The Beyond Alliance responds to two European Commission consultations on international carbon credits and the post-2030 climate framework
By Carl Kish, Senior Policy Lead
The European Union is designing the policy architecture that will define its path to a 90% net reduction in greenhouse gas emissions by 2040 — arguably the most consequential set of climate policy decisions the bloc will face this decade. Legislative proposals are expected in the fourth quarter, and the choices made in coming months will shape European climate policy, global carbon market standards, and corporate investment for decades to come.
The Beyond Alliance has filed two companion submissions in response to parallel European Commission Calls for Evidence: one on the use of high-quality international carbon credits toward the 2040 target, and one on the redesign of the Effort Sharing Regulation, Land Use, Land Use Change and Forestry (LULUCF), and the role of the Carbon Removals and Carbon Farming Regulation (CRCF) in the post-2030 framework. Both reflect the perspectives of our corporate members and aim to support a framework that is scientifically grounded, operationally credible, and effective at mobilizing private climate finance at scale. Below is a summary of core feedback our corporate members provided for these consultations.
The IPCC is clear that achieving net zero requires both deep emissions reductions and significant scaling of carbon dioxide removal. International credits are not a replacement for domestic effort; they are a complement that channels finance to high-integrity mitigation and removal activities globally while the EU pursues its domestic transition. Many countries that would supply these credits — including least developed countries that have contributed least to the climate crisis — rely on high-integrity market mechanisms to access the climate finance they need. At the scale envisioned for 2036 onward, EU credit demand represents one of the largest pools of high-integrity climate finance available globally. Constraining those tools disproportionately affects countries with the fewest resources to act alone.
We support allowing 5 percentage points of the EU’s 2040 target to be met through high-quality international carbon credits under Article 6 of the Paris Agreement — as a firm allocation, not a ceiling. That distinction matters: it provides the investment certainty needed to build a high-integrity Article 6 pipeline in time for 2036. Deployed with rigorous safeguards, this mechanism reduces the cost of meeting the 2040 target, strengthens EU competitiveness by alleviating pressure on EU-based industry, channels climate finance to partner countries, and reinforces the political resilience of the EU’s climate ambition. The Commission has proposed a pilot phase no later than 2031; we support that timeline and encourage starting sooner where feasible. Delay is not a neutral choice — it is a decision to enter the market with insufficient supply.
The EU should adopt a portfolio approach to credit procurement that encompasses both emission reductions and removals, and both nature-based and engineered solutions. A diverse portfolio maximizes climate impact per euro, ensures resilience against supply shortages in any single category, and delivers broader co-benefits including biodiversity protection, landscape resilience, rural livelihoods, and climate adaptation.
High-integrity nature-based solutions deserve particular attention. They are widely available and delivering measurable climate impact today; afforestation and reforestation alone account for approximately 10% of net GHG reductions between 2020 and 2030 in 1.5°C-aligned scenarios. We recognize the need to support and scale engineered removal technologies, which are critical for the long term, but not at the cost of sidelining nature-based investment now.
We also encourage the Commission to include short-lived climate pollutants — particularly methane, which has roughly 80 times the warming potential of carbon dioxide over a 20-year period — within the eligible credit pool. In March 2026, we helped launch the Superpollutant Action Initiative, a joint effort by Amazon, Autodesk, Figma, Google, JPMorganChase, Salesforce, and Workday, to deploy $100 million through 2030 into projects that reduce superpollutants like methane and refrigerants. Corporate demand is already moving in this direction; policy should follow.
The CRCF currently classifies carbon removals as either “permanent” or “temporary.” This binary framing represents a major structural barrier to scaling the high-integrity removal pathways the EU needs today because it fails to reflect the spectrum of storage duration and reversal risk that exists across removal methods. Critically, it does not recognize how these risks can be managed through a combination of legal and financial instruments, known as Contracted Durability Mechanisms. Beyond, in partnership with the American Forest Foundation and RMI, is publishing a white paper on Contracted Durability in June 2026, highlighting mechanisms such as:
Used in combination — and alongside complementary tools like insurance products that can contractually compensate for reversals through replacement credits — these mechanisms provide the enforceable liability and compensation architecture that long-term climate commitments require. And EU law already offers a template for this approach: under the CCS Directive, liability for geological storage generally transfers from the operator to the Member State once storage stability is demonstrated; Contracted Durability just extends the same logic to a broader range of removal pathways and market actors. When these mechanisms maintain the atmospheric benefit for as long as climate targets require, the relevant question for regulators is not the storage medium but whether the atmospheric outcome is secured.
The concepts and tools underpinning Contracted Durability are in active development. For example, the ICVCM’s Continuous Improvement Work Programme on Permanence is developing standardized guidance for buffer pools, insurance, and reversal compensation. The American Forest Foundation, in partnership with the carbon insurance specialist Kita, has launched a to design and stress-test the trust mechanism in practice. Policy should leave the door open to this kind of iteration — recognizing that Contracted Durability is a performance-based framework whose specific tools will continue to evolve.
The financing stakes are significant. According to UNEP, global investment in nature-based solutions must reach $571 billion per year by 2030, up from $220 billion today, with private finance currently contributing only $23 billion. Public funding alone cannot close this gap, and the regulatory framework the Commission designs will significantly influence whether private capital flows at the scale required.
The EU should ensure robust quality safeguards for international credits without creating duplicative criteria that fragment the global market. We encourage the Commission to align its quality criteria with established benchmarks — most notably the Integrity Council for the Voluntary Carbon Market’s Core Carbon Principles, which, alongside related frameworks under the Paris Agreement Crediting Mechanism and CORSIA, addresses additionality, permanence, robust quantification, independent verification, sustainable development safeguards, and avoidance of double counting.
International momentum is already moving in this direction. The Coalition to Grow Carbon Markets, co-chaired by Kenya, Singapore, and the United Kingdom, with France as a founding member, published Shared Principles for corporate use of high-integrity carbon credits in November 2025, explicitly referencing the ICVCM CCPs. Fifteen governments now support the Principles, including France, Germany, Luxembourg, and the Netherlands. Aligning EU quality criteria with this emerging consensus would create interoperable integrity standards across major markets and strengthen demand for high-integrity credits at scale.
The EU Emissions Trading System is the cornerstone of European decarbonization. A stable, predictable ETS has underpinned corporate decarbonization strategies across sectors. Weakening it through cap adjustments, scope reductions, or policy uncertainty ahead of the 2026 ETS review would undermine the business cases that first movers have built around the carbon price signal. Policy stability is a catalyst for climate ambition rather than a counterweight: it is what allows private capital to flow to innovation at the scale the transition requires.
In March 2026, approximately 150 companies and investors coordinated by the We Mean Business Coalition, Cleantech for Europe, CLG Europe, and the Business for CBAM Coalition published an open letter to EU Heads of State calling for a strong and predictable ETS. Beyond Alliance members echo this message. We also support exploring future integration of durable, high-integrity CRCF units into the ETS as part of the 2026 ETS review, once durability standards and quality safeguards are fully established.
These two consultations are among the most influential intervention points in the post-2030 policy cycle: they will shape the Commission’s analysis and ultimately inform legislation. The framework that emerges should accelerate credible climate action, preserve optionality as technologies mature, and enable each category of mitigation and removal activity to contribute where it adds the most value.
For more detail — including on the proposed EU Buyers’ Club, financing pathways for the 5% contribution, regulatory clarity for corporate climate claims, and livestock emission reductions in the CRCF — read our full submissions on international carbon credits and national targets and flexibilities.
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