehensive standard can require EUR 1–10 million annually for research, consultation, field testing and implementation support. These are planning estimates for standard-setters and adopting regulators, excluding companies' credit purchases and amounts merely recorded as assets or liabilities.
Complexity
Low to Medium
Guidance under existing standards mainly requires technical interpretation and consultation. A comprehensive standard adds contract analysis, field testing and coordinated enforcement capability. The international standard-setter's published process includes research, exposure drafts, consultation and subsequent implementation support, rather than a single administrative announcement.
Timeline
Short to Medium
A focused clarification can affect a reporting cycle and related purchasing decisions within one to two years. Developing a comprehensive standard, consulting on contracts and preparing company systems may require two to five years before early adopters change their reporting or purchasing. These are planning estimates to first material use, rather than to publication or universal mandatory application.
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
Accounting standard-setters and financial regulators can establish or clarify how companies record removal credits, purchase contracts and obligations in their financial statements. The rules determine when expenditure becomes an asset or an expense, how recorded values change, and when an outstanding obligation must appear as a liability. Clear treatment allows finance teams, auditors and investors to assess CDR transactions on a consistent basis instead of repeatedly negotiating an accounting interpretation. The objective is faithful reporting of the transaction and its risks. Financial accounting does not verify the physical removal, establish ownership rights or determine whether a credit supports a climate claim. Those decisions require their own legal, certification and claims rules.
Key Considerations
The rules should distinguish a credit already held from a promise of future delivery, a refundable advance, a non-refundable payment and the service of retiring a credit. They should also distinguish credits held for sale, regulatory compliance or voluntary use, since their economic purpose can affect their accounting treatment. Guidance should explain how delivery failure, invalidation, reversal and replacement duties affect the relevant asset, contract or obligation. A commitment to buy or retire removals does not automatically justify recording either an asset or a liability. Recognition must follow the applicable accounting framework, including whether a present obligation has arisen and whether its amount can be estimated.
Opportunities
Clear accounting can remove a practical obstacle when procurement teams seek approval for long-term removal contracts and advance payments. Finance departments can assess the timing of expenses, the treatment of undelivered volumes and the consequences of supplier failure before signing. Consistent reporting also helps investors distinguish tradable credits from money already spent on voluntary climate action, and assess obligations that remain unsettled. Guidance on replacement and reversal exposure can make the financial consequences of weak contract terms more visible. These improvements may support better purchasing and financing decisions, although the appropriate accounting treatment can also make a proposed transaction less attractive. The lever enables informed decisions without guaranteeing additional demand or cheaper capital.
Risks
Rules designed to make CDR purchases appear financially favourable can conceal expenditure, overstate assets or understate obligations. Conversely, immediate expense recognition may discourage advance purchases even where early funding would help a supplier develop capacity. Management could manipulate its stated intention to sell or use credits to obtain a preferred treatment. Valuation can also mislead if a cheap avoidance credit is used as the price reference for an obligation requiring durable removal. A financial audit must not be presented as certification of carbon quality. Divergent national treatments, abrupt transition dates and guidance that ignores forward contracts can leave buyers with inconsistent balance sheets and unresolved purchasing questions.
Monitoring and Evaluation
Standard-setters and reporting regulators should assess whether comparable transactions receive consistent treatment and whether companies explain material judgements about intended use, delivery risk and unsettled obligations. Reviews can examine accounting-policy disagreements, restatements, audit findings and the handling of invalidated or undelivered credits. Where relevant, reported holdings and retirements should reconcile with registry and contract records. Evaluation should also examine whether accounting uncertainty is delaying contracts, and whether changed treatment alters advance payments or purchasing dates. Persistent differences that arise from unclear rules should prompt clarification; differences reflecting genuinely different rights and obligations should remain visible rather than be forced into uniform reporting.
Stakeholder Engagement
Accounting standard-setters and securities regulators should determine the financial reporting requirements and how they are enforced. Corporate finance and procurement teams can supply actual removal contracts and explain where accounting uncertainty changes purchasing decisions. Auditors, investors and lenders should test whether the resulting information distinguishes cash already committed, credits available for use and outstanding exposure. Developers and registries can explain delivery milestones, credit issuance, transfer and retirement records. Carbon-accounting specialists and public-interest organisations should check that financial terminology does not imply environmental equivalence between different credits or turn an accounting asset into an unsupported removal claim.
Governance Levels
International accounting bodies develop standards and interpretations. Supranational and national authorities adopt and enforce them, as illustrated by the EU's accounting-standards endorsement powers. Regional securities regulators can exercise comparable powers where financial reporting falls within their jurisdiction, including Canadian provincial regulators. Recognised private standard-setters can establish market-wide accounting practice; the US securities regulator formally recognises the Financial Accounting Standards Board's standards. Individual companies apply these requirements and exercise permitted judgement, rather than unilaterally changing the applicable standards.
Implementation Strategies
Standard-setters should examine representative contracts, including issued-credit purchases, advance funding, future-delivery commitments and retirement services, and identify questions that existing rules already answer.
Authorities should use interpretations for genuine application questions and full standard-setting procedures where recognition or measurement requirements need to change. Guidance should identify its legal status and the reporting entities it covers.
Draft requirements should explain how intended use, cancellation, delivery failure and replacement duties change the accounting outcome, with separate examples for voluntary purchases and compliance obligations.
Preparers, auditors and investors should field-test the proposed treatment against actual contracts. Standard-setters should examine whether the information faithfully represents risk, including when that exposes an expense or liability rather than improving a buyer's reported position.
Adopting regulators should set a workable transition, explain differences from other accounting frameworks and provide a route for implementation questions. Financial reporting guidance should preserve a clear distinction between accounting recognition and permission to make a carbon claim.
Case Studies
International interpretation of climate commitments
The IFRS Interpretations Committee is the body that addresses application questions under international financial reporting standards. Its April 2024 decision on climate commitments clarified when a public offset pledge can give rise to a provision, meaning a recognised liability whose amount or timing remains uncertain. In the examined fact pattern, a commitment could create a valid expectation that the company would act, but the company would not immediately recognise the cost of all its future emissions. It would recognise a provision as the covered emissions occurred, if the recognition criteria were met and the obligation remained unsettled. The decision interprets existing rules and concerns carbon offsets generally. For CDR commitments, its lesson is to examine the specific promise and triggering event; neither a distant target nor an accounting provision establishes a purchase of removals.
US accounting standard for environmental credits
The Financial Accounting Standards Board, the independent body that develops US accounting standards for nongovernmental entities, issued ASU 2026-02 in May 2026. It specifies how environmental credits, including carbon reduction and removal credits, are recorded. Qualifying credits expected to be sold or used to settle regulatory obligations can be recognised as assets, while costs of credits acquired for voluntary initiatives are generally expensed when incurred. The standard also addresses valuation, disclosures and regulatory obligations. Mandatory application begins with annual periods starting after 15 December 2027 for public business entities and one year later for other entities; early adoption is permitted. Its published rules demonstrate that financial accounting can materially distinguish intended uses of the same credit. They do not certify removal quality, and no increase in CDR purchasing or financing is established by issuance of the standard.
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.
Except where otherwise indicated, this work is licensed under the Creative Commons Attribution–NonCommercial–ShareAlike 4.0 International Licence.
Headline and barrier scores based on Carbon Gap analysis.