Qarlbo Biodiversity
Qarlbo Biodiversity has a mission to renew our planet's lifeline - biodiversity.
ID: 296529896220-53
Lobbying Activity
Response to Roadmap towards Nature Credits
25 Sept 2025
The Roadmap towards Nature Credits presented by the EU commission on the 7th of July represents a promising first step towards a standardized and credible European nature market. Nature credit markets are inherently complex structures with inbuilt risks and opportunities. Building a new market infrastructure with integrity safeguard from scratch is a very resource-demanding and time-consuming project. Therefore, we noticed with great satisfaction that the EU commission recognized the work on integrity principles already delivered by the BCA/IAPB/WEF troika with the High-Level Principles for High Integrity Credits as a foundation for future work with market development. We understand the roadmap as laying the inspirational first step for a future certification system, which could help achieve market trust from investors and potential project financers. Among many critical topics, the use case for nature credits is important to highlight as fundamental for any ambition to scale a market for nature credits. In the roadmap, nature-positive contributions and co-benefits to CRCF based carbon project is mentioned. We believe the EU commission, in its work on nature credits, in addition should consider the enormous potential that lies in supply chain impact compensation, and as concrete examples of a nature positive action after avoidance and minimizations efforts have been implemented. We anticipate this use case area to drive demand in the voluntary space in the coming years, especially considering the ongoing work within NPI (Nature Positive Initiative) and TNFDs transition planning initiative. A critical complement to the ongoing efforts from BCA/IAPB/WEF to develop high-level integrity principles, is efforts to incentivize demand side actors e.g. by defining and developing attractive and cost-efficient carrots and/or sticks based on EU or member state level policies. We do believe that the EU-commissions ambition with nature credits can be realized through a well-designed independent certification system, where certification can be attached onto projects validated by third party using approved Methodologies. Future work should emphasize the following: The EU commission should as a first step consider developing a set of eligibility criteria based on the already existing integrity principles from previous work within BCA/IAPB/WEF for Nature Credits In addition to or instead of a project-by-project certification approach, an approval mechanism for Methodologies meeting the EU commissions eligibility criteria can be designed. Such an approval procedure could replace the need to develop new Methodologies as part of the work stream during 2026-2027. A potential approval mechanism for methodologies should include an HLP-alignment test. The BCA is currently developing such assessment protocols for hands-on evaluation of methodology alignment with the HLP. The nature credit expert group or other competent part should consider exploring two especially promising uses-cases for nature credits; a) supply chain insetting/compensation and b) product integration. Supply chain insetting refers to financing nature improvements in corporates supply areas with a direct positive impact on the corporates production and/or resilience of raw material supply. Product integration refers to a use case where nature credits are used to create nature-positive product categories e.g. in renewable energy sector. Identifying barriers for demand side actors and develop recommendations for how EU and member states can help incentivize corporates in engaging in nature credit markets. This could potentially include tax incentives, subsidies, novel claims and other promotional benefit schemes. Interact with other major sustainability initiatives with strong corporate relevance such as SBTN, TNFD and NPI (Nature-Positive Initiative) in order to understand how nature credits can be integrated into existing sustainability frameworks.
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