Event:16 September | Carbon Removal Policy Summit
Trading and Settlement Infrastructure for Removal UnitsMarket Creation and Price Signals

TRADING AND SETTLEMENT INFRASTRUCTURE FOR REMOVAL UNITS

Lever last updated: 14 September 2026

Systems helping buyers and sellers transact in recognised removal units.

Cost

Very low to Low

Indicative costs cover annualised system adaptation, transaction interfaces, data feeds, testing and oversight. Adapting an existing operator costs less than building shared trading and settlement capability. Registry establishment and project finance have separate budgets.

Complexity

Medium

Implementors need a new administrative capability to align deliverable-unit specifications, registry interfaces, trade confirmation, counterparty checks and settlement procedures, while applying existing ownership and certification rules.

Timeline

Short to Medium

From formal initiation, adapting an existing operator could produce initial transactions within one to two years. New shared trading and settlement infrastructure may need two to five years for systems, oversight, testing and participant onboarding. These are design estimates.

Integrity, Transparency & MRV

2–4

Innovation & Cost Reduction

N/A

Social & Environmental Safeguards

N/A

Energy, Transport & Storage Infrastructure

N/A

Inputs & Capacity

N/A

Demand Formation

1–2

Bankability and Cost of Capital

3–4

Policy Architecture & Coordination

2–4

Overview

Authorities and market operators can establish systems that help buyers and sellers transact in recognised removal units. Price information helps participants compare offers; trading venues match orders; clearing arrangements manage counterparty default; and settlement services coordinate payment and transfer through existing registries. Together, these services can reduce transaction costs and failed delivery. The lever concerns buying and transferring units whose eligibility and legal status are established elsewhere. Creating registries, determining credit legal status and drafting model contracts remain separate interventions. Trading infrastructure makes purchases easier; it does not itself create an obligation to buy removals.

Key Considerations

Standardisation requires agreement on what a contract can deliver, including method, durability, vintage, certification, reversal and replacement rules. Broad categories can hide quality differences, while numerous narrow categories can divide already low trading volumes. Trading and settlement rules must reflect the unit’s established legal status, since this affects ownership, tax, security interests and insolvency. Exchange-traded derivatives should therefore follow credible certification, registry and spot-market systems rather than substitute for them.

Opportunities

Common transaction interfaces can reduce processing costs, while registry reconciliation and clearing reduce duplicate transfers and counterparty risk. Transparent prices help buyers, suppliers and lenders compare deals. Forward contracts allow projects and buyers to fix future prices, improving revenue forecasts and price-risk management. Nasdaq and Puro.earth’s carbon-removal indexes show that completed CDR transactions can already produce reference prices, although those indexes are not themselves a forward market.

Risks

Standardisation can make unlike removals appear interchangeable or give weak units the credibility of an exchange-listed product. Low trading volumes can produce unstable or distorted prices, while derivatives can become detached from physical delivery. Competing registries and contract families can fragment activity; a dominant venue creates concentration risk. Incorrect transfers, cybersecurity failures and poor registry reconciliation can also compromise ownership records.

Monitoring and Evaluation

Monitoring can compare participation, traded and delivered volumes, failed settlements, registry discrepancies and concentration. Bid-ask spreads could shed light on transaction costs, while open interest shows outstanding futures contracts. Evaluation should distinguish trading activity from physical delivery and retirement.

Stakeholder Engagement

Registries, certification bodies, suppliers and buyers can define eligible units and test contract terms. Exchanges, clearing houses and industry associations can develop trading and settlement rules. Financial regulators can oversee conduct, while tax authorities and insolvency experts help operators apply the unit’s established legal treatment.

Governance Levels

InternationalSupranationalNationalRegional / StateCity / MunicipalCorporate / Industry

Exchanges, registry operators and industry bodies build and operate transaction interfaces, trading venues, price data and settlement services. National regulators supervise trading. International and supranational bodies can provide transfer infrastructure through Article 6.4 and the Union Registry. Regional and municipal authorities qualify only where they operate comparable transfer or trading systems themselves, as in the California–Québec registry and Tokyo’s carbon-credit market. These competences support market infrastructure; they do not independently establish CDR eligibility.

Implementation Strategies

  • Authorities and operators should confirm applicable unit status, ownership and insolvency treatment before connecting trading products to existing registries.

  • Trading operators can agree deliverable classes with registries and industry bodies by method, durability, vintage, reversal treatment and certification without forcing unlike removals into one category.

  • Venues should test spot and forward transactions using recognised contract terms before listing derivatives, which should initially require physical delivery.

  • Venues should reconcile delivery with registries and publish volumes, spreads, failed settlements and market concentration.

Case Studies

Puro.earth registry and Nasdaq price indexes

Puro.earth operates a registry for certificates representing independently verified carbon removal and storage. Its Trade Connect interface lets approved users manage accounts, transfer and retire units, record trades and retrieve registry data. Nasdaq and Puro.earth also created carbon-removal price indexes using transaction data across several methods. This is one example of direct CDR market infrastructure. It shows how registry records and completed transactions can produce reference prices, but neither service provides an exchange-traded forward market.

CME Group and Xpansiv carbon futures

CME Group launched physically settled carbon-credit futures using Xpansiv prices and units from recognised registries. By February 2022, its first two contracts had traded 57 million tonnes and delivered 6.5 million. The original contract was nevertheless permanently delisted in March 2026. The suite concerned emissions credits rather than dedicated removal units. It shows that exchanges and clearing houses can provide standard prices, settlement and physical delivery, but listing a contract does not guarantee sustained participation or demand.

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