Is the CRCF Carbon Farming Delegated Act fit for purpose?

The study finds that the draft CRCF methodology for carbon farming is not fit for purpose, setting a lower integrity standard than the PACM and risking the issuance of units not backed by actual emission reductions. Key failures include insufficient additionality and permanence requirements, the omission of leakage and indirect land-use change (ILUC) risks, and a lack of systematic safeguards. The authors recommend revising the methodology to align with international benchmarks and prohibiting the use of CRCF carbon farming units for offsetting purposes.

• The draft CRCF methodology lacks a systematic approach to safeguards, outsourcing environmental protections to existing EU law rather than implementing a dedicated assessment procedure or specific criteria per impact category.
• The methodology fails to address leakage and indirect land-use change (ILUC), which may lead to significant overestimation of removals or emission reductions by ignoring the risk that activities on certified parcels are compensated by increased emissions elsewhere.
• Additionality requirements are insufficient because the draft allows retroactive crediting for activities that started between 1 January 2023 and 31 December 2027, meaning projects that were already successful without CRCF incentives can be certified.
• Permanence requirements are inadequate, with monitoring durations as short as 5 years after the activity period for some agricultural activities, contradicting the CRCF Regulation's objective to store CO2 "for at least several decades".
• The draft methodology incorrectly treats peatland rewetting as permanent and irreversible, omitting the liability mechanisms required for such activities despite scientific consensus on non-permanence risks.
• Quantification and monitoring requirements are too flexible and lack specificity, allowing operators to choose from various models or proxies without prioritising the most accurate or conservative options, which risks inflated estimates.
• The methodology does not fully account for uncertainties, using confidence levels (70% for SOC and N2O; 90% for biomass) that are significantly lower than the 95% level required under the PACM.
• Baseline-setting is not sufficiently ambitious; the draft allows for open-ended reference periods for mineral soils and sets a baseline of zero for living biomass, which may ignore natural regrowth and reflect business-as-usual levels.
• The draft methodology combines requirements for diverse activity types—including mineral soils, agroforestry, peatland rewetting, and afforestation—into one document, making it convoluted and increasing transaction costs.
• There is a critical gap in the definition of use cases for temporary units; if these units are used for offsetting permanent emissions, it could result in higher atmospheric emissions than if the CRCF were not used.

APA

Siemons, A., Fallasch, F., Schneider, D. L., & Böttcher, D. H. (2026). Is the CRCF Carbon Farming Delegated Act fit for purpose? Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2026/05/Oko-Institut_2026_Analysis-EU-CRCF-carbon-farming-methodology-and-Article-6.4-PACM-requirements.pdf

Chicago

Siemons, Anne, Felix Fallasch, Dr. Lambert Schneider, and Dr. Hannes Böttcher. Is the CRCF Carbon Farming Delegated Act fit for purpose? Carbon Market Watch, 2026. https://carbonmarketwatch.org/wp-content/uploads/2026/05/Oko-Institut_2026_Analysis-EU-CRCF-carbon-farming-methodology-and-Article-6.4-PACM-requirements.pdf.

Wikipedia

{{cite report |last1=Siemons |first1=Anne |last2=Fallasch |first2=Felix |last3=Schneider |first3=Dr. Lambert |last4=Böttcher |first4=Dr. Hannes |title=Is the CRCF Carbon Farming Delegated Act fit for purpose? |publisher=Carbon Market Watch |date=7 May 2026 |url=https://carbonmarketwatch.org/wp-content/uploads/2026/05/Oko-Institut_2026_Analysis-EU-CRCF-carbon-farming-methodology-and-Article-6.4-PACM-requirements.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{siemons2026crcf, author = {Siemons, Anne and Fallasch, Felix and Schneider, Dr. Lambert and Böttcher, Dr. Hannes}, title = {{Is the CRCF Carbon Farming Delegated Act fit for purpose?}}, institution = {Carbon Market Watch}, year = {2026}, month = may, url = {https://carbonmarketwatch.org/wp-content/uploads/2026/05/Oko-Institut_2026_Analysis-EU-CRCF-carbon-farming-methodology-and-Article-6.4-PACM-requirements.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }