BeZero Carbon Ltd
BeZero Carbon is a carbon ratings agency.
ID: 608623792999-55
Lobbying Activity
Meeting with Beatriz Yordi (Director Climate Action)
30 Sept 2025 · Carbon credits
Response to European Climate Law amendment
15 Sept 2025
BeZero Carbon strongly supports the European Commissions proposal to introduce a target to reduce the EUs net greenhouse gas emissions by 90% by 2040. Setting ambitious interim targets is vital if the EU is to deliver on its long-term goal to achieve net zero emissions by 2050. However, this is set against a backdrop of wavering political and public support for decarbonisation. Given this context, we welcome the Commissions inclusion of additional flexibilities to support delivery of the 2040 target in a more cost effective manner - namely driving up removals capacity within the EU and using Article 6 credits imported from overseas to meet a proportion of the target. Both of these flexibilities have the potential to drive lower costs while also showing climate leadership through the development of new industries and creation of jobs. At the same time, concerns that credit-based approaches do not deliver the climate impact they claim to must be dealt with robustly. Not doing so risks integrity scandals linked to specific credits and projects undermining public faith in the EUs climate strategy. A key mistake of carbon credit markets of the past is to believe that defining high quality methodologies for generating credits is sufficient action to ensure credits have a high likelihood of achieving their claimed climate impact. In reality, projects operating under the same methodology can deliver considerably different outcomes (see our ratings database of over 600 projects for evidence of this: https://bezerocarbonmarkets.com/). This applies both to international credits and credits generated within the EU under (e.g.) CRCF What is therefore required to prevent poor quality credits being used towards EU climate targets is some degree of project-specific risk assessment. This should be backed by an incentive or mandatory threshold to ensure that credits with a higher likelihood of delivering on their carbon claim are used to achieve policy objectives. Carbon credit ratings are the best tool available to deliver this risk assessment. Ratings assess the likelihood a given credit achieves a tonne of COe avoided or removed through rigorous, independent analytical assessment. To date, BeZero Carbon has assessed over 650 projects across 81 countries and 41 sub-sectors, and changed the dynamics of the voluntary carbon market such that each incremental notch on our rating scale is associated with (on average) a 40% price premium. We believe that ratings can and should play the same role in the policy setting, as a guardrail against low quality credits. In an upcoming report we show that designing the integration of credits into the EU climate targets using ratings can achieve the most cost efficient outcome by allowing a wider range of climate solutions to be used while maintaining integrity standards, saving a potential 40bn EUR per annum by 2040. This is based on ratings providing the enabling conditions under which lower cost removal pathways such as reforestation or biochar can contribute to policy goals in a high integrity way, compared with an alternative scenario where only geologic removal technologies such as BECCS are deemed to be of sufficient quality. We would be pleased to share this report in full when published.
Read full response8 Jul 2025
Please find attached a briefing note summarising our argument for the EU to consider a role for project-level risk assessment in the form of carbon ratings to deliver a more effective integration of removals into the ETS. This supplements the feedback we have provided in response to the consultation questionnaire.
Read full responseResponse to Verification of carbon removals, carbon farming and carbon storage in products
30 Jun 2025
We have two pieces of feedback: (1) Implement clear public disclosure requirements for project technical information; (2) Consider introducing a requirement for all CRCF projects to be assessed by an independent carbon credit ratings agency. More detail on these recommendations is provided below. (1) The registry that hosts CRCF projects must mandate an appropriate level of public technical information disclosure from projects, as a minimum meeting the level of disclosure required by voluntary carbon market registries. For the CRCF market to operate effectively, and have credibility with market actors & the public, its vital that third parties can scrutinise the carbon claims made by projects, and the evidence for any co-benefit claims. Ratings agencies, insurance companies, consultants and in-house due diligence teams will need this information in order to operate in the CRCF market. As it stands, the regulation makes reference to minimum information requirements for activity plans and audit reports in the Annex. However, it is not clear that these information requirements: (i) Meet the same standard expected by voluntary carbon market registries; (ii) Will lead to public disclosure (as opposed to just being reported to the regulator). Both these conditions must be met. The specific information that should be disclosed publicly for CRCF projects includes (all updated on an ongoing basis): - Basic project information name, description, location, project boundary etc. - Details of tests applied to establish a projects additionality. - Details of the projects carbon accounting calculations in a standardised format - The projects third-party validation and verification reports. (2) CRCF methodologies will not produce carbon credits that are free from performance risk i.e. there will always be a risk that credits do not live up to their claim to represent a tonne of CO2 removed. This is not a specific criticism of CRCF methodologies it is an inherent property of all carbon crediting projects, which are subject to scientific uncertainty, use of inappropriate assumptions, real-world natural hazards and other issues. These issues create risk of credit underperformance, at the point of credit issuance and on an ongoing basis over the lifetime of a project. Methodologies are needed to set a minimum standard, but risk will always primarily be driven by decisions taken at the project level. Carbon credit ratings have emerged as a tool to characterise this risk, and therefore manage it. Ratings have been adopted by actors across the market, and are increasingly influential in driving demand and price. The ability to attract demand and higher prices through a better rating gives projects an incentive to adopt approaches which minimise performance risk of. From a buyers perspective, ratings enable you to navigate the market with a full picture of the performance risk of the credits available for purchase. As a minimum, the EU must make project technical information publicly available to facilitate the entry of ratings agencies into the market. But going beyond this, we think that consideration should be given to making independent ratings a requirement for CRCF projects, rather than just enabling voluntary adoption. There are two key reasons for this. First, since CRCF is administered by the EU, and backed by public funding, it is imperative that the authority responsible for the market ensures that the appropriate incentives are in place to maximise the carbon impact achieved per CRCF credit. The introduction of universal, publicly available ratings would support this objective. Second, the EU is considering integrating CRCF credits into the ETS. In this context, the voluntary adoption of ratings is unlikely since buyers are incentivised towards minimising cost. Here, a mandatory ratings requirement may be necessary to deliver the desired market outcome of buyers prioritising higher performance credits.
Read full responseMeeting with Sebastien Paquot (Head of Unit Climate Action)
22 Jan 2025 · Presentation of BeZero’s carbon ratings products and lessons learned from their carbon credits assessments.