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United Kingdom

Fact Sheet by Gautam Jain, Preetha Jenarthan, Victoria Prado + 1 more • June 17, 2026

This Country Framework is part of the Regulatory Frameworks for Project-Based Carbon Credit Markets. To learn more click here.

Overview

The United Kingdom’s project-based carbon credit market (PCCM) is anchored in a robust compliance market under the UK Emissions Trading Scheme (UK ETS) and a high-integrity domestic voluntary market governed by the Woodland Carbon Code (WCC)1 and the Peatland Code.2 This framework is underpinned by the Climate Change Act 2008 (amended in 2019),3 which enshrines a legally binding 2050 net-zero target and establishes carbon budgets to drive economy-wide decarbonization.

As of 2026, the market is undergoing a significant transition toward higher integrity and eventual integration into the UK ETS. While it currently does not accept project-based carbon credits, the UK ETS Authority announced in June 2025 its decision to integrate engineered greenhouse gas removals (GGRs) into the scheme by 2028–2029,4 creating a long-term compliance pathway for project-based carbon removal credits.

On the governance and integrity side, in 2024–2025, the UK moved from a largely market-driven voluntary offset landscape toward an explicit national policy framework for the voluntary carbon market (VCM) and nature market. In late 2024, the government published a set of guiding principles for high-integrity voluntary carbon and nature markets, and in April 2025, the Department for Energy Security and Net Zero (DESNZ) launched a consultation5 that set out a proposed policy and governance framework to improve trust in credits, clarify what constitutes a high-quality carbon or nature unit, and operationalize six integrity principles. The principles—which cover prioritizing in-value-chain mitigation; use of high-integrity credits, robust , reporting, and verification (MRV); transition planning; avoiding misleading claims; and collaboration and interoperability—are explicitly intended to align the UK’s approach with emerging international best practices, such as the Integrity Council for the Voluntary Carbon Market (ICVCM) and the Voluntary Carbon Markets Integrity Initiative (VCMI), and are central to the government’s strategy to develop credible nature and carbon credit markets.

I. Supply-Side Regulations

On the supply side, the core of the UK’s domestic PCCM is formed by two government-backed voluntary standards: the WCC and the Peatland Code. UK authorities describe the WCC as the “quality assurance standard for woodland carbon projects in the UK,”6 designed to remove carbon dioxide (CO₂) from the atmosphere and to enable landowners and companies to generate independently verified woodland carbon units under a government-backed framework. The Peatland Code—developed by the International Union for the Conservation of Nature (IUCN) UK Peatland Programme7 and similarly recognized by UK public bodies as the domestic voluntary standard for peatland restoration—provides a science-based methodology for generating verified carbon units from emissions reductions achieved through restoring degraded peatlands over 30- to 100-year commitments. Together, these codes constitute the main domestic project-based crediting infrastructure endorsed by the government and explicitly referenced in UK policy discussions on nature-based climate solutions and net-zero delivery.

A. Regulatory Framework

The UK’s PCCM supply-side regulations combine binding program and registry rules with non-binding government principles for carbon markets’ integrity.

  • Market Classification: Project-based credits in the UK are currently generated almost entirely through the domestic voluntary carbon market via government-backed standards—the WCC8 and the Peatland Code9—which the UK government explicitly recognizes as high-integrity domestic carbon and nature credit programs. These codes sit outside the UK ETS, which is currently an allowance-based compliance market that the UK operates for energy and industry, but is legislated to integrate engineered removals (GGRs) by 2028. The DESNZ frames these domestic codes as the backbone of the UK’s nature-based PCCM,10 while signaling the development of frameworks for engineered and nature-based removals.
  • Regulatory Status: Program rules and registry terms are binding within schemes:
  • The WCC11 and Peatland Code are voluntary to join, but once a project is registered, the code rules, validation and verification requirements, and UK Land Carbon Registry Terms and Conditions become contractually binding on project developers and account holders.12

Government integrity principles are formally endorsed:

  • The UK government’s principles for voluntary carbon and nature markets integrity (2024)13 apply across nature and engineered removal markets.14
  • Key Authorities:
  • DESNZ leads policy on voluntary carbon and nature markets15 and government integrity principles, and coordinates with the UK ETS Authority on future GGR integration.
  • Scottish Forestry is the program authority for the WCC on behalf of the UK, Scotland, Wales, and Northern Ireland governments, responsible for code governance, technical guidance, and accreditation,16 and for overseeing the UK Land Carbon Registry relationship.
  • The IUCN UK Peatland Program develops and manages the Peatland Code. Scottish Forestry represents the Peatland Code in the UK Land Carbon Registry as program administrator.17
  • The UK Land Carbon Registry Operator and S&P Global operate the UK Land Carbon Registry, whose terms and conditions govern the listing, transfer, retirement, and cancellation of WCC and Peatland Code units and embed sanctions for fraud, misrepresentation, and noncompliance.18
  • The Competition and Markets Authority (CMA) issues and enforces the Green Claims Code, while the Advertising Standards Authority (ASA) enforces advertising rules, including specific guidance on “carbon-neutral” and “net-zero” claims.19
  • The Financial Conduct Authority (FCA) regulates authorized firms that design, distribute, or market investment products or strategies referencing carbon credits. The FCA has flagged high-risk unregulated schemes, including historical carbon credit scams.20
  • Sanctions: Noncompliance within the UK’s domestic project-based crediting schemes is enforced primarily through program rules and the UK Land Carbon Registry Terms and Conditions,21 which allow the registry operator to
  • suspend or freeze registry accounts,
  • void, retire, or cancel Woodland Carbon Units (WCUs), Pending Issuance Units (PIUs), or Peatland Carbon Units (PCUs),
  • discontinue project listings, and
  • require correction of misstatements or non-conformities.

Under the Peatland Code, additional internal sanctions include the use of a buffer reserve,22 where units may be drawn down to compensate for reversals or significant underperformance; persistent non-compliance may result in buffer forfeiture or removal of the project from the code.

B. Credit Generation Standards

  • Eligible Activities: Eligible project types are defined under the two codes: the WCC covers new woodland creation and woodland restoration, generating removals through biomass growth;23 the Peatland Code covers peatland rewetting and restoration, generating emissions reductions by lowering peat oxidation and methane emissions.24 No other project categories (e.g., soil carbon, renewable energy, industrial fugitives) are currently eligible under UK-endorsed domestic crediting schemes.
  • Methodology Framework: Each code operates under a formal methodology framework that sets additionality, baseline determination, permanence, leakage assessment, and risk-buffer requirements. The WCC uses the WCC carbon calculation methodology, look-up tables, and validated project design documents, and requires compliance with the UK Forestry Standard.25 The Peatland Code applies science-based emissions-factor methodologies26 and mandates long-term management plans and risk-buffer contributions to ensure permanence.
  • MRV Requirements: the UK Accreditation Service. Validation and verification must follow:
  • ISO 17029:2019: General principles for validation and verification bodies
  • ISO 14065:2020: Requirements for validating and verifying environmental information
  • ISO 14064-3:2019: Specification for verification and validation of GHG statements27
  • Registry System: All project registration, issuance of PIUs, conversion to verified units (WCUs or PCUs), transfers, and cancellations occur within the UK Land Carbon Registry,28 operated by S&P Global,29 which maintains serialization, account structures, and program-level enforcement powers.

C. Integrity Principles

  • Additionality Tests: Both the WCC and the Peatland Code require projects to demonstrate additionality by passing formal additionality screens. The WCC applies a legal additionality test, a financial additionality test, and barrier assessment, ensuring projects go beyond legal obligations and cannot be carried out without carbon finance.30 The Peatland Code requires projects to pass legal compliance and financial feasibility,31 demonstrating that restoration is not legally mandated, is not business as usual, and relies on carbon revenue. These tests mirror international integrity expectations and align with the UK government’s principles for high-integrity voluntary carbon and nature markets, which require real, additional, and verifiable climate benefits.
  • Permanence Safeguards: Both codes include permanence safeguards to manage reversal risk. Woodland Carbon Code requires long-term woodland management plans (40–100 years)32 and mandates corrective action reporting in the event of a reversal (e.g., fire, disease, or storm damage). Peatland Code requires commitments of 30–100 years,33 depending on restoration type, and contributes a portion of expected reductions to a shared buffer reserve that is drawn down if reversals occur.
  • Quantification Standards: Project-level emission reductions or removals must be quantified using methodologies defined in each code. The WCC uses a standardized carbon calculation methodology, look-up tables from Forest Research, and model-based estimates of biomass growth, applying conservative assumptions and uncertainty deductions.34 The Peatland Code uses scientifically derived emissions factors from the UK Peatland Emissions Inventory, alongside baseline and project scenario assessments incorporating conservative estimates.35
  • Double-Counting Prevention: Both codes prevent duplicate issuance or claims through the UK Land Carbon Registry,36 which assigns unique serial numbers to all PIUs, WCUs, and PCUs; records all issuance, transfer, retirement, and cancellation events; and provides public visibility of retired units to prevent double claims and double counting across projects or buyers. The UK government’s VCM integrity principles also require that credits used toward corporate claims be transparently reported and not counted more than once.

D. Sustainable Development

  • Co-benefits: Co-benefits are not required for the issuance of WCUs and PCUs, but both UK domestic standards emphasize wider environmental and social outcomes. The WCC encourages the delivery of biodiversity enhancement, improved water regulation, recreational benefits, and landscape resilience, consistent with the UK Forestry Standard. The Peatland Code highlights benefits such as improved water quality, reduced wildfire risk, biodiversity gains, and support for rural economies. While co-benefits do not affect carbon crediting, developers frequently report them to buyers, and the UK government’s principles for high-integrity voluntary carbon and nature markets37 explicitly encourage nature-positive and community-positive project outcomes.
  • Net-Zero Compatibility: The UK’s overarching climate framework, anchored in the Climate Change Act 2008 (as amended in 2019),38 legally commits the UK to meet net-zero greenhouse gas (GHG) emissions by 205039 and five-yearly carbon budgets. This framework positions domestic nature-based projects, particularly woodland creation and peatland restoration, as critical contributions to the UK’s long-term decarbonization pathway, as reflected in the Net Zero Strategy and Environmental Improvement Plan.40

II. Demand-Side Regulations

A. Use Authorization Framework

  • Applications Allowed:
  • Voluntary Claims: UK-based companies, financial institutions, and individuals may voluntarily purchase and retire project-based carbon credits—including units from the WCC, the Peatland Code, and eligible international standards—to support climate-finance objectives or make climate-related claims. The UK government’s principles for voluntary carbon and nature market integrity explicitly address both the buying and selling of credits and are intended to guide responsible participation in voluntary markets for buying and selling carbon and nature credits.41
  • Compliance Integration: Project-based credits from the WCC and Peatland Code cannot be used for UK ETS compliance. UK ETS Authority states that offset credits are not allowed in the UK ETS;42 the scheme is currently allowances-only, with a planned future window for engineered GGRs issued as compliance-grade units, not voluntary offsets.
  • Nationally Determined Contribution (NDC) Alignment: Emission reductions and removals from UK-based projects (including WCC, Peatland Code, and future engineered-GGR projects) are accounted for within the UK’s national GHG inventory and carbon budgets under the Climate Change Act 2008. The UK government does not apply corresponding adjustments to voluntary credit purchases from domestic projects, meaning the underlying mitigation continues to contribute to the UK’s NDC rather than to private voluntary retirements.43
  • Regulatory Status:
  • No Compliance Use: The UK ETS does not currently allow offsets, and voluntary credits cannot substitute for required decarbonization.44
  • Guidance-Based Voluntary Use: Corporate use of voluntary carbon credits is governed by non-binding government guidance—the UK government’s principles for high-integrity voluntary carbon and nature markets (April 2025),45 which position credits as a complement to, not a substitute for, deep in-value-chain mitigation46 and require transparency in claims.
  • Oversight Bodies:
  • DESNZ sets overall policy for voluntary carbon and nature markets, including principles on how credits should be used in corporate net-zero strategies and how to avoid double counting and low-integrity use.47
  • CMA enforces consumer-protection law through the Green Claims Code, which applies to any UK business making environmental claims (including carbon-neutral, net-zero, or offset claims) and requires that such claims be truthful, substantiated, and not misleading.48
  • ASA applies rules and specific guidance on carbon-neutral and net-zero claims, requiring advertisers to be unqualified carbon-neutral statements, and provide accessible information on basis and limitations.49
  • FCA, through PS23/16 Sustainability Disclosure Requirements (SDR) and the anti-greenwashing rule, regulates sustainability-related claims made by FCA-authorized firms, including products or strategies that invest in or rely on carbon credits. The anti-greenwashing rule applies to all authorized firms, requiring that any sustainability-related claims are “fair, clear and not misleading.”50
  • UK Land Carbon Registry Operator and S&P Global operate the UK Land Carbon Registry, whose terms and conditions govern listing, transfer, retirement, and cancellation of WCC and Peatland Code units and embed sanctions for fraud, misrepresentation, and non-compliance.51
  • Standards Integration: While there is no legal mandate to use the Science Based Targets Initiative (SBTi), VCMI, or ICVCM, the UK government explicitly positions its principles as aligned with global integrity standards.The government intends to endorse ICVCM’s52 Core Carbon Principles as a benchmark for high-quality credits, align with VCMI’s claims framework, and integrate carbon credit disclosure53 requirements from the Transition Plan Taskforce (TPT) framework.
  • Enforcement Mechanisms:
  • The UK employs a multilayered enforcement regime governing the use and marketing of project-based carbon credits. Under the Greenhouse Gas Emissions Trading Scheme Order 2020, UK ETS operators may surrender only UK allowances (UKAs) for compliance, meaning voluntary carbon credits cannot be used to meet statutory obligations. Consumer-facing claims involving are tightly regulated. The Digital Markets, Competition and Consumers Act 202454 empowers the CMA to issue substantial civil penalties for misleading environmental claims, while the ASA55 can require withdrawal of advertisements that make unqualified or unsubstantiated carbon-neutral or net-zero claims. For financial firms, the FCA’s anti-greenwashing rule56 (within the Sustainability Disclosure Requirement regime) requires that all sustainability-related claims referencing carbon credits be “fair, clear and not misleading,”57 with breaches subject to supervisory or enforcement action. Serious misconduct, such as issuing or selling nonexistent credits, may constitute criminal fraud under the Fraud Act 2006,58 exposing individuals to prosecution and potential imprisonment.

B. Corporate Use Requirements

  • Mitigation Hierarchy: There is no statutory “reduce-first” mandate that forces UK companies to cut internal emissions before using offsets. However, the UK government’s principles for voluntary carbon and nature market integrity set a clear policy expectation that credits are only used in addition to ambitious value-chain action,59 explicitly referencing the mitigation hierarchy.60
  • Scope Coverage: No UK law prescribes which Scope 1, Scope 2, or Scope 3 emissions may be offset in voluntary claims. In principle, companies can associate credits with any scope, provided claims are not misleading under consumer protection and advertising law.61
  • Quality Standards: There is no binding list of approved programs or methodologies for corporate voluntary use, but government policy is clearly moving toward anchoring quality expectations in ICVCM, VCMI, and national standards. Principle 2 (“Use high-integrity credits”) directs buyers to credits that are real, additional, permanent, independently verified, and transparently registered, and the DESNZ consultation proposes to formally recognize the ICVCM Core Carbon Principles62 and Assessment Framework as a benchmark for high-integrity credits used in the UK. It also positions the UK’s own domestic standards (WCC, Peatland Code) and the forthcoming GGR standard for engineered removals as examples of high-integrity supply.63 These expectations remain soft law for corporations (guidance, not statute) but are reinforced by the CMA’s Green Claims Code and the ASA’s codes, which effectively require that any credits relied upon for claims meet robust integrity criteria.64
  • Accounting Treatment: UK frameworks increasingly require companies to separate gross emissions from the use of carbon credits in disclosures, rather than silently netting them away.
  • The government’s principles (Principle 3: Measure and disclose the planned use of credits)65 require entities to report how many credits they use or plan to use, how they fit into their transition strategy, and how to avoid presenting credit use as if it changes national-level accounting. The TPT Disclosure Framework (section 4.4, “Carbon Credits”) requires transition plans to disclose the intended role of credits in meeting targets, volumes purchased and retired, type (removal versus avoidance; nature-based versus technological), certification scheme, and other quality indicators; credits are treated as a separate lever, not as an adjustment embedded inside reported gross emissions.66
  • FCA-regulated listed companies and financial institutions already make climate disclosures aligned with the Task Force on Climate-related Financial Disclosures. Moreover, SDR’s anti-greenwashing rules require that any “net-zero” or “sustainable” claims relying on credits be clearly explained and not obscure the underlying gross emissions profile.67

C. Transparency and Assurance

  • Public Reporting:
  • Companies in the UK are increasingly expected to separately disclose their use of carbon credits rather than net them into emissions totals. Under the UK government’s Principle 3 for voluntary carbon and nature markets,68 organizations are encouraged to “measure and disclose” both planned and actual credit use as part of sustainability reporting. The TPT framework further recommends that transition plans detail the role, type, and expected volume of carbon credits used to meet targets (Element 4.4).69
  • Third-Party Verification:
  • Firms disclose the use of carbon credits in annual reports, transition plans, or sustainability statements. These disclosures fall within the scope of statutory audit consistency checks, meaning auditors must assess whether statements about credit purchases, retirements, or reliance on are accurate and consistent with other information in the report. The TPT framework and FCA supervisory expectations also require credible governance70 and evidence for claims involving carbon credits.
  • Science-Based Targets: UK law does not require companies to obtain SBTi validation. Entities must disclose their own climate targets, progress under FCA rules and the TPT framework, and ensure any science-aligned or Paris-aligned claims are not misleading.
  • Policy Advocacy: There are no mandatory buy-side quotas or rules prescribing the volume or type of credits that corporates must purchase. Government guidance encourages the use of high-integrity credits aligned with ICVCM71 or VCMI principles and emphasizes transparency, but participation remains voluntary.

D. Market Integrity Protection

  • Anti-greenwashing: The UK applies anti-greenwashing enforcement across consumer markets, advertising, and financial services.
  • The CMA enforces the Green Claims Code, which requires all environmental and offset-related claims to be truthful, substantiated, and not misleading. Under the Digital Markets, Competition and Consumers Act 2024, the CMA now has direct civil penalty powers and can issue fines of up to 10 percent of global turnover for misleading environmental claims, including carbon-neutral or net-zero claims based on low-integrity offsets.72
  • The ASA enforces the advertising codes and its 2023–2024 environmental claims guidance, requiring ads referencing carbon credits, carbon neutrality, or net-zero claims to be transparent about the role of , to avoid unqualified or absolute claims, and to provide clear substantiation. It can also issue ad bans, require public corrective statements, and refer persistent offenders to statutory regulators.73
  • The FCA’s anti-greenwashing rule (effective May 31, 2024)74 requires all sustainability-related claims made by FCA-authorized firms, including those involving carbon credit use in portfolios, funds, or investment products, to be fair, clear, and not misleading. Under the SDR and investment labels regime, firms must provide transparent disclosure when materially contribute to net-zero or sustainable product claims. FCA enforcement can include supervisory intervention, fines, or marketing restrictions.
  • Co-benefits Delivery: There is no legal requirement in the UK for buyers to prioritize project-based credits with biodiversity, social, or community co-benefits. However, the UK government’s voluntary carbon and nature markets integrity principles75 encourage credit users to support nature-positive outcomes and to choose projects with broader environmental and social value where possible.

III. Market-Side Regulations

A. Infrastructure Framework

  • Market Structure: The UK’s project-based carbon and nature markets operate as a decentralized, largely over-the-counter (OTC) voluntary market layered on top of the broader UK carbon-market ecosystem. Project-based units from the WCC and Peatland Code are typically traded via offtake agreements between brokers and project developers, with trades privately negotiated and then settled through registry transfers;76 there is no dedicated central exchange. In parallel, the UK runs a separate compliance market under the UK ETS, where spot and futures trading of UKAs occur on ICE77 and other financial venues, but these instruments are distinct from domestic project-based credits and cannot be interchanged.
  • Registry Operations: All accredited domestic land-use projects (WCC and Peatland Code) and their units are recorded in the UK Land Carbon Registry, operated by S&P Global. The registry
  • serves as the official electronic record of project registration, predicted and actual sequestration, and unit ownership and retirement;
  • lists project and unit-level information (project status, PIUs, verified units, retirements, and buffer units) and provides a publicly viewable ledger of UK-based carbon units; and
  • serializes each unit (PIUs, WCUs, and PCUs) with unique identifiers, enabling traceability, prevention of double issuance, and public confirmation of retirements.

The registry is not a trading venue;78 rather, it functions as the cradle-to-retirement ledger for WCUs and PCUs,79 recording issuance, transfer, buffer allocation, invalidation, and retirement, while price discovery occurs off-registry in OTC contracts and brokered markets.

  • Data Standards: The UK Land Carbon Registry and domestic codes apply common data standards to support integrity and transparency:
  • WCC and Peatland Code guidance require projects to submit standardized documentation (project design documents,80 monitoring and verification reports) and rely on unit serialization and public registries to prevent double counting and provide transparent credit histories.
  • MRV for projects is conducted under International Organization for Standardization (ISO)-based validation and verification standards (ISO 17029, ISO 14065, ISO 14064-3)81 via bodies accredited by the UK Accreditation Service, ensuring that data feeding into registry issuance meets internationally recognized assurance norms.

B. Trading and Participation

  • Eligibility Rules:
  • Participation in the UK Land Carbon Registry is open to organizations involved in UK land-sector projects or holding UK land carbon units.82 S&P Global performs due diligence or identity checks83 before activating accounts to uphold platform integrity and mitigate risks.
  • Project developers, aggregators, traders, and large corporate buyers typically hold accounts, while corporate buyers that do not wish to open an account can still participate via assignment.84 Peatland Code guidance85 explicitly allows units to be assigned on behalf of a corporate buyer without requiring the buyer to have an account, with a note attached to the unit naming the buyer and rendering the unit non-tradable once assigned.
  • There is no bespoke UK financial services license category for dealing in WCC or Peatland units, but where carbon credit schemes are structured as investment products or collective investment schemes, the FCA treats them under the Financial Services and Markets Act; past enforcement (e.g., Capital Alternatives)86 has confirmed that some carbon credit schemes constituted unauthorized collective investment schemes (UCISs) and could not lawfully be promoted to retail investors.
  • Trading Mechanisms:
  • Spot or Physical Market (OTC): Trading of WCUs and PCUs is almost entirely over the counter. Buyers typically (1) identify a project or aggregator using the WCC’s public lists and registry holdings pages, and (2) negotiate a contract directly with project developers, aggregators, or brokers.
  • Assignment Versus Transfer: Under the Peatland Code (and similarly for the WCC), two mechanisms demonstrate a sale: a transfer, where units move from the seller’s registry account to the buyer’s registry account, and an assignment,87 where the buyer does not hold an account and the seller’s registry account records a non-tradable assignment with the buyer’s name, automatically leading to retirement at verification for PIUs.
  • Derivatives: As of , there are no UK-specific exchange-traded futures contracts that reference only WCUs or PCUs.
  • Settlement Systems:
  • Registry Settlement (Units): For trades where both parties hold accounts, settlement of WCC or Peatland transactions is completed by electronic transfer of units within the UK Land Carbon Registry,88 which acts as a serialized ledger rather than a trading venue or central counterparty.
  • Price Discovery: The UK has no mandatory transaction-level price reporting for WCUs and PCUs. Price discovery is primarily based on the following:
  • Bilateral OTC prices are negotiated between project developers, aggregators, and buyers.
  • The WCC publishes indicative national averages based on reported transactions.89
  • Oversight Authority:
  • DESNZ leads policy on voluntary carbon and nature markets, including the “Voluntary Carbon and Nature Markets: Raising Integrity” consultation (2025)90 and the government integrity principles, and coordinates with the UK ETS Authority on future GGR integration.
  • His Majesty’s Revenue and Customs (HMRC) regulates the value-added tax (VAT) treatment of voluntary carbon credits.91 Revenue and Customs Brief 7 (2024) confirms that, from September 1, 2024, sales of voluntary carbon credits where the place of supply is the UK must be treated as taxable supplies, with some trades brought into the Terminal Markets Order for potential zero rating.
  • FCA, through PS23/16 SDR and the anti-greenwashing rule, regulates sustainability-related claims made by FCA-authorized firms, including products or strategies that invest in or rely on carbon credits. The anti-greenwashing rule applies to all authorized firms, requiring that any sustainability-related claims be fair, clear, and not misleading.
  • UK Land Carbon Registry Operator and S&P Global operate the UK Land Carbon Registry, whose terms and conditions govern listing, transfer, retirement, and cancellation of WCUs and PCUs and embed sanctions for fraud, misrepresentation, and non-compliance.92
  • Legal : The only formal government definition comes from HMRC, which, for VAT purposes, defines voluntary carbon credits as “tradable instruments representing the reduction or removal of one ton of CO₂e,” and distinguishes them from compliance-market units.93 This VAT definition does not confer property status or financial instrument status; it only clarifies tax treatment.

There is no UK-specific accounting standard for voluntary carbon credits. Entities therefore apply the general UK-adopted International Financial Reporting Standards, and classification depends primarily on the purpose and intent of holding the credits, consistent with practice guidance from major accounting firms and UK regulators.

  • Inventory (International Accounting Standard [IAS] 2) Guidance:94 If WCUs, PCUs, or PIUs are held for resale, or for use in delivering offsetting services to customers (e.g., retailers, aggregators, or intermediaries), they typically meet the definition of inventory. They are measured at the lower of cost or net realizable value.95
  • Intangible Assets (IAS 38) Guidance:96 If voluntary carbon credits are purchased and held for the company’s own use as part of a long-term decarbonization or net-zero strategy, rather than for trading, they generally meet the definition of an intangible asset.
  • Expense (P&L): Where credits are purchased and immediately retired to offset current-period emissions or claims, many UK entities recognize an expense at the point of retirement, particularly when holdings are small or immaterial, credits do not meet internal capitalization thresholds, or the company’s accounting policy treats offset purchases as a period cost. This treatment is common among corporations making annual “carbon-neutral” or “net-zero” product or operations claims.97

C. Market Integrity Safeguards

  • Anti-Manipulation and Fraud Prevention: The UK’s project-based carbon market relies on the UK Land Carbon Registry as a single, serialized ledger that prevents double issuance and double counting of WCUs and PCUs. Fraudulent behavior, such as selling nonexistent units or misrepresenting credit ownership, falls under the Fraud Act 2006, while misleading environmental or credit-related claims are enforced by the CMA (Green Claims Code,98 Digital Markets, Competition and Consumers Act 2024)99 and ASA (environmental advertising rules). Where carbon credit schemes are marketed as investments, the FCA100 regulates market conduct under the Financial Services and Markets Act and has previously taken action against unauthorized collective investment schemes involving carbon credits.
  • Transparency and Reporting Requirements: The UK Land Carbon Registry provides public project-level information, including project documentation, PIUs issued, verified units, retirements, buffer contributions, and unit serial numbers. The WCC and Peatland Code publish annual market data such as average prices,101 transaction volumes, and market trends.

D. Financial and Cross-Border Integration

  • Financial Regulation Integration: The UK does not classify WCC or Peatland Code units as “financial products” by default. However, carbon credit activities fall within the UK financial services regulatory perimeter when they constitute regulated investment activity (e.g., when credits are packaged or promoted as investments or form part of a UCIS, as confirmed by FCA enforcement in Capital Alternatives). FCA rules under the Financial Services and Markets Act 2000, therefore, apply where carbon credit schemes resemble investment products or are marketed to retail consumers.102 From a tax standpoint, HMRC Brief 7 (2024)103 establishes that most voluntary carbon credit transactions are taxable supplies for VAT purposes in the UK.
  • Cross-Border Trading Framework:
  • The UK does not permit domestic voluntary credits (WCC or Peatland Code units) to be transferred internationally (Article 6) for compliance purposes,104 nor does the UK apply corresponding adjustments to voluntary domestic credit use.
  • DESNZ’s consultation confirms that mitigation achieved in the UK through domestic projects will continue to count toward the UK’s NDC and carbon budgets, even when credits are sold to private buyers.105
  • is exploring participation in the Paris Agreement Crediting Mechanism (PACM). The consultation proposes establishing a designated national authority to enable project developers to generate and sell Article 6.4 credits, specifically mitigation contribution emission reductions (MC-A6.4ERs), without corresponding adjustments.106
  • No cross-border trading of WCUs or PCUs currently occurs under Article 6.2 arrangements, though the UK is developing governance structures for future interoperability.

E. Regulatory Advancement Development Road Map

  • Infrastructure Plans: The UK government is expanding the enabling architecture for high-integrity voluntary markets rather than building a centralized exchange. Current priorities include:
  • strengthening the UK Land Carbon Registry (operated by S&P Global) as the unified ledger for domestic land-sector credits;107
  • developing the UK GGR Standard and associated accreditation pathway to support future integration of engineered removals into both the voluntary market and the UK ETS;108
  • a broader nature-markets level, developing cross-market data and governance frameworks through standards such as the British Standards Institution’s BSI Flex 701, “Nature Markets—Overarching Principles and Framework,” which sets out common principles for integrity, transparency, data quality, and market governance across all UK nature and carbon credit schemes, including the WCC, the Peatland Code, Biodiversity Net Gain, and emerging private standards.109
  • International Cooperation: The UK continues to participate actively in United Nations Framework Convention on Climate Change Article 6 negotiations, but has clarified that domestic voluntary credits will not receive corresponding adjustments and will continue to count toward UK carbon budgets and the NDC.110 The 2024–2025 DESNZ consultation proposes enabling UK project developers to access the PACM111 by establishing a designated national authority, allowing the issuance of Article 6.4 credits without corresponding adjustments. No Article 6.2 Internationally Transferred Mitigation Outcomes export pathway currently exists.
  • Regulatory Evolution:
  • Development of Governance and Data Standards Enabling Financial Market Confidence: The BSI Flex 701 nature markets framework112 sets cross-market standards for integrity, data quality, governance, and transparency across all UK nature and carbon markets, critical prerequisites for institutional investors and insurers to treat WCC, Peatland Code, and nature-credit units as recognized environmental assets.
  • Integration of Engineered GGRs into the UK ETS,113 Enabling Financial Grade Credit Instruments: The UK ETS Authority’s decision to admit engineered GGR credits into the ETS from 2028–2029 creates, for the first time, a compliance-grade carbon-removal asset class. This will allow financial institutions to value, hedge, trade, and contract long-term removals alongside ETS allowances, tightening the link between voluntary removal credits and compliance markets.
  • Mainstreaming Carbon Credit Use into Regulated Financial Reporting: The FCA is incorporating the TPT Disclosure Framework114 into its sustainability disclosure regime, meaning listed companies and financial institutions will be required to disclose how carbon credits feature in investment strategies, transition plans, and net-zero pathways, bringing carbon credit data into the core of regulated financial reporting.
  • Enforcement Enhancement: Market integrity enforcement is intensifying across regulators:
  • The CMA now has direct civil-penalty powers under the Digital Markets, Competition and Consumers Act (up to 10 percent of global turnover) for misleading green or offset claims.115
  • The ASA enforces strengthened rules on “carbon-neutral” and “net-zero” advertising, requiring explicit disclosure when claims rely on offsets.116
  • The FCA’s anti-greenwashing rule (May 2024)117 introduces binding obligations for financial firms to ensure all sustainability-related claims, including those involving carbon credits, are fair, clear, and not misleading.
  • Fraudulent carbon credit schemes face criminal liability under the Fraud Act 2006.118

References

  1. Woodland Carbon Code, “The Woodland Carbon Code Scheme for Buyers and Landowners,” February 2022, https://www.gov.uk/guidance/the-woodland-carbon-code-scheme-for-buyers-and-landowners. ↩
  2. IUCN UK Peatland Programme, “Peatland Code,” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/peatland-code. ↩
  3. UK Government, “Climate Change Act 2008,” November 2008, https://www.legislation.gov.uk/ukpga/2008/27/contents. ↩
  4. UK ETS Authority (Department for Energy Security and Net Zero, Scottish Government, Welsh Government and DAERA), Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme: Main Response, June 30, 2025, 5, https://assets.publishing.service.gov.uk/media/689cda8487bf475940723f5b/uk-ets-ggrs-main-response.pdf. ↩
  5. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  6. Forest Research, “Woodland Carbon Code,” accessed December 2025, https://www.forestresearch.gov.uk/climate-change/carbon/woodland-carbon-code/. ↩
  7. IUCN UK Peatland Programme, “Peatland Code,” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/peatland-code. ↩
  8. Woodland Carbon Code, “The Woodland Carbon Code Scheme for Buyers and Landowners,” February 2022, https://www.gov.uk/guidance/the-woodland-carbon-code-scheme-for-buyers-and-landowners. ↩
  9. IUCN UK Peatland Programme, “Peatland Code,” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/peatland-code. ↩
  10. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  11. Woodland Carbon Code, Woodland Carbon Code version 3.0, August 1, 2025, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  12. These set detailed eligibility, MRV, issuance, transfer, retirement, nonverification, and cancellation rules for Woodland or Peatland Units and Pending Issuance Units (PIUs), including the ability of the registry to cancel units where fraud, misrepresentation, or non-compliance is identified; IUCN UK Peatland Programme, Peatland Code Version 2.1 Guidance, April 2025, https://live-twt-d8-iucn.pantheonsite.io/sites/default/files/2025-04/Peatland%20Code%20V2.1%20Guidance%20-%20Web%20final.pdf. ↩
  13. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  14. They are explicitly described as voluntary principles intended to “support organisations engaged in discretionary action towards net zero and nature positive transitions” and to guide both credit supply and use, building on experience with the WCC and Peatland Code. ↩
  15. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, https://www.gov.uk/government/consultations/voluntary-carbon-and-nature-markets-raising-integrity. ↩
  16. Scottish Forestry, “About the Woodland Carbon Code,” accessed December 2025, https://www.woodlandcarboncode.org.uk/about. ↩
  17. IUCN UK Peatland Programme, “Peatland Code Governance,” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/peatland-code/peatland-code-governance. ↩
  18. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  19. Competition and Markets Authority, “Green Claims Code: Making Environmental Claims,” September 20, 2021, https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims. ↩
  20. The FCA has flagged high-risk unregulated schemes, including historical carbon credit scams; Financial Conduct Authority, “Beware of Carbon Credit Scams,” accessed December 2025, https://www.fca.org.uk/scamsmart/carbon-credit-scams. ↩
  21. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  22. IUCN UK Peatland Programme, Peatland Code Version 2.1, October 2024, 11, https://www.iucn-uk-peatlandprogramme.org/sites/default/files/2025-09/Peatland%20Code%20V2.1%20-%20Web%20Final-Sept%202025.pdf. ↩
  23. Woodland Carbon Code, Woodland Carbon Code Version 3.0, August 1, 2025, 11, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  24. IUCN UK Peatland Programme, Peatland Code Version 2.1, October 2024, 3, https://www.iucn-uk-peatlandprogramme.org/sites/default/files/2025-09/Peatland%20Code%20V2.1%20-%20Web%20Final-Sept%202025.pdf. ↩
  25. Woodland Carbon Code, Woodland Carbon Code Version 3.0, August 1, 2025, 17, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  26. IUCN UK Peatland Programme, “Peatland Code Key Documentation & Support (Including Emissions Calculators),” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/using-peatland-code/support. ↩
  27. Woodland Carbon Code, Woodland Carbon Code Version 3.0, August 1, 2025, 3, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  28. Woodland Carbon Code, “About the Registry,” accessed December 2025, https://www.woodlandcarboncode.org.uk/about-registry. ↩
  29. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  30. Woodland Carbon Code, Woodland Carbon Code Version 3.0, August 1, 2025, 18–19, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  31. IUCN UK Peatland Programme, Peatland Code Version 2.1, October 2024, 3, https://www.iucn-uk-peatlandprogramme.org/sites/default/files/2025-09/Peatland%20Code%20V2.1%20-%20Web%20Final-Sept%202025.pdf. ↩
  32. Woodland Carbon Code, Woodland Carbon Code Version 3.0, August 1, 2025, 8, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  33. IUCN UK Peatland Programme, Peatland Code Version 2.1, October 2024, 4, https://www.iucn-uk-peatlandprogramme.org/sites/default/files/2025-09/Peatland%20Code%20V2.1%20-%20Web%20Final-Sept%202025.pdf. ↩
  34. Woodland Carbon Code, Woodland Carbon Code Version 3.0, August 1, 2025, 50–58, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  35. IUCN UK Peatland Programme, “Peatland Code Key Documentation & Support (including Emissions Calculators),” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/using-peatland-code/support. ↩
  36. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  37. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 16, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  38. UK Government, “The Climate Change Act 2008 (2050 Target Amendment) Order 2019,” June 2019, https://www.legislation.gov.uk/uksi/2019/1056/contents/made. ↩
  39. UK Government (DESNZ), “Net Zero Strategy: Build Back Greener,” October 19, 2021, https://www.gov.uk/government/publications/net-zero-strategy. ↩
  40. Department for Environment, Food & Rural Affairs, Environmental Improvement Plan 2023, January 31, 2023, https://www.gov.uk/government/publications/environmental-improvement-plan. ↩
  41. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 64, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  42. UK ETS Authority (Department for Energy Security and Net Zero, Scottish Government, Welsh Government and DAERA), “UK Emissions Trading Scheme (UK ETS): A Policy Overview,” accessed December 2025, https://www.gov.uk/government/publications/uk-emissions-trading-scheme-uk-ets-policy-overview/uk-emissions-trading-scheme-uk-ets-a-policy-overview. ↩
  43. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 64, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  44. There are no binding obligations permitting UK ETS entities or other regulated sectors to use project-based carbon credits (WCC, Peatland Code, or international VCM credits) for statutory compliance. ↩
  45. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 64, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  46. Ibid, 13. ↩
  47. Ibid, 64. ↩
  48. Competition and Markets Authority, “Green Claims Code: Making Environmental Claims,” September 20, 2021, https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims. ↩
  49. Advertising Standards Authority, “Carbon Neutral and Net Zero Claims—Where Are We Now?” May 2024, https://www.asa.org.uk/news/carbon-neutral-and-net-zero-claims-where-are-we-now.html. ↩
  50. Financial Conduct Authority, PS23/16: Sustainability Disclosure Requirements (SDR) and Investment Labels, November 2023, 64, https://www.fca.org.uk/publication/policy/ps23-16.pdf. ↩
  51. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  52. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 13, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  53. Ibid., 40. ↩
  54. UK Parliament, “Digital Markets, Competition and Consumers Act 2024,” May 24, 2024, https://www.legislation.gov.uk/ukpga/2024/13/contents/enacted. ↩
  55. Advertising Standards Authority, “Updated Environment Guidance: Carbon Neutral and Net Zero Claims in Advertising,” February 9, 2023, https://www.asa.org.uk/news/updated-environment-guidance-carbon-neutral-and-net-zero-claims-in-advertising.html. ↩
  56. Financial Conduct Authority, PS23/16: Sustainability Disclosure Requirements (SDR) and Investment Labels, November 2023, 21, https://www.fca.org.uk/publication/policy/ps23-16.pdf. ↩
  57. Ibid., 64. ↩
  58. ABV Solicitors, “Carbon Credit Fraud,” February 23, 2025, https://www.abvsolicitors.co.uk/legal-guides/fraud-by-false-representation/carbon-credit-fraud/. ↩
  59. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 15, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  60. Principle 1 states that “credits should only be used in addition to ambitious action within value chains, consistent with a science-aligned pathway,” and the 2025 DESNZ consultation proposes to recognize the VCMI Claims Code as representative of best practice for how companies sequence internal reductions, in-setting, and external credit use. ↩
  61. Advertising Standards Authority, “Carbon Neutral and Net Zero Claims—Where Are We Now?” May 2024, https://www.asa.org.uk/news/carbon-neutral-and-net-zero-claims-where-are-we-now.html. ↩
  62. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 13, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  63. Ibid., 9. ↩
  64. Advertising Standards Authority, “Carbon Neutral and Net Zero Claims—Where Are We Now?” May 2024, https://www.asa.org.uk/news/carbon-neutral-and-net-zero-claims-where-are-we-now.html. ↩
  65. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 37, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  66. Transition Plan Taskforce, The Transition Plan Taskforce Disclosure Framework, October 2023, 34,https://www.ifrs.org/content/dam/ifrs/knowledge-hub/resources/tpt/disclosure-framework-oct-2023.pdf. ↩
  67. Financial Conduct Authority, PS23/16: Sustainability Disclosure Requirements (SDR) and Investment Labels, November 2023, 21, https://www.fca.org.uk/publication/policy/ps23-16.pdf. ↩
  68. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 37, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  69. Transition Plan Taskforce, The Transition Plan Taskforce Disclosure Framework, October 2023, 34,https://www.ifrs.org/content/dam/ifrs/knowledge-hub/resources/tpt/disclosure-framework-oct-2023.pdf. ↩
  70. Ibid., 35. ↩
  71. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 13, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  72. UK Parliament, “Digital Markets, Competition and Consumers Act 2024: Section 86 (Amount of Penalties),” May 24, 2024, https://www.legislation.gov.uk/ukpga/2024/13/section/86/enacted. ↩
  73. Advertising Standards Authority, “Carbon Neutral and Net Zero Claims—Where Are We Now?” May 2024, https://www.asa.org.uk/news/carbon-neutral-and-net-zero-claims-where-are-we-now.html. ↩
  74. Financial Conduct Authority, PS23/16: Sustainability Disclosure Requirements (SDR) and Investment Labels, November 2023, 21, https://www.fca.org.uk/publication/policy/ps23-16.pdf. ↩
  75. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 16, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  76. S&P Global, “UK Land Carbon Registry: Public View,” accessed December 2025, https://registry.spglobal.com/uklandcarbonregistry/public/wcc. ↩
  77. ICE Futures Europe, “ICE Futures UKA Daily Futures Contract Rules (Section 7H1),” accessed December 2025, https://www.ice.com/publicdocs/contractregs/193%207H1.pdf. ↩
  78. S&P Global, “UK Land Carbon Registry: Public View,” accessed December 2025, https://registry.spglobal.com/uklandcarbonregistry/public/wcc. ↩
  79. Ibid. ↩
  80. Woodland Carbon Code, Woodland Carbon Code version 3.0, August 1, 2025, 16, https://www.woodlandcarboncode.org.uk/sites/default/files/2025-09/Woodland%20Carbon%20Code_V3.0_August2025_0.pdf. ↩
  81. Ibid., 3. ↩
  82. Account applications are made online to the UK Land Carbon Registry (operated by S&P Global) and must include organization details (registered name, registration number, VAT or tax number, address, website, contact persons) and acceptance of the Registry Terms and Conditions. ↩
  83. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  84. Woodland Carbon Code, “Registry Rules of Use | Woodland Carbon Code,” April 23, 2025, https://www.woodlandcarboncode.org.uk/registry-rules-use. ↩
  85. IUCN UK Peatland Programme, “Buying and Selling Credits | IUCN UK Peatland Programme,” accessed December 2025, https://www.iucn-uk-peatlandprogramme.org/peatland-code/buying-and-selling-credits. ↩
  86. Financial Conduct Authority, “FCA Wins Case Against Capital Alternatives Limited and Others,” November 23, 2021, https://www.fca.org.uk/news/press-releases/fca-wins-case-against-capital-alternatives-limited-and-others. ↩
  87. Woodland Carbon Code, “Registry Rules of Use | Woodland Carbon Code,” April 23, 2025, https://www.woodlandcarboncode.org.uk/registry-rules-use. ↩
  88. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  89. As of December 2025, the average price for a Pending Issuance Unit is listed at £26.85, providing one of the few publicly available reference points for UK land-sector credit pricing; Woodland Carbon Code, “UK Carbon Market Prices,” accessed December 2025, https://www.woodlandcarboncode.org.uk/uk-carbon-prices. ↩
  90. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, https://www.gov.uk/government/consultations/voluntary-carbon-and-nature-markets-raising-integrity. ↩
  91. HM Revenue & Customs, “Revenue and Customs Brief 7 (2024): VAT Treatment of Voluntary Carbon Credits,” May 9, 2024, https://www.gov.uk/government/publications/revenue-and-customs-brief-7-2024-vat-treatment-of-voluntary-carbon-credits. ↩
  92. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  93. HM Revenue & Customs, “Revenue and Customs Brief 7 (2024): VAT Treatment of Voluntary Carbon Credits,” May 8, 2024, https://www.gov.uk/government/publications/revenue-and-customs-brief-7-2024-vat-treatment-of-voluntary-carbon-credits/revenue-and-customs-brief-vat-treatment-of-voluntary-carbon-credits. ↩
  94. KPMG, “What Might a Company That Purchases Carbon Credits Voluntarily Need to Consider?” July 2024, https://kpmg.com/xx/en/our-insights/ifrg/2024/climatechange-ias2-voluntary-carbon-credits.html. ↩
  95. KPMG, “Carbon Offsets and Credits Under IFRS® Accounting Standards,” March 2, 2023, https://kpmg.com/us/en/articles/2023/carbon-offsets-credits-ifrs-accounting-standards.html. ↩
  96. Ibid. ↩
  97. Ibid. ↩
  98. Competition and Markets Authority, “Green Claims Code: Making Environmental Claims,” September 20, 2021, https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims. ↩
  99. UK Parliament, “Digital Markets, Competition and Consumers Act 2024: Section 86 (Amount of Penalties),” May 24, 2024, https://www.legislation.gov.uk/ukpga/2024/13/section/86/enacted. ↩
  100. Financial Conduct Authority, “FCA Wins Case Against Capital Alternatives Limited and Others,” November 23, 2021, https://www.fca.org.uk/news/press-releases/fca-wins-case-against-capital-alternatives-limited-and-others. ↩
  101. Woodland Carbon Code, “UK Carbon Market Prices,” accessed December 2025, https://www.woodlandcarboncode.org.uk/uk-carbon-prices. ↩
  102. Financial Conduct Authority, “FCA Wins Case Against Capital Alternatives Limited and Others,” November 23, 2021, https://www.fca.org.uk/news/press-releases/fca-wins-case-against-capital-alternatives-limited-and-others. ↩
  103. HM Revenue & Customs, “Revenue and Customs Brief 7 (2024): VAT Treatment of Voluntary Carbon Credits,” May 9, 2024, https://www.gov.uk/government/publications/revenue-and-customs-brief-7-2024-vat-treatment-of-voluntary-carbon-credits. ↩
  104. Woodland Carbon Code, “How to Buy and Use Units,” accessed December 2025, https://www.woodlandcarboncode.org.uk/how-buy-and-use-units. ↩
  105. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 63–64, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  106. Ibid. ↩
  107. S&P Global, UK Land Carbon Registry: Terms and Conditions, accessed December 2025, https://www.spglobal.com/content/dam/spglobal/corporate/en/documents/legal/UK_Land_Registry_TCs.pdf. ↩
  108. UK ETS Authority (Department for Energy Security and Net Zero, Scottish Government, Welsh Government and DAERA), Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme: Main Response, June 30, 2025, https://www.gov.uk/government/consultations/integrating-greenhouse-gas-removals-in-the-uk-emissions-trading-scheme. ↩
  109. Department for Environment, Food & Rural Affairs, “Meet the First Organisations Piloting Nature Investment Standards,” November 6, 2025, https://defraenvironment.blog.gov.uk/2025/11/06/meet-the-first-organisations-piloting-nature-investment-standards/. ↩
  110. Woodland Carbon Code, “How to Buy and Use Units,” accessed December 2025, https://www.woodlandcarboncode.org.uk/how-buy-and-use-units. ↩
  111. Department for Energy Security and Net Zero, Voluntary Carbon and Nature Markets: Raising Integrity, April 16, 2025, 63–64, https://assets.publishing.service.gov.uk/media/67ff86a6ed87b81608546788/vcnm-integrity-consultation-document.pdf. ↩
  112. Department for Environment, Food & Rural Affairs, “Meet the First Organisations Piloting Nature Investment Standards,” November 6, 2025, https://defraenvironment.blog.gov.uk/2025/11/06/meet-the-first-organisations-piloting-nature-investment-standards/. ↩
  113. UK ETS Authority (Department for Energy Security and Net Zero, Scottish Government, Welsh Government and DAERA), Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme: Main Response, June 30, 2025, https://www.gov.uk/government/consultations/integrating-greenhouse-gas-removals-in-the-uk-emissions-trading-scheme. ↩
  114. Transition Plan Taskforce, The Transition Plan Taskforce Disclosure Framework, October 2023, 34,https://www.ifrs.org/content/dam/ifrs/knowledge-hub/resources/tpt/disclosure-framework-oct-2023.pdf. ↩
  115. UK Parliament, “Digital Markets, Competition and Consumers Act 2024: Section 86 (Amount of Penalties),” May 24, 2024, https://www.legislation.gov.uk/ukpga/2024/13/section/86/enacted. ↩
  116. Advertising Standards Authority, “Carbon Neutral and Net Zero Claims—Where Are We Now?,” May 2024, https://www.asa.org.uk/news/carbon-neutral-and-net-zero-claims-where-are-we-now.html. ↩
  117. Financial Conduct Authority, PS23/16: Sustainability Disclosure Requirements (SDR) and investment labels, November 2023, 64, https://www.fca.org.uk/publication/policy/ps23-16.pdf. ↩
  118. ABV Solicitors, “Carbon Credit Fraud,” February 23, 2025, https://www.abvsolicitors.co.uk/legal-guides/fraud-by-false-representation/carbon-credit-fraud/. ↩
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