What the EU Carbon Removal Certification Framework (CRCF) is and why it matters for buyers
CRCF is the EU-level certification framework for carbon removals and carbon farming, set out in Regulation (EU) 2024/3012. It is voluntary, but it is designed to make “quality” measurable through rules that can be checked, audited, and compared across suppliers.
CRCF covers three buckets that matter for procurement teams. It applies to permanent carbon removals, carbon farming, and carbon storage in products. The buyer-side goal is practical: turn debates about additionality, quantification, MRV, and greenwashing risk into verifiable requirements that can survive internal review and external scrutiny.
CRCF is moving from legislation to operational rules in 2025 to 2026. The Commission has adopted Implementing Regulation (EU) 2025/2358 on transparency and supervision for certification schemes and certification bodies, including expectations around audits, accreditation, and controls. In February 2026, the Commission adopted the first set of methodologies for permanent removals, including DACCS, BECCS/BioCCS, and biochar, with scrutiny by Parliament and Council and entry into force expected around April 2026.
CRCF makes certified units more “procurement-grade” in ways that show up immediately in buyer workflows. Vendor due diligence gets easier because the same EU framework defines what must be evidenced. Comparability improves because suppliers are pushed into methodology-aligned reporting. Internal policy becomes easier to enforce because durability and monitoring requirements can be written into procurement rules and committee approvals, especially for multi-year offtake programs.
Two constraints matter right away for international buyers. Claims and cross-border use are shaped by how certified units relate to EU climate targets and NDC accounting, including the question of corresponding adjustments, with a review expected in 2026. Infrastructure also matters because a Union-wide registry is planned by 2028, so near-term execution depends on how CRCF-recognised schemes and registries handle issuance, transfers, and audit trails before the EU registry is live.
CRCF answers a foundational question for the market: what counts as one tonne of EU-certified removal. The next question is market-facing: how do you create liquidity and price discovery around that tonne, without losing integrity. That is where Nasdaq’s entry becomes consequential.
Why Nasdaq is backing CRCF removals and what a liquid secondary market could change
Nasdaq is positioning itself as market infrastructure for carbon, not as a project developer. It has launched technology intended to support issuance, settlement, and custody of carbon credits, alongside a carbon taxonomy and APIs that can connect marketplaces and registries and reduce manual, bilateral OTC friction.
Price transparency is already part of the playbook for engineered removals. Nasdaq, together with Puro.earth, publishes benchmark indices under the CORC family, including CORCX and CORCCHAR for biochar. Nasdaq’s published snapshot dated 01/02/2026 shows CORCX at €140.10 and CORCCHAR at €139.14, giving buyers a reference point for budgeting, benchmarking, and negotiating forward pricing.
Secondary liquidity changes the economics of durable CDR because most durable supply is still sold as forward offtake. A tradable secondary market for CRCF units could reduce the illiquidity premium embedded in long-dated contracts. It could also enable hedging of price and volume exposure, and it could support intermediaries such as traders and market makers who can warehouse risk. For developers, that can translate into better financing options, including inventory-style financing once issued units exist and can be pledged or sold with clearer title.
Brokered intermediation is already dominant in parts of durable CDR. Puro.earth reports that around 85% of biochar transactions are done via brokers or platforms rather than directly. That is a signal about market microstructure: participants already want standardised access and repeatable processes, even if the market is not yet liquid in the way commodities markets are.
EU-certified removals are also structurally easier to standardise into contracts. CRCF introduces clearer rules around monitoring, liability, and reversals, which reduces ambiguity about what “delivery” means. When the underlying quality is specified by a public framework, it becomes simpler to define standard contract terms for spot and forwards, and eventually to imagine clearing-style mechanics if the market matures.
Liquidity still needs a credible underlying and replicable MRV. Europe needs test cases that show durability, supply chain control, and auditability in practice, not just on paper. Stockholm is becoming one of those reference points.
The Stockholm biochar project as a test case for durable removals and MRV expectations
Stockholm is emerging as an early supply corridor for durable removals, with projects that buyers can point to when building a portfolio narrative. A widely cited example is Beccs Stockholm by Stockholm Exergi, a BECCS facility under construction with a stated target to be operational by the end of 2028 and a stated capacity of 800,000 tCO₂ per year captured and permanently stored. The same project communication frames roughly 7.83 MtCO₂e removed over ten years, which helps buyers think in portfolio sizing rather than pilot-scale tonnes.
Project bankability is the point, not just the tonnes. Stockholm Exergi has communicated an investment of SEK 13 billion, with a financing mix that includes public support such as the Innovation Fund alongside expected private market revenues. That structure explains why offtake contracts matter beyond procurement: they can be part of what makes project finance possible, and MRV quality becomes a condition for capital.
Corporate demand is also shaping the template for long-dated delivery. Stockholm Exergi has announced an agreement with Microsoft for 3.33 million tonnes of permanent removals with delivery from 2028 over about ten years. For buyers, the practical takeaway is how delivery schedules, commissioning milestones, and reporting expectations get written into multi-year contracts when the underlying asset is not yet issued.
MRV expectations rise sharply when storage is geological and the supply chain is long. The project describes storage at more than 800 metres below the seabed in the North Sea, which implies a chain-of-custody and mass balance story across capture metering, compression or liquefaction, shipping, injection, and site monitoring for leakage. The buyer question that keeps coming up is simple: what is the verified boundary, and where does operator responsibility begin and end across that chain.
Biochar remains part of the same CRCF conversation even when the headline story is BECCS. The Commission’s first methodology set for permanent removals includes both biochar and BioCCS/BECCS, which invites direct comparison of risk profiles. Biochar leans on chemical-physical durability but needs strong traceability for use and end-of-life. BECCS leans on geological permanence but brings more operational interfaces that must be audited.
Flagship projects make the trading constraints visible. Delivery risk, reversal and liability, and the definition of a “net tonne” all determine whether a unit can be priced and transferred with confidence.
Pricing, risk and contract design in a tradable CRCF market from delivery risk to reversal and liability
Pricing will split into two markets even if CRCF succeeds. Spot pricing will apply to issued units that can be transferred and retired. Forward pricing will dominate for years because many durable projects are still pre-issuance, especially those with construction and commissioning timelines into 2028 and beyond.
A tradable CRCF curve will embed a stack of risks that buyers already price informally today. Construction and commissioning risk is central for capital-intensive projects. Methodology and regulatory risk matters because delegated acts and audit requirements can change what qualifies. Counterparty risk remains real because delivery is operational, not just administrative. MRV and registry costs become more visible once the market standardises data fields and audit trails. Nasdaq’s CORC index levels around €139 to €140 in early 2026 provide a public anchor for engineered removals, but they do not remove the need to price these risk layers explicitly.
Reversal and liability mechanics are not optional if units are tradable. The Council communication on CRCF highlights operator responsibility to manage reversals during the monitoring period, which must be at least as long as the activity period, and it points to the need for liability mechanisms in methodologies, including cases where monitoring is incomplete or interrupted. For contracts, this pushes parties toward standard “make-good” language, replacement unit rules, and timelines that can be enforced without bespoke negotiation every time.
Fungibility is the design problem for a secondary market. Contracts need minimum specs that let a buyer resell without rewriting the deal: vintage or issuance date, CRCF methodology type (biochar vs DACCS vs BioCCS), durability class, storage geography where relevant, buffer or insurance features, certification scheme and accredited body, and clear transfer and retirement rules with a complete audit trail. Nasdaq’s taxonomy and API approach matters here because normalised data fields are what allow marketplaces, custodians, and risk teams to treat units as comparable.
Delivery risk is where forward contracts either become financeable or fall apart. Buyers typically ask for conditions precedent such as final investment decision, permits, and secured access to transport and storage. They also negotiate remedies for delay, data access rights for MRV, and credit substitution rules. Substitution is especially important if the buyer wants the position to be transferable, because the replacement must match the attributes that the secondary market recognises as equivalent.
Market plumbing decides whether liquidity is real. Settlement needs clear timing, title transfer needs to be unambiguous, and registry controls must prevent double counting. Nasdaq’s focus on digitising the lifecycle from issuance to transfer to retirement targets a known weakness of the voluntary carbon market, where manual processes can create operational errors that show up as reputational risk.
Even with strong contracts, buyers will ask a governance question: what does a CRCF unit mean for reporting and for climate claims, and how does it sit next to EU ETS and CSRD requirements.
How CRCF credits could interact with EU ETS, CSRD reporting and corporate net-zero claims
CRCF is voluntary and does not make removals fungible with EU ETS allowances. The regulation and the broader policy context around industrial carbon management do, however, point to future assessment of whether and how removals could be accounted for in the ETS. For buyers and investors, that creates an option value narrative: CRCF units can be seen as closer to “pre-compliance grade” in governance terms, without assuming future ETS eligibility.
CSRD raises the bar on evidence, not just intent. For companies subject to CSRD and increasing assurance expectations, CRCF can strengthen the audit trail behind purchased removals because it is built around supervised certification schemes and certification bodies. The practical benefit is clearer documentation for how removals procurement fits into a climate transition plan, especially when discussing neutralisation of residual emissions, without presenting removals as a substitute for Scope 1 to 3 reductions.
Claims management will be a deciding factor for multinational buyers. CRCF introduces guardrails on integrity and touches the relationship between certified units and EU climate objectives, with corresponding adjustments and related rules flagged for review in 2026. Companies operating across jurisdictions will need internal policy that prevents double claiming and aligns communications with how NDC accounting is handled, even when the purchase is voluntary.
Asset-class clarity helps avoid category errors. EU ETS allowances are compliance instruments under cap-and-trade. CRCF units are certified removals under a voluntary EU framework. Legacy voluntary credits sit under different governance and quality regimes. Treating these as interchangeable in reporting or communications is where companies tend to get into trouble with auditors, regulators, and customers.
Procurement strategy is likely to shift toward compliance readiness. CRCF could become the default European reference for durable CDR portfolios such as biochar, BECCS, and DACCS, alongside global voluntary standards. As reporting expectations tighten, buyers may reduce reliance on non-certified units for the most scrutinised claims and instead prefer contracts that are written to be compatible with CRCF-style requirements.
Execution is now the bottleneck. Standards need to become usable, registries need to support clean transfers, and adoption needs to show up in repeatable transactions that can be priced and traded.
What to watch next standards, registry infrastructure, market adoption and cross-border demand signals
The first thing to watch is the standards timeline. The Commission adopted the first permanent removals methodologies on 3 February 2026, with a scrutiny window of two months extendable by two months, and entry into force expected around April 2026. The immediate market question is which methodologies become first movers in real issuance, because liquidity cannot form around a spec that is not yet used at scale.
The second thing to watch is certification capacity. Implementing Regulation (EU) 2025/2358 sets expectations for transparency and supervision of certification schemes and certification bodies, but the market still needs enough accredited auditors and enough operational schemes to avoid bottlenecks. The Union-wide registry planned by 2028 is also a key milestone, and the interim period will test how well recognised private registries and schemes can support issuance and transfers with robust chain-of-title.
Adoption signals will matter more than announcements. The Commission has pointed to initiatives such as an EU Buyers’ Club for permanent removals and carbon farming, which could aggregate demand and push standard contracting. Large corporate offtakes like the Microsoft and Stockholm Exergi agreement also anchor the forward curve by showing what long-dated delivery commitments look like in practice.
Liquidity indicators are measurable even early on. Watch whether price references like Nasdaq’s CORC indices start appearing in contracts as benchmarks. Watch whether marketplaces converge on standardised data fields and API-based integration rather than PDFs and bespoke spreadsheets. Watch for the first “clean” secondary transfers where chain-of-title, custody, and retirement controls are easy to verify.
Cross-border demand will be shaped by audit readiness and optionality. Some buyers will want CRCF units because they expect higher scrutiny and want stronger evidence. Others will want them because they see a chance of future regulatory linkage, even if nothing is promised today. Any Commission clarification in 2026 on corresponding adjustments and how certified units relate to climate targets will influence this demand.
Controversies will show up as risk premia, not just headlines. Feedstock sustainability for BECCS, additionality, and leakage are exactly the issues methodologies must handle, and disputes over these points can widen bid-ask spreads, increase collateral haircuts, and reduce willingness to make markets. A liquid CRCF market will only emerge if integrity rules reduce uncertainty enough that intermediaries can price risk consistently.
