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The report argues that carbon pricing is a vital but insufficient tool for climate action and must be integrated into a broader policy mix. It advocates for absolute emission caps, the elimination of free allowances, and the reinvestment of revenues into public climate benefits. The document strongly warns against the use of carbon offsets and credits, which it claims undermine environmental integrity and allow polluters to avoid real reductions. It also addresses the 'carbon leakage' myth, suggesting that the risks are often overestimated and used to justify policies that lock in polluting industries.

The Corporate Climate Responsibility Monitor (CCRM) 2025 finds that corporate climate action is frequently treated as a marketing exercise rather than a business model redesign. While some companies like Inditex and Adidas have improved their target setting, the report highlights widespread 'creative accounting' and greenwashing. Key issues include the use of unbundled Renewable Energy Certificates (RECs) in tech and fashion, the conflation of land-based carbon removals with emission reductions in agrifood, and the use of unsubstantiated carbon credits to claim carbon neutrality. The document argues that voluntary standards are insufficient and calls for stringent government regulation, specifically citing EU directives like the CSRD and CSDDD, to mandate transparent reporting and ban product-level carbon neutral claims.

The document identifies critical transparency gaps in current carbon market infrastructure, specifically within the Clean Development Mechanism, Verra, and Gold Standard registries. It argues that existing systems fail to adequately track credit ownership, verify retirement claims, or distinguish between units contributing to a host country's NDC and those adjusted for international transfer. To remedy this, Carbon Market Watch recommends implementing machine-readable datasets, mandatory non-technical project summaries, detailed financial reporting on revenue distribution, and a transaction log to track legal ownership of credits.

Carbon Market Watch urges the Kenyan government to completely rewrite the climate change amendment bill 2023, citing pervasive ambiguity and vague terminology. The organization argues that the current wording could lead to misinterpretation, potentially harming human rights and the environment. Specific concerns include the lack of clear definitions for actors in the voluntary carbon market, the failure to distinguish between 'aiming' for reductions and actually delivering them, and insufficient requirements for the permanence of carbon removals. The response also highlights a need for greater transparency, specifically calling for the public availability of the Registry and community development agreements.

Carbon Market Watch opposes Verra's proposed "tonne-year accounting" method, which would allow projects storing carbon temporarily to issue credits based on the duration of storage (e.g., 100 tonnes for 1 year equals 1 credit). The organization argues this approach is logically flawed regarding radiative forcing, incompatible with finite global carbon budgets, and creates a risk where short-term benefits are prioritized over long-term climate costs. Additionally, it warns that the method could encourage selection bias, allowing high-risk projects to avoid long-term monitoring requirements.

The report evaluates the Greenhouse Gas Protocol's Land Sector and Removals Standard (LSRS), a framework for corporate accounting of land-based emissions and carbon removals. While praising the mandate for separate accounting of emissions and removals, the authors identify critical weaknesses: the voluntary nature of removals reporting and a provision that may allow the SBTi's FLAG Guidance—which permits netting—to take precedence. The analysis also criticizes the inclusion of enhanced oil and gas recovery, the lack of mandatory measurement-based quantification, and loopholes in 'physical traceability' via non-proportional mass balance. The report concludes with recommendations to make removals reporting mandatory, exclude fossil fuel recovery, and assert the LSRS's primacy over other target-setting frameworks.

Carbon Market Watch advises the CMA against adopting the Supervisory Body's text on removals under the Article 6.4 mechanism without further guidance to ensure environmental integrity. The organization calls for stricter definitions of removal durability, the creation of a science-based risk assessment tool, mandatory post-crediting monitoring, and clear rules on avoidable reversals and buffer pool replenishment. Regarding methodology development, it suggests requiring proponents to prove carbon credit revenues were a significant income source and conducting additionality analyses for different activity types.

Carbon Market Watch argues that Gold Standard's proposed methodology for crediting the early retirement of coal plants lacks the necessary rigor to ensure additionality and environmental integrity. The organization expresses skepticism that carbon credit finance is a suitable tool for this purpose given the volatility of energy markets and the difficulty of accurately measuring the future viability of coal plants. Specific concerns include the risk of double claiming, vague definitions of 'baseline plants' that might include economically unviable facilities, and the failure to account for the lifecycle emissions of new renewable energy plants.

Carbon Market Watch criticizes the proposed Green Claims Directive (GCD) for allowing the continued use of carbon neutrality and offsetting claims, which the organization asserts are inherently misleading due to quantification uncertainties, low carbon credit quality, and consumer misunderstanding. The response argues that the GCD's substantiation rules are too weak to prevent greenwashing and that the directive lacks clear definitions for 'significant' environmental impacts and specific requirements for future performance claims.

Carbon Market Watch has filed a complaint with the ICVCM, asserting that Verra violated the Core Carbon Principles (CCP) Assessment Framework by failing to ensure impartiality during its review of human rights allegations made by Human Rights Watch. The complaint highlights that Verra relied on the project implementer and the same validation/verification bodies that had previously approved the project, creating inherent conflicts of interest. Carbon Market Watch calls on the ICVCM to evaluate the real-world effectiveness of Verra's grievance mechanism and to implement a broader process for assessing program compliance beyond written commitments.

The letter argues that greenwashing is a "widespread scourge across the EU" and calls for a ban on carbon neutrality claims in upcoming legislative proposals. The signatories demand that companies report emissions reductions separately from external climate financing and that any long-term net zero targets requiring carbon credits be subject to corresponding adjustments under Article 6 of the Paris Agreement to prevent double counting. Additionally, the letter criticizes the European Commission's own 2030 climate neutrality target for being unspecific and urges the institution to prioritize absolute reductions over offsets.

An analysis of PoA 10471, a cookstove project in Myanmar transitioning to the Article 6.4 mechanism, indicates that the project is likely to issue 7.2 times more credits than justified based on literature-based adjustments. The analysis, applying the Gill-Wiehl (2024) methodology, identifies several factors contributing to this over-crediting, with 'stacking' (2.63x) and 'usage' (1.96x) being the most significant drivers across both analyzed batches of component project activities.

The analysis finds that PoA 10415 is likely to issue 26.33 times more credits than it should have across monitoring periods 5, 6, and 7. This over-crediting is driven by multiple factors, with the fraction of non-renewable biomass (fNRB) contributing a factor of 2.94 and fuel stacking contributing 2.19. The project, based in Myanmar, is transitioning from the Clean Development Mechanism (CDM) to the Article 6.4 mechanism of the Paris Agreement.

Carbon Market Watch argues that the current Sustainable Development (SD) Tool under Article 6.4 of the Paris Agreement lacks robust safeguards for communities affected by land-intensive projects. The organization recommends a fundamental reconsideration of the Tool's structure, advocating for shared decision-making mechanisms, independent validation by Designated Operational Entities (DOEs), the primacy of international human rights standards over weak national laws, and the expansion of Free, Prior, and Informed Consent (FPIC) to all affected communities and land-related impacts.

A coalition of organisations argues that allowing carbon credits to meet scope 3 targets undermines the 'mitigation hierarchy' and corporate responsibility for value chain emissions. The letter warns that such flexibility, as suggested in VCMI's 'beta' guidance, would damage the credibility of climate standards and discourage fundamental business model changes necessary for deep reductions.

The submission argues that environmental attribute certificates, specifically REDD+ carbon credits and energy certificates like RECs and GOs, are unsuitable for corporate decarbonisation targets. It highlights systemic issues in the voluntary carbon market, including over-crediting and flawed methodologies in REDD+ projects, and asserts that energy certificates are financial instruments that do not represent physical electricity delivery. The document advocates for a strict separation of these certificates from gross emission reduction targets, citing the EU Corporate Sustainability Reporting Directive (CSRD) as a regulatory precedent.

The document argues that forest-based carbon credits should be treated as financial contributions to climate action rather than offsets for fossil emissions. It recommends shifting support from individual projects to jurisdictional programs to drive large-scale policy change, reduce leakage, and ensure better environmental integrity. The author emphasizes the need for conservative baselines, comprehensive social and environmental safeguards, and the full involvement of Indigenous Peoples and local communities, including the requirement for Free, Prior and Informed Consent (FPIC).

The document argues that carbon markets, offsetting systems, and carbon credits are 'false climate solutions' rooted in capitalism, neocolonialism, and extractivism. It asserts that these mechanisms often violate the rights of indigenous peoples and local communities, leading to land theft and environmental harm, and provides a framework to help these communities protect their rights and territories.

The report advocates for climate justice, asserting that wealthy nations bear a historical responsibility for emissions and must provide financial and technological support to developing regions. It critiques market-based mechanisms like carbon credits and biofuels, labeling them as 'false solutions' that protect corporate profits while harming local communities and ecosystems. The text provides specific examples of climate impacts in Nigeria, Kiribati, and the Himalayas, and proposes a transition for Europe toward a low-carbon society based on drastic emission reductions and lifestyle changes.

The document argues that the financialization of nature allows companies to bypass strict environmental regulations through biodiversity offsets and carbon credits. It details the emergence of a 'conservation industry' comprising specialized NGOs, think tanks, and financial institutions that create the standards and accounting methods necessary for this system. The report highlights how extractive industries, aviation, and agribusiness use these mechanisms to access protected areas and 'greenwash' their activities, while noting that actual private investment in conservation remains a small fraction of global financial flows.