Voluntary and Normative DriversVOLUNTARY INDUSTRY CODES AND PARTICIPATION REQUIREMENTS
Lever last updated: 14 September 2026
An industry-run code of conduct that participating firms agree to follow.
Cost
Very low to Low
The organisation running the code pays for consultation, guidance, compliance reviews and complaints. An existing association can use current staff; independent oversight and regular reviews require continuing expenditure, financed through membership fees or other support.
Complexity
Low to Medium
An existing association can adopt a code through its membership rules. Reviewing evidence, protecting reviewers' independence, handling complaints and deciding corrective action require more developed procedures and administrative capacity.
Timeline
Very short to Medium
Existing participants may change reporting or complaint handling within a year. Developing a new code, recruiting firms and checking their first compliance cycle may take two to five years before practice materially changes.
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
An industry association or another organisation running a voluntary initiative can require participating firms to follow a common code of conduct. Firms choose whether to join, but participation brings stated responsibilities, such as disclosing results, consulting affected communities and correcting misleading public statements. The organisation publishes the code, checks how members apply it and can require improvements or withdraw membership or recognition. For CDR, a code could require developers to publish credible removal evidence, use independent verification and address complaints about their projects. These participation conditions make companies answerable for how they operate and communicate. The code can require the use of established measurement and certification methods; it does not itself calculate or certify the tonnes removed.
Key Considerations
The organisation running the code should identify the firms covered, the conduct expected and the evidence required to remain a participant. A commitment to disclose project results needs a timetable; a duty to consult communities needs a way to record concerns and respond to them. Removal claims should rely on recognised accounting and verification requirements, with the participant responsible for making the relevant evidence available. Independent representatives should be able to challenge rules that favour the companies drafting them. The code also needs a complaints process, deadlines for correcting failures and clear grounds for suspension or removal. New requirements should allow a practical transition without excusing breaches of applicable law.
Opportunities
A shared code gives responsible companies a public commitment against which buyers, communities and competitors can assess their conduct. It can raise expectations across an emerging industry before regulation addresses every issue. Firms can organise their reporting and complaint handling around common requirements, making it easier to respond consistently to customers and affected communities. Experience with those requirements can reveal problems that later regulation should address. The benefit depends on whether participation changes behaviour. A code with published findings and consequences for non-compliance gives outsiders a stronger basis for scrutiny than a pledge that nobody follows up.
Risks
Companies may write weak rules, overlook breaches by influential members or use the code to argue against necessary regulation. Firms can also advertise membership more prominently than their actual performance warrants. Competing codes may let companies select the least demanding conditions, while disproportionate reporting and review costs can exclude small developers. Independent oversight, visible complaints procedures and published responses to non-compliance help address these risks. Membership should never be presented as proof that every project or removal claim has been independently verified.
Monitoring and Evaluation
The organisation running the code should assess participation by method and company size, the proportion of firms reviewed, identified breaches and resulting corrections or suspensions. Comparing company practices before and after joining can show whether disclosure, community engagement and complaint handling improve. Reviews should also test whether buyers understand what membership does and does not establish. These findings should inform revised requirements and the support participants need to meet them.
Stakeholder Engagement
Participating firms should help test whether proposed duties are workable, while buyers, scientists, civil society and affected communities challenge gaps in what the code requires. Independent reviewers need access to the evidence used to assess compliance. The organisation running the code remains responsible for decisions on membership and correction; public authorities can explain how those decisions relate to legal requirements.
Governance Levels
International organisations, industry associations and philanthropic organisations can operate voluntary business initiatives and set participation conditions. An association uses its membership rules; an international or philanthropic operator uses the terms of its own programme. Each can require reports and decide whether a firm retains recognition.
Implementation Strategies
The organisation running the initiative should define the conduct required of participants, the evidence they must provide and the consequences of failing to comply. It should use established accounting and certification requirements for technical claims.
Proposed duties should be tested with different removal methods and company sizes. Participants and independent reviewers should examine reporting costs, access to evidence and whether the code identifies misleading claims or poor project conduct.
The initiative should establish independent review, rules for conflicts of interest and an accessible complaints process. Published procedures should explain when a company must correct its practices, faces suspension or loses recognition.
The organisation should publish participation and review results, explain what recognition means and update the code as experience accumulates. Changes should include realistic transition periods and a record of how earlier complaints informed the revision.
Case Studies
Negative Emissions Platform commitments
The Negative Emissions Platform is an industry association focused on carbon removal. Its CDR industry commitments set common expectations on removals alongside emissions reductions, lifecycle accounting, monitoring, transparency and responsible development. Signatories distinguish atmospheric removal from fossil point-source capture and publicly commit to credible scrutiny. By publishing the same commitments, companies give buyers, policymakers and civil society a shared basis for questioning their conduct and comparing it with stated principles. The mechanism uses collective norm-setting and reputational accountability to shape industry practice. The commitments are a direct CDR example, while their practical strength depends on subsequent monitoring and responses to non-compliance. Signing a pledge is distinct from independent certification of a project's performance.
UN Global Compact's participation requirements
The UN Global Compact asks companies to commit to ten principles covering human rights, labour, the environment and anti-corruption. Joining is voluntary, while business participants must report annually through its Communication on Progress. The 2026 requirements include a statement of continuing support signed by the chief executive and a questionnaire or, under that year's rules, an eligible sustainability report. This turns a general commitment into recurring duties that the initiative can monitor. The public record gives stakeholders material with which to question a company's conduct, although submitting a report does not independently certify every claim it contains. A CDR industry code could use the same combination of common principles, senior accountability and recurring reporting, with project-specific evidence requirements added for removals.
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2–3©2026 Alexander Mäkelä and Carbon Gap.
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Headline and barrier scores based on Carbon Gap analysis.