Event:16 September | Carbon Removal Policy Summit
Removal Compliance SystemMarket Creation and Price Signals

REMOVAL COMPLIANCE SYSTEM

Lever last updated: 14 September 2026

An annual purchase obligation requiring covered companies to buy verified permanent removals.

Cost

Low to Medium

Authorities fund allocation, reporting, verification and enforcement, reusing existing systems where possible. Broader coverage requires dedicated administration. Company purchases are compliance costs; public purchasing commitments need separate budgets.

Complexity

Medium to High

Authorities must legislate obligations, calculate company shares, recognise eligible removals and enforce delivery. Broader coverage and intermediary purchasing require additional financial reporting, procurement rules and coordination across regulators.

Timeline

Medium to Long

With existing reporting and verification, initial compliance purchases could begin within two to five years. Creating those systems and preparing broad company coverage may take five to ten years.

Integrity, Transparency & MRV

3–4

Innovation & Cost Reduction

2–4

Social & Environmental Safeguards

1–3

Energy, Transport & Storage Infrastructure

N/A

Inputs & Capacity

N/A

Demand Formation

3–5

Bankability and Cost of Capital

2–4

Policy Architecture & Coordination

3–4

Overview

A removal compliance system creates recurring demand by requiring covered companies to purchase verified permanent carbon removals against an annual obligation. Government determines the removal quantity needed and allocates responsibility across firms. Obligations can reflect emissions, financial capacity or a combination, with the allocation method tested for fairness and affordability. Companies purchase from eligible suppliers, while an intermediary may organise purchasing and manage supply. Trading can be permitted, but is a design choice. The system connects a collective removal objective to company obligations, eligible supply and enforcement, while retaining separate requirements to reduce emissions.

Key Considerations

The central decision is who pays for the required removals and how their share is calculated. Obligations can follow emissions responsibility, ability to pay or a combination. Affordability should be assessed against profitability and cash generation, with attention to differences between business models. Rules must specify eligible removals, compliance deadlines, treatment of shortfalls and responsibility for invalid or reversed units. Policymakers should also decide whether firms purchase directly or through an intermediary, and whether purchases support company compensation claims or contributions to a wider climate objective.

Opportunities

A rising requirement can give removal suppliers a growing pool of customers beyond voluntary buyers. Companies can plan forward purchases against future obligations, while developers seek contracts across the covered market. Spreading responsibility across sectors can reduce dependence on a few large emitters and sustain financing as emissions decline. An intermediary could combine smaller orders and offer suppliers longer contracts. These benefits depend on the obligation producing credible purchases and delivery, rather than an unfunded target or a promise of future market activity.

Risks

Requirements that grow faster than credible supply can cause price spikes, market concentration or repeated exemptions. Poor allocation can impose disproportionate costs on particular sectors or loss-making firms. Weak verification and unclear reversal rules can leave buyers or taxpayers paying for removals that do not endure. Companies may also present compliance purchases as a substitute for emissions cuts. Political changes can undermine the future demand on which suppliers have relied.

Monitoring and Evaluation

Authorities should compare required and delivered removals, compliance shortfalls, prices and contract lengths. Assessments should examine how compliance costs affect profitability, cash flow and investment capacity. Supplier concentration, reversals and replacement performance should inform eligibility and enforcement. Reviews should adjust future allocations and purchasing arrangements while preserving the overall removal objective and separate visibility of emissions reductions.

Stakeholder Engagement

Climate and finance authorities should define responsibility and affordability with evidence from covered firms, suppliers and lenders. Registries and auditors should test delivery records and claims. Any purchasing intermediary needs a clear mandate and accountability. Competition authorities, workers, communities and civil society should examine market power, cost pass-through and project safeguards.

Governance Levels

SupranationalNationalRegional / State

Supranational institutions, national governments and regional or state legislatures can establish company obligations where their climate and business-regulation powers permit. Climate regulators administer compliance, while financial and competition authorities oversee relevant market activity. A purchasing intermediary can act under a specific mandate. International coordination may support compatible systems, but a crediting registry alone cannot impose these obligations. Companies and philanthropic organisations can participate as buyers or funders without possessing the public authority to make participation compulsory.

Implementation Strategies

  • Lawmakers should define the removal trajectory, covered firms and allocation formula, then test affordability and competition effects.

  • Regulators should specify eligible delivery, claims, reversal liability and narrowly defined shortage relief.

  • Authorities should decide whether firms buy directly or through an accountable intermediary, and permit advance contracting where useful.

  • Scheduled reviews should compare obligations with delivered removals and revise future coverage without leaving the collective objective unfunded.

Case Studies

Carbon Gap From Targets to Tonnes (concept)

Carbon Gap's October 2025 From Targets to Tonnes, using CONCITO modelling, analyses a proposed removal compliance system. It compares obligations on ETS-covered CO₂ emitters, non-CO₂ emitters outside those markets, and firms across the wider economy under an ability-to-pay approach. The analysis examines which companies could finance the required removal volumes and at what cost. Trading and intermediary purchasing are possible design features. The report supports allocating lasting removal demand across firms; it does not establish an operating system or make trading its defining mechanism.

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©2026 Alexander Mäkelä and Carbon Gap.
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Headline and barrier scores based on Carbon Gap analysis.