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Soil Capital Belgium SRL

Soil Capital is an independent agronomy company working to empower farmers to commit as many hectares as possible of farmland to more profitable, regenerative agriculture to address the climate urgency.

Lobbying Activity

Meeting with Christian Holzleitner (Head of Unit Climate Action)

26 Nov 2025 · Policy options for market-based incentives in the agri-food value chains.

Meeting with Kerstin Rosenow (Head of Unit Agriculture and Rural Development)

15 Sept 2025 · Exchange of views on the role of public and private financing to accelerate the agricultural transition

Response to Verification of carbon removals, carbon farming and carbon storage in products

1 Jul 2025

Article 9, Point 2 There is ambiguity in the requirement for Certification Schemes to list on their registries those operators with. Would such listings be publicly accessible to anyone or rather just visible to other Schemes and Registries? If the former, this does not contribute to effective governance but does create a barrier to entry to operators who may fear an unjustified degree of public scrutiny on activities (such as expiry of a certificate) which could be readily misinterpreted. We recommend the requirement be list on their registries ONLY FOR THE BENEFIT OF OTHER REGISTRIES AND SCHEMES those operators Article 12, Point 1(a) This clause would result in unnecessary costs and barriers to entry where a group of operators aggregates operators from multiple EU member states. This is already common practice today with at least three of the EUs major group of operators (Soil Capital, Klim and Agreena) operating across multiple EU member states. The intention of the requirement can be met if the SAMPLING of a group audit includes stratification according to similar geographic and pedoclimatic characteristics. That way, a group of operators can exist across multiple geographies, ensuring audit costs are manageable, but unique geographic or pedoclimatic conditions are still given due scrutiny. Article 12, Point 6 The requirement that Random selection shall representat least 25% of the total area covered by the activities of the group needs clarification. There are two plausible interpretations that seem logically impossible. Take a group of operators with 2,000 farms - average farm size of 250 ha each - 500,000 ha in total. Per Point 4, the sample size will be 45. Per Point 6, random selection shall represent at least 25% of the members of the sample - 11 farms. The second half of Point 6, then could be understood to mean that this same 25% of the sample (the randomly selected part) must also represent at least 25% of the total area covered by the activities of the group. The group covers 500,000 ha. 25% of that area is 125,000 ha. 11 farms covering this area would mean the average farm size would be 11,363 ha. Even if the second half of Point 6 means that the overall sample itself must also represent at least 25% of the total area covered by the activities of the group, this would mean that the sample should reflect 125,000 ha (500,000 ha / 4) in the example above, leading to an average farm size of 2,777 ha (125,000 / 45). Article 13, Point 4(c)(1) Experience in fuel life-cycle assessment is not appropriate as a core competency for auditors focused on carbon removals. Article 13, Point 4(c)(4) A balance is needed between the technical knowledge of auditors for rigour and being realistic about the size of the market for duly qualified auditors today. We encourage the Commission to conduct a market analysis to evaluate the readiness of the audit market to meet the requirements of Point 4(c). More specifically, Point 4(c)(4) is not well defined which could lead to unnecessary disputes. It would be more appropriate to require that where the scope of the auditorganic carbon levels, proven experience interpreting comparable laboratory or field analysis results; Article 16 There is already an industry-created solution live and operational that Point 1(a) and (b): FarmVault: https://www.climate-ag.org/ Certification Schemes and registries should be required to use this industry-backed system as an efficient and scalable mechanism to implement these requirements. Annex III Annex III includes personal information for operators that is covered by GDPR (name and address, geographical locations of activity). Article 3, Point 3 states that this information must be issued by the Certification Body. If those reports are to be public, that is not appropriate.
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

16 Jun 2025 · Soil Monitoring Law, carbon farming,

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

15 May 2025 · State of play of the EGD; future of CAP; future MFF; EU position as an (un)investable jurisdiction; beyond growth Dinner discussion at the annual board mtg

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

22 Apr 2025 · Speech on the state of play of the EGD

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

11 Feb 2025 · Activities of Soil Capital Cooperation with private sector actors to support farmers in implementing practices beneficial for the soil

Response to Carbon Removal Certification

24 Jan 2023

1. On Quantification : Reduction in greenhouse gas emissions resulting from the implementation of the carbon removal activity not in scope of net removals but can be counted as a co-benefit to increase the value of the certificate. There could be a technical accounting challenge in separating out emissions reductions/increase not related to the net carbon removal and those that are related to the net carbon removal activity. 2. On additionality : The preferred use of a standardized baseline reflecting the standard performance of comparable activities in similar social, economic, environmental and technological circumstances and geographical locations is very positive because, among others, it will recognize the efforts of first movers. Indeed, in arable agriculture, it is crucial to recognize that each year there is a regular opportunity for land managers to challenge and change their previous decisions on farming practices. This means that approaches to defining additionality that only recognize new practices compared to an individual baseline will create a perverse incentive for land managers altering their practices for the period a baseline is set in order to maximise their benefit. We therefore believe that in this context, a very thoughtful approach to rewarding the maintenance of practices that continue to result in additional carbon removals is needed. 3. On Long-term storage : It is said in the framework proposal that "Carbon removals generated by carbon farming and carbon storage in products should be subject to an expiry date (end of monitoring), after what the carbon is considered to be released unless proof of the maintenance of the carbon storage through uninterrupted monitoring activities." Furthermore it is said that "Liability mechanisms should be introduced to address cases of reversal (e.g. discounting of carbon removal units, collective buffers or accounts of carbon removal units, and up-front insurance mechanisms)" We observe carbon farming schemes in various European markets that do make land managers liable for reversals today. We often hear that the consequence of taking this kind of approach is to dissuade land managers from engaging in such schemes in the first place, since they have so many other risks and liabilities to manage already. What we find is more successful is to offer land managers a positive financial incentive, such as a balloon payment, for respecting permanence periods. We also have positive experience of making multi-year monitoring plans (up to 15 years) and operating a buffer account. Finally, we find the idea to issue certificates with specific durations interesting (and observe precedents in the US) but would need to see analysis of the consequent market dynamics that would result from such an approach. 4. We remain convinced that EU certification framework should allow different types of certificates for different types of removals (different duration of removals or robustness of monitoring, reporting and verification). Our view is that to fail to design for the inherent diversity in different types of carbon removal is to design to fail. 5. On the regulatory process : The proposal does not settle the debate on the financing of these carbon credits (public or private ; scope 3 or credits, etc.), nor the potential competition or partnership between this carbon removal certification and public tools such as the Common Agriculture Policy. Coexistence of private and public initiatives in the EU regulatory framework still needs to be clarified. 6. On the regulatory process : For carbon farming, it is said in the proposal that "the delegated act will initially focus on a limited number of practices, such as agroforestry or peatland restoration, and will then be completed". Our concern is that because arable agriculture and mineral soils are not yet specifically identified, they could be deprioritized.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

26 May 2020 · Sustainable food systems