The European Commission has adopted a delegated act setting out certification methodologies for permanent carbon removals.
By Jean-Philippe Brisson, Michael D. Green, James Bee, and Toon Dictus
Key Points
- The EU has adopted methodologies for certifying activities that remove carbon dioxide from the atmosphere and store it.
- The voluntary EU CRCF framework is intended to build increased trust and transparency for carbon credit methodologies and is expected to influence existing and emerging practices for certification in the carbon credit market.
As part of its broader climate strategy, the EU is establishing a comprehensive certification framework for carbon removals and carbon farming through the EU Carbon Removals and Carbon Farming (EU CRCF) Regulation. The Commission identified these activities as essential components of the EU’s strategy to achieve climate neutrality by 2050 as part of the 2021 Sustainable Carbon Cycles Communication.
This blog outlines the regulatory background, key definitions, and recent developments under the EU CRCF.
Background to the CRCF
To standardise quality criteria and enhance credibility of carbon removals and carbon farming methods, on 6 December 2024, the Commission adopted the EU CRCF. The EU CRCF sets out a voluntary framework for the certification of carbon removals and soil emissions reductions.
Under this framework, operators carrying out eligible activities may apply for independent verification of the net carbon removal or soil emission-reduction benefits they generate. The CRCF also sets out rules for the functioning and recognition by the Commission and Member States of certification schemes and independent certification bodies (which in turn provide the certification and verification to operators). The voluntary nature of the certification framework means that new and existing certification schemes may apply for Commission recognition but are not required to do so to operate within the EU.
Implications of the CRCF
Adoption of the CRCF is significant for several reasons. First, the EU CRCF is essentially a new carbon-credit label that project developers may use to distinguish their products in the market. As such, it is similar to labels already available in the market, such as the Climate, Community & Biodiversity (CCB) label of Verra or the Core Carbon Principles (CCP) of the Integrity Council for the Voluntary Carbon Market.
However, the EU CRCF is, to our knowledge, the first government-issued label for voluntary credits. As the framework is established by a governmental agency and certification occurs by government-accredited certifiers, it is possible, if not expected, that carbon credit purchasers may be willing to pay a premium for CRCF accredited credits, on the basis that the additional level of scrutiny enhances the quality of the credit.
Second, it is possible that CRCF-certified credits may become eligible for use in the EU Emissions Trading Scheme, as discussed further below. The Commission must assess by 31 July 2026 how permanently stored carbon removals can be integrated into the scheme, potentially opening the door for CRCF credits to be recognised.
Carbon Removals and Carbon Farming Definitions
Under the EU CRCF, carbon removals are defined as “the anthropogenic removal of carbon from the atmosphere and its durable storage in geological, terrestrial or ocean reservoirs, or in long-lasting products”.1 The EU CRCF differentiates between permanent carbon removal, which covers storage of carbon for several centuries, and carbon storage in products, which are processes that store carbon for a timeframe of at least 35 years.
Carbon farming refers to “any practice or process carried out over an activity period of at least five years, related to the management of a terrestrial or coastal environment and resulting in the capture and temporary storage of atmospheric or biogenic carbon in biogenic carbon pools, or in the reduction of soil emissions”.2 For example, carbon farming may include rewetting and restoring peatlands and wetlands, soil protection measures, afforestation, and agroforestry practices that integrate trees, shrubs, or hedgerows within crop or grazing systems. These measures not only increase carbon sequestration in soils and biomass, but also promote soil health, thereby enhancing the resilience of food production systems.
Quality Criteria and Certification
To be recognised, activities must meet quality criteria set out by the Commission and be independently verified.
The four core quality requirements are:
- Quantification: Activities must be quantified in a manner that is relevant, conservative, accurate, complete, consistent, transparent, and comparable.
- Additionality: Activities must demonstrate additionality, meaning they go beyond existing legal requirements and would not be financially viable without the incentive of certification.
- Long-term storage, monitoring, and liability: Operators must ensure permanent or long-term storage of carbon, monitor and mitigate reversal risks, and remain liable for any carbon release during the monitoring period.
- Sustainability: Activities must meet certain sustainability requirements, ensuring they do no significant harm to the environment.
To achieve certification, operators must apply to a Commission-recognised certification scheme and show an activity plan demonstrating compliance. Following this step, the certification body will carry out an audit and review before publishing the audit report and a compliance certificate.
In November 2025, the Commission introduced Implementing Regulation (EU) 2025/2358, which establishes technical standards for certification schemes and sets out rules for the appointment and supervision of certification bodies, as well as for audit processes.
Delegated Act on Permanent Carbon Removals
To further operationalise the EU CRCF, the Commission is empowered to adopt delegated acts setting out certification methodologies for various carbon removal and soil-emissions reduction activities.3
The first Delegated Act on Permanent Carbon Removal Activities was adopted by the Commission on 3 February 2026, covering three types of permanent carbon removal activities:
- Direct air capture with carbon storage (DACCS)
- Biogenic emissions capture with carbon storage (BioCCS)
- Biochar carbon removal (BCR)
The Commission noted that these removal activities were selected due to their “technological maturity”, alongside their potential contribution to the EU’s climate objectives.
The delegated act establishes the requirements that carbon removal activities must meet to be certified and sets out explicit guidelines for the three approaches, including: eligibility criteria, activity and monitoring periods, rules for calculating total carbon removals and associated GHGs, rules on long-term storage, and liability and minimum sustainability requirements. The guidelines also establish procedures for addressing key risks, including potential leakages, and liability issues, and the conditions under which a removal may be classified as permanent.
Subject to no objections being raised by the Council of the European Union or the European Parliament during the scrutiny period, the delegated act is expected to be published in the Official Journal of the EU in early April 2026.
Once the Delegated Acts enter into force, carbon removal projects using DACCS, BioCCS, and BCR can start applying for certification, with the first projects to be certified and recognised “in the coming months”.
The Commission will assess the schemes through a standardised assessment protocol, which will be developed and published on the Commission’s Directorate-General for Climate Action (DG CLIMA) website.
Interaction With the EU ETS
The EU Emissions Trading System (EU ETS), launched in 2005, is a mandatory emissions cap-and-trade system that aims to reduce emissions by setting a cap on emissions for in-scope sectors. Historically, the EU ETS has focussed exclusively on emissions reductions, rather than carbon removals, and carbon removal credits are not currently eligible for use within the scheme.
However, there is the potential for future carbon dioxide removal integration into the EU ETS. By 31 July 2026, the Commission must assess and report on how GHGs removed from the atmosphere and stored permanently can be accounted for and covered by the EU ETS. Furthermore, the adoption of the EU 2040 climate target has renewed the debate regarding the potential role of carbon dioxide removals in the EU ETS, particularly as a means to address residual emissions in hard-to-abate sectors.
Next Steps
The Commission is currently developing a delegated act for methodologies related to carbon farming, starting with agroforestry, peatland restoration, and afforestation. The Commission adopted a draft delegated act on 22 January 2026, which was open for feedback until 19 February. The adoption of the delegated act on these methodologies is expected in summer 2026.
The Commission is also finalising a delegated act for carbon storage methodologies in bio-based construction products. This is intended to help building owners demonstrate the carbon-storage performance of buildings.
The EU CRCF represents a step towards creating standardised methodology for certifying carbon removal and carbon farming activities across the EU. Despite the voluntary nature of the framework, the EU has positioned the framework as setting a “global benchmark” for others to follow.4 For companies engaged in carbon removal and carbon farming activities, the CRCF’s quality criteria could become a key reference point for evaluating and certifying carbon removals in the EU and other jurisdictions.
This blog was prepared with the assistance of Samantha Banfield at Latham & Watkins.
Latham & Watkins will continue to monitor developments relating to the European sustainability regulatory landscape.