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A voluntary carbon offset is a way for a company or person to make up for their own emissions by paying for an equivalent amount of carbon to be cut or removed somewhere else. That might mean planting or protecting forests, restoring peat bogs, capturing carbon from the air, or funding renewable energy. Each tonne of carbon avoided or removed becomes a credit, which the buyer can retire against their own emissions. It is voluntary because these buyers choose to do it rather than being required to by law, which is what separates this market from government-run compliance schemes. The idea is appealing: it puts a price on carbon and moves money towards cutting it. The hard part, as the responses show, is proving that each credit represents a real, lasting, additional reduction.
MCC’s role was to summarise and assess the evidence, not to give its own opinion. The Climate Change Committee ran an online call for evidence in February 2022 to inform a planned report on voluntary offsets. Fifty-six organisations responded. MCC consolidated every response, grouped them into common themes through a process called coding, summarised what was said question by question, and separately judged how strong each set of responses was on relevance, detail and the quality of research cited. The report states plainly that all views belong to the respondents and that it makes no claim they are true. The table below shows who responded; not every organisation answered every question, so the counts in later sections vary. The full list of named respondents is at the end of this page.
Table 1: The 56 organisations that responded to the Climate Change Committee’s 2022 call for evidence on voluntary carbon offsets, by type of respondent. Source: MCC Economics report for the Climate Change Committee.
Fifty-one organisations answered this opening question, and their answers set the tone for the whole exercise: serious concern about the market’s integrity, alongside genuine belief in what it could deliver. The table below shows how the main themes split.
Table 2: How respondents to the opening question split between the main risks and opportunities of voluntary carbon offsets, number of the 51 respondents raising each. Source: MCC Economics report for the Climate Change Committee.
Most respondents, 39 of 51, said the current state of the voluntary carbon market is a real risk. They pointed to credits that tend to be lower quality and focused on avoidance and reduction rather than removal, which can saturate the market with options that do not meaningfully help the climate while companies claim carbon neutrality or net zero. They noted that the rules of different crediting programmes differ widely, on which activities are eligible, levels of transparency and oversight, the effectiveness of third-party auditing, when credits can be used, and provisions to avoid double counting. And they said parts of the market’s basic infrastructure are missing in the United Kingdom: price transparency, clarity on the legal nature of a carbon credit, and a definitive threshold standard for what counts as a high-quality credit.
Twenty-three of 51 respondents raised accounting risks. The recurring three were additionality, paying for reductions that may well have happened anyway; double counting, where two parties, such as a company and a host country, claim ownership of the same reduction; and leakage, where an offset scheme pushes emissions elsewhere, with superficial offsets in South America cited as an example, tree planting in one area replaced by deforestation in another.
Twenty of 51 respondents said monitoring, verification and reporting problems are a very real risk. They argued fossil and biological carbon are not equivalent and should be reported separately; that sequestered carbon must be scientifically measurable under high-integrity methods, or schemes will fail to deliver the abatement they promise; that baselines used to calculate credits can be inaccurate and overestimated; and that greenwashing, misleading or false green claims, is a reputational risk that is hard to monitor. They also noted that United Kingdom businesses increasingly want formal verification of carbon-neutral status, but the only available option is a single standard, PAS 2060, with demand likely to grow.
On the opportunity side, 29 of 51 respondents said the market can channel private investment into tackling climate change while saving public money for other services. They saw high-quality carbon markets directing significant private finance into restoring and enhancing nature, large-scale habitat protection, peatland restoration and carbon-positive farming, and financing mitigation in developing countries where costs and missing expertise hold back more ambitious national climate pledges.
Twenty-four of 51 respondents argued offsets give companies wide-ranging, flexible options to accelerate action towards net zero, reducing and removing emissions at the speed the 1.5 degree goal requires while buying time for harder emissions and new technologies. Seventeen pointed to co-benefits beyond carbon: improved biodiversity, flood and drought resilience, cleaner air and water, and higher crop yields, with research by Imperial College cited as finding each tonne of carbon reduced brings additional gains such as poverty alleviation, infrastructure development and nature conservation.
Poor, in the view of most of the 38 organisations that answered, and that gap is itself one of the market’s biggest problems.
Only 6 of 38 respondents pointed to solid existing data. They cited the official registry cataloguing peatland restoration credits, the Woodland Carbon Code and Woodland Carbon Guarantee, whose projects are also scored for biodiversity, water, community and economic benefits, and research coordinated by WWF-UK and Green Alliance estimating that about 600 square kilometres of United Kingdom land, roughly the extent of Greater Manchester, or a quarter of one percent of the country’s land, is managed under voluntary carbon schemes. Even here, respondents noted there is limited evidence on the quality of these projects, given how recently the codes were established.
About half, 19 of 38, said there is very little data on the range, price and quality of voluntary offsetting, in the United Kingdom and globally. Ownership and retirement of credits cannot be uniformly tracked because reporting to registries is not required; disclosure of purchases is not mandatory; and prices depend on everything from habitat type and site profile to project duration and the buyer’s willingness to pay. Even within public registries there is a lack of traceability on trading, and international credits make up the bulk of the market, leaving the United Kingdom’s domestic market small by design. Twelve respondents listed further specific gaps: no centralised data source, no requirement to disclose sale prices, and no clarity on who ultimately receives the proceeds, how much goes to brokers and intermediaries versus the underlying projects.
Eight of 38 respondents raised concerns about what the available data reveals. The sharpest was quality. Respondents noted that in 2021, of the 284 million credits issued on the four largest registries, the large majority came from activity types with recognised quality problems. The breakdown was as follows.
Table 3: Credits issued on the four largest voluntary carbon market registries in 2021, by activity type, as cited by respondents. These types were flagged for recognised quality concerns. Source: MCC Economics report for the Climate Change Committee. Interactive on the live page: rows highlight on hover. Source: MCC Economics report for the Climate Change Committee.
Respondents also flagged greenwashing in buyers’ claims, analysis suggesting many buyers exaggerate the impact of their credits; a market that has grown rapidly on avoidance offsets rather than removals, and which analysis by Bloomberg New Energy Finance suggests may be oversupplied; pricing discrepancies between domestic and international credits; and growing evidence that verification mechanisms such as Verra and Gold Standard are not ensuring quality, with a potential conflict of interest noted, since certifiers can earn commissions per tonne of credits they approve.
Twelve of 38 set out what better data would need: a transparent, regulated trading body; minimum standards ensuring United Kingdom natural climate solutions are high integrity in line with the Paris rules agreed after COP26; a registry of all credit sales, purchases and retirements on a government-owned public domain; a clearer focus on quality that distinguishes avoidance, reduction and removal credits in line with the Oxford Principles for offsetting; quality assessment covering wider benefits, locality, traceability and longevity; and an international market under a unified governance regime, with the Energy Charter Treaty cited as precedent that internationally administered schemes can work.
Divided, with concern outweighing praise, among the 50 organisations that answered.
Fourteen of 50 spoke positively. The Woodland Carbon Code was noted as the only United Kingdom-specific standard endorsed in the International Carbon Reduction and Offset Alliance’s code of best practice, alongside international schemes including the American Carbon Registry, the Clean Development Mechanism, Climate Action Reserve, Gold Standard, Joint Implementation and the Verified Carbon Standard. The Peatland Code, backed by a government entity, was seen with the Woodland Carbon Code as upholding strict quality assurance, making data transparency a strength of the United Kingdom market. The IUCN Global Standard drew praise for fifteen years of practice and constant evolution, the Verified Carbon Standard for being the most used crediting programme worldwide, and standards linking carbon to community and biodiversity benefits for addressing climate, communities and nature together.
Thirty-three of 50 raised concerns. Approaches to additionality, permanence, leakage and reversals vary considerably across international soil carbon codes, which would need substantial development to work in the United Kingdom. The Woodland Carbon Code and Peatland Code need safeguards to protect species-rich grasslands as demand grows, with nature considerations currently covered only by a toolkit or not at all. Gold Standard and the Verified Carbon Standard were said to give insufficient focus to human rights and to hold contrasting views on fundamentals: the required permanence of biological removals, corresponding adjustments, and additionality. The Verified Carbon Standard was said to have been widely documented failing basic tests of atmospheric integrity, financial transparency and equitability. More generally, respondents said international standards are undermined by imperfect additionality tests, flawed baselines, missing retirement information, absent claims guidance and inadequate buffers against reversal; that robust standards for removal technologies are still missing, with removals wrongly treated as if they were offsets; that many standards have yet to commit to corresponding adjustments despite the new Paris rules; and that the distinction between removals and reductions is unclear, risking higher-quality removal credits being outcompeted by cheaper reduction credits under the same label.
Thirty-three of 50 recommended changes: overarching framework standards managed through a governance process visibly independent of the verifiers themselves; a stronger government role in ensuring monitoring requirements are robust and, where appropriate, regulated; the next phase of carbon standards distinguishing removal credits as a separate unit, with market forces and innovation policy steering purchases towards them; and new codes for habitats current schemes leave out, grasslands, heathlands, saltmarshes, seagrass beds and reefs, since United Kingdom verification today covers little beyond woodland and peatland.
Not reliable enough, according to most of the 39 organisations that answered.
Sixteen of 39 acknowledged strengths: monitoring, verification and reporting is critical to confidence in offset technologies, can create the highly transparent market the sector’s past criticisms demand, and is already robust for particular sectors such as peatlands and woodlands. Respondents also noted wider benefits, from confirming that schemes deliver their pledges to allowing comparison between countries and policy designs, and aggregating global progress on a common metric.
Thirty-two of 39 pointed to weaknesses. Scheme claims are broadly contested because of leakage, lack of permanence, poor monitoring, double counting and the impossibility of verifying avoided emissions. Permanence is underweighted in some schemes. Standards of monitoring quality are inconsistent between the United Kingdom and the world. Costs and time shut out small projects. Oversight of private methodologies is limited, and details behind schemes are hard to find in public information. Specific concerns were raised about standards that let developers pick the rules that suit them. International processes can double count reductions in both the buying and delivering country, and many international programmes have never been trialled or calibrated for the United Kingdom. Respondents also listed methodological problems: weak baselines, patchy data, sporadic reporting, different auditors verifying at different scales, imprecise estimates, unreliable approaches, bottlenecks that cause delays and a shortage of capacity to verify projects at all.
Thirty-three of 39 suggested improvements: a clear framework highlighting the quality and permanence of each credit; harmonisation across schemes so buyers can compare with confidence; globally or regionally agreed minimum quality standards, independently recognised; premade protocols for removals; comparability between methods; a move to technological verification, including remote sensing, to widen data and cut costs; reliable high-tech infrastructure and integrated systems such as a geographic registry; international peer review of all standards under Article 6.4 of the Paris Agreement; assessment of any societal or environmental harm a project causes; and government regulation and oversight as the industry scales.
Four areas stood out among the 44 organisations that answered.
First, offsetting claims and carbon accounting, raised by 17 of 44. Respondents saw potential for overclaiming if credits are not produced to good standards, a problem previously identified with a large majority of credits under the United Nations Clean Development Mechanism. They wanted corporate claims verified before terms are used, noting the credits behind a claim matter: carbon-neutral claims need reduction offsets, while net zero claims require removal credits. And they argued businesses should be required to make good on reduction plans before using offsets at all. Second, oversight of the standards and codes themselves, raised by 8 of 44, so buyers can tell high-quality from low as competing schemes multiply, with intermediaries held to disclosure standards on transactions and revenue, and monitoring approaches harmonised around metrics like permanence, durability and lifecycle emissions. Third, 11 of 44 pointed to other areas: the quality of offsets, given wide variation in accreditors’ methods; the use of offsets, with decarbonisation obligatory first; monitoring methods; and pricing and trading transparency. Fourth, 15 of 44 wanted an internationally agreed regulatory framework: consistent rules for issuing credits, minimum standards with the possibility of international ISO-style codes, new international codes for areas that lack them such as soil carbon, and cross-border trading rules that do not yet exist.
Both positive and negative, and different at home and abroad, according to the 37 organisations that answered.
Sixteen of 37 saw specific land-use opportunities: on-farm carbon sequestration could bring income to United Kingdom farmers and landowners, particularly where food production is limited, and rising demand for energy crops could improve biodiversity if a strategy for sustainably sourced biomass is developed. Eight listed wider gains: job creation in project areas supporting regional economic agendas, stronger customary rights for local communities over their territories, contribution to global climate goals and carbon budgets, supply-chain growth through technologies like carbon capture usage and storage, new revenue for community lands, funding for nature conservation, and support for the United Kingdom’s tree planting targets, alongside water quality improvements, soil regeneration, remediation of brownfield land, more public green space and reduced flood risk.
Nine of 37 warned of harm: damage to biodiversity and ecosystem function, especially from renewable energy projects; risks to environmental and social outcomes in an unregulated market; damage across habitat boundaries, such as tree planting drying out nearby peat bogs and turning them into net emitters; carbon pricing that incentivises the wrong behaviour; nature-based schemes enabling speculative land purchases, greenwashing and conflicts with indigenous peoples and local communities; afforestation’s large land take raising food prices on farmland or reducing biodiversity on wild land; threats to species-rich grasslands from international tree planting; over-reliance on offsetting displacing real emissions cuts; dense monoculture planting raising wildfire risk and drying adjacent wetlands; and bioenergy crops bringing low biodiversity, soil erosion, disease risk in monocultures, land take from food, and extra nitrous oxide emissions.
Respondents noted structural differences: the United Kingdom’s clearly defined land registry ensures the legality of land deeds in a way many developing countries cannot; land management, baselines and reversal risks are easier to govern at national level than internationally, where enforcement may be lacking; the quality of credits ultimately rests on governance, methodology and oversight; and while much international activity focuses on avoiding forest loss through REDD+, the United Kingdom’s biggest opportunities lie in restoring its own lost forests, peatlands and grasslands.
Nature first, removals second, and the places with most to gain, in the view of the 43 organisations that answered. Nineteen named specific activities: nature-based solutions generally, forest protection under the international REDD+ mechanism, engineered removals including carbon capture usage and storage, bioenergy with carbon capture, and direct air capture, permanent native forest planting and conservation, species-rich grassland, peatland restoration, blue carbon, especially seagrass beds and saltmarsh creation from coastal realignment, high-integrity permanent removal with carbon transport and storage, green infrastructure in cities, and even replacing plastic sports pitches with real turf. Fifteen named regions: developing countries and the Global South, areas identified as high potential in the Natural Climate Solutions World Atlas, biodiversity hotspots, many in the Asia Pacific, areas at extreme risk of desertification, areas of intense or planned deforestation, areas with high poaching and degradation, places that struggle to produce food at a profit, regions holding irrecoverable carbon stores, and, within the United Kingdom, upland and lowland peatlands.
A trustworthy market first, and yes, a real but bounded role for public funding, according to the 43 organisations that answered.
About half, 22 of 43, saw a continuing role for public money: building the market and its infrastructure until carbon prices rise; financing research and development, quantification work, start-up costs and monitoring; supporting innovative removal projects through contracts for difference and negative emissions payments; partnering with private finance to de-risk investment, provide subsidies and make direct purchases; offering matched, stacked or seed funding for projects that would otherwise stall; issuing carbon bonds or loans tied to activities such as woodland sequestration; and changing tax arrangements around land ownership, inheritance relief and incentives. A small group, 3 of 43, disagreed, arguing public money should be limited to establishing the regulatory framework and ensuring only effective activities are legal, with no public money in private companies.
Thirteen of 43 said what government should provide is support: creating enabling conditions through regulation and monitoring, enforcing standards so genuine credits reach the market, mandating natural capital accounting, expanding the codes to more habitats, developing governance against greenwashing, promoting long-term removals with wider benefits, blocking low-quality projects through mandatory registries with third-party verification, and developing a greenhouse gas removals strategy setting out objectives, principles and regulation.
Ten of 43 said the key to concentrating private investment is a clear, transparent market with verifiable high-quality credits: an international framework to standardise schemes, standards and oversight to guide capital to the most effective projects, clarity across jurisdictions on the legal nature of credits, and scale and liquidity, possibly through sovereign green bonds. Producing countries need systems guaranteeing legitimacy, on land rights, developer rules and independent monitoring. And 6 of 43 asked for authoritative buyer guidance, from government or the Climate Change Committee itself: identifying reputable schemes, valuing temporary against permanent methods, explaining which credits support net zero claims, renewed at regular intervals, and setting out how to conduct due diligence on crediting projects.
Quality, integrity and wider impact, though few businesses described their own buying directly, a gap the report notes. Among the 31 organisations that answered, 13 pointed to quality as the first consideration, verified against ratings and standards such as the International Carbon Reduction and Offset Alliance endorsement, the United Kingdom’s environmental reporting guidelines, the Core Carbon Principles, the PAS 2060 carbon-neutrality standard, and independent ratings agencies BeZero Carbon and Sylvera. Eleven pointed to integrity and credibility: proper information from sellers on methods, climate integrity and traceability; prices reflecting science-based targets; restrictions on credit vintage and methodology; risk and compliance checks covering anti-money-laundering, know-your-client and corporate governance; and a broad, trusted registry. Five emphasised a focus on removals aligned with the Oxford Principles for net zero aligned offsetting, and five looked for wider benefits: biodiversity, water, community gains, a host country committed to corresponding adjustments, and contributions to the Adaptation Fund. Two respondents made the sharper point that credits should never come before cutting a company’s own emissions, both because offsetting can become the easier option and because genuine offsetting is hard to guarantee. The evidence buyers draw on, respondents said, includes industry surveys, university briefings on offsetting, and the Oxford Principles.
Heavily, it appears, but nobody can measure it, which is itself the finding. Among the 35 organisations that answered, respondents noted that most large companies now have net zero targets, including many of the world’s largest firms, and state they intend to use offsets, that corporate appetite for offset-inclusive strategies has accelerated sharply in recent years, and that companies with such plans assume offsets will keep playing a role even after all possible decarbonisation. Yet the proportion of reductions that will actually be met with offsets is unknown, and some respondents noted there is no evidence of over-reliance either, because transparency and data are so poor. On the role offsets play, respondents were split. Many saw a positive one: offsets are currently the only mechanism for reaching net zero where reduction technology does not yet exist, they complement other efforts, they cover genuinely unavoidable emissions, they let companies act immediately, they funnel funds to projects in developing countries, they put a price on a company’s emissions that encourages cutting them, they bridge sectors like aviation with few technical options, and companies that offset may cut their own emissions more than those that do not. Others cautioned that reliance on offsets must not replace reduction, can obscure and ultimately lower overall ambition, and that emissions remaining after decarbonisation should be addressed through mitigation beyond a company’s value chain.
Most of the 32 organisations that answered thought some intervention would help, while flagging real difficulties with each option the Committee posed.
On rules requiring businesses to use offsets only where emissions cannot yet be cut, respondents saw strengths in tackling greenwashing, standardising practice and funding projects that support communities and biodiversity. The weaknesses: proving that further reduction is impossible is difficult, such rules may imply offsets grant permission to keep emitting, and enforcement is only as strong as the regulator’s capacity. Implementation would also need to reckon with uncertain future technology costs, loosely defined allowances, short-term effects on financial flows, administrative burden and accounting challenges.
On consumer protection standards for low-carbon products, respondents saw better market integrity, stronger green-claims regulation and easier quality judgements for buyers, against increased consumer costs and the inherent difficulty of measuring carbon. On regulating how far net zero targets can lean on offsets, respondents saw a route to policing corporate pledges and aligning practice with initiatives like the Voluntary Carbon Markets Integrity Initiative and the Oxford Principles, possibly with a maximum offset percentage; they suggested companies report their own absolute reductions separately from reductions financed outside their value chain, rather than one aggregate number, and that science-based cuts should come before any offset use.
On investment product labelling, respondents wanted any product containing credits described so climate-harming and climate-positive elements are visible separately rather than netted into one misleading number, giving non-specialist investors confidence. Other suggested interventions included a mechanism to confirm a business has made all feasible reductions, a move to science-based pathways with credits purchased as contributions rather than offset claims, legal clarification of terms like net zero and carbon neutral, fiscal regulation with mandatory disclosure of credit use, international alignment through the standards bodies, a British Standards Institution standard for carbon-neutrality claims, permitting fossil emissions to be offset only with permanent removals, a clear national roadmap to 2050 for the role of removals, and a defined value component linking offsets to a science-determined carbon price.
They cut both ways, in the view of the 29 organisations that answered. Article 6 is the Paris Agreement framework for countries to trade carbon reductions across borders. The risks respondents raised: double counting, a reduction claimed by both the host country and the buying company, which corresponding adjustments, the accounting mechanism that prevents a host country also counting a sold reduction, are meant to fix but bring complications of their own, including difficulties for host countries meeting their own pledges; the potential for multiple regional certification mechanisms creating inconsistency with international requirements; quality problems repeating the experience of the Kyoto Protocol’s Clean Development Mechanism; guidance becoming too complex to understand and too cumbersome to implement; concern that the voluntary market will be used to fund national climate targets; and higher administrative costs that could discourage activity and investment. The opportunities: exporting credits internationally and meeting national pledges through cross-border trading; applying corresponding adjustments to voluntary credits, which could accelerate the global transition beyond what companies do alone and strengthen the integrity of offset claims; mobilising private finance for climate action, including adaptation resources for vulnerable developing countries; enabling crediting programmes to go beyond offsetting towards net global mitigation by cancelling a share of units; independent project inspection as a condition of credibility; replacing today’s voluntary standards with internationally reviewed ones under the Paris Agreement; and building a global market for removal technologies, including exporting bioenergy with carbon capture and direct air capture.
A final open question invited any further material. Of the 23 organisations that answered, 15 supplied references or direct links to research articles, reports and publications, 71 pieces of evidence in all, which MCC catalogued in a separate table for the Committee. The remainder reiterated points made elsewhere.
It varied widely by question, and the report assessed it openly, judging each question’s responses on relevance, detail and the types of research cited. The pattern is clear in the table below: the market’s problems are well documented, while how companies actually buy and rely on offsets is poorly evidenced, the corporate purchasing question drew no directly relevant evidence at all. That unevenness is itself a finding.
Table 4: MCC’s assessment of the evidence respondents provided for each question: how many pieces of evidence were submitted and the assessment in brief. Source: MCC Economics report for the Climate Change Committee, Appendix C. Interactive on the live page: rows highlight on hover. Source: MCC Economics report for the Climate Change Committee.
That voluntary carbon offsets could be a valuable tool for reaching net zero, but only if the market’s integrity problems are fixed. Across all 13 questions, respondents returned to the same balance: genuine promise in channelling private money into real climate and nature projects, set against genuine risk that weak standards, poor data and thin regulation let the market deliver the appearance of climate action rather than the substance. The fixes they pointed to were consistent, better standards, better data, a public registry, stronger monitoring and some form of oversight, applied nationally and coordinated internationally. The Climate Change Committee drew on this evidence for its own recommendations to policymakers.
Table 5: The questions from the Climate Change Committee’s call for evidence within the scope of MCC’s review, abridged. Source: MCC Economics report for the Climate Change Committee, Appendix A (the source report’s Figure 1). Interactive on the live page: rows highlight on hover. Source: MCC Economics report for the Climate Change Committee.
The 56 respondents are listed below as published in the report. Individual respondents were anonymised, and one response was confidential.
Table 6: All respondents to the call for evidence, as published. Individuals anonymised; one response was confidential. Source: MCC Economics report for the Climate Change Committee, Appendix B (the source report’s Figure 2). Interactive on the live page: rows highlight on hover. Source: MCC Economics report for the Climate Change Committee.
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