Roadmap towards Nature Credits

ClientEarth critiques the European Commission's 'Roadmap towards Nature Credits', warning that a market for biodiversity credits could undermine EU environmental law if not strictly separated from regulatory obligations and offsetting. The organization argues that the biodiversity financing gap—estimated at 19 billion euros per year in the EU—should first be addressed by scaling up public funds and redirecting the 48 billion euros in annual harmful subsidies. ClientEarth recommends that any future credit system be strictly outcome-based, exclude 'business-as-usual' practices, and prohibit the use of credits for ecological compensation (offsetting) to avoid 'net loss' of biodiversity. It further highlights the scientific complexity of measuring biodiversity compared to carbon, cautioning against reductionist proxy metrics that could lead to greenwashing.

• The European Union faces a biodiversity financing gap of 19 billion euros per year, while the global gap is approximately USD 700 billion per year.
• The EU currently provides up to 48 billion euros in annual subsidies to economic activities that harm the environment, which ClientEarth argues should be redirected toward biodiversity before implementing market-based mechanisms.
• Nature credits must be strictly separated from regulatory compliance and the 'mitigation hierarchy'; using credits for legally required ecological compensation (offsetting) would result in a 'net loss' of biodiversity.
• To maintain integrity, credits should only be issued ex-post based on concrete, measurable biodiversity outcomes rather than ex-ante activity-based certifications.
• ClientEarth proposes five specific categories for biodiversity credits: Habitat Conservation (“avoided loss” or “maintenance”), Species Conservation, Habitat Restoration (“uplift”), Habitat Re-establishment, and Non-deterioration Credits.
• Measuring biodiversity is significantly more complex than measuring greenhouse gases because there is no single agreed-upon metric equivalent to 'carbon-dioxide equivalent'.
• The document warns that the UK's Biodiversity Net Gain (BNG) model has flaws, including counterincentives for protecting high-ecological value habitats and the potential to bypass the mitigation hierarchy.

APA

ClientEarth (2025). Roadmap towards Nature Credits. https://www.clientearth.org/media/f2jj42sw/roadmap-to-nature-credits_clientearth-feedback.pdf

Chicago

ClientEarth. Roadmap towards Nature Credits. 2025. https://www.clientearth.org/media/f2jj42sw/roadmap-to-nature-credits_clientearth-feedback.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Roadmap towards Nature Credits |date=September 2025 |url=https://www.clientearth.org/media/f2jj42sw/roadmap-to-nature-credits_clientearth-feedback.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2025roadmap, author = {{ClientEarth}}, title = {{Roadmap towards Nature Credits}}, publisher = {ClientEarth}, year = {2025}, month = sep, url = {https://www.clientearth.org/media/f2jj42sw/roadmap-to-nature-credits_clientearth-feedback.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }