Verra released version 1.1 of its EV charging methodology VM0038 and its companion additionality module VMD0049 on August 19, and the practical effect is counterintuitive: the faster electric vehicles spread in a market, the harder it becomes for new charging projects there to earn carbon credits. The revision ties access to the methodology’s fast-track additionality route, the so-called positive list, to explicit EV adoption thresholds, and for the first time treats slow AC charging and DC fast charging as separate cases. For project developers, buyers and investors, this is a rule change that converts EV market success into a shrinking crediting window.
What Changed in VM0038 v1.1
VM0038 covers projects that install EV charging systems and associated infrastructure for passenger and freight vehicles. The credited reductions come from a simple chain: the electricity delivered by project chargers lets EVs provide transport that would otherwise have been done by fossil fuel vehicles, and the displaced tailpipe emissions, minus the emissions from the electricity consumed, form the quantifiable reduction.
The weakest link in that chain has always been additionality. If EVs and charging networks are already expanding without carbon finance in a given market, why should a new charger earn credit revenue? Verra’s answer in v1.1 is to make the screening criteria explicit and market-dependent. The revision updates the methodology’s applicability conditions to account for EV market share in each country, refreshes the positive list in VMD0049, and adopts two VCS tools to tighten integrity: VT0008, used to demonstrate additionality for projects that do not meet the positive list, and VT0011, used to calculate the emission factor of the electricity consumed by project chargers.
The update also brings the methodology onto the latest VCS template, incorporates a corrections document that fixed an equation, and simplifies parts of the quantification approach. Verra classifies the changes as minor revisions. The process began as a submission by the Climate Neutral Business Network and later transitioned to a Verra-led development, with a public consultation held in spring 2026.
Two Thresholds: Slow and Fast Charging Now Diverge
The most consequential change sits inside the positive list. Under VMD0049 v1.1, passenger vehicle charging is split into two tracks with different penetration ceilings. For AC Level 1 and Level 2 charging, a project location qualifies if EVs make up no more than 2.5% of the vehicle stock, or, where stock data is unavailable, no more than 10% of average vehicle sales over the past three years. For DC fast charging, the ceilings are higher: 5% of vehicle stock or 20% of recent sales.
The logic is not that fast charging is inherently greener. It is an additionality judgment. Slow AC charging is closer to standard infrastructure once EV adoption takes off, so it loses its claim to carbon finance earlier. DC fast charging, which enables longer trips and heavier use cases, remains scarce for longer and is therefore allowed at higher penetration levels. The result is that within a single country, AC charging projects may already fall outside the positive list while DC fast charging projects in the same market still qualify.
Falling off the list is not a ban. Projects outside the positive list can still pursue crediting, but they must switch from the standardized shortcut to a full project method: investment analysis or barrier analysis, plus a common practice test, now formalized through VT0008. That route is slower, more expensive and less predictable, which in practice is where many marginal projects will drop out.
What It Means for Developers, Buyers, and Investors
For charging infrastructure developers, carbon revenue is moving from a scalable subsidy to an early-stage incentive. Business plans that assumed credit income across the life of a charging network now need to be stress-tested against local EV registration data, because the positive list status of a region can change as adoption crosses the thresholds. The same dynamic strengthens the case for heavy-duty and freight charging, where penetration is lower and the crediting window stays open longer.
For credit buyers, the revision is a quality signal. EV charging credits have faced persistent criticism precisely on additionality grounds, and a methodology that auto-expires its own fast track as markets mature produces supply that is easier to defend in corporate claims. The trade-off is that forward supply from mature EV markets will thin out, concentrating new issuance in earlier-stage geographies where MRV and grid data may be weaker.
For investors, the message is about revenue durability. Credit-linked financing for charging networks should now price in a declining credit contribution over time, with VT0011 introducing more rigorous electricity emission factor accounting that will also affect net quantification.
Deadlines and Transition Rules
Verra has set a defined runway for projects on the old versions. VM0038 v1.0 will be inactivated on September 1, 2027, with registration, crediting period renewal, verification and requantification requests accepted until August 31, 2027. VMD0049 v1.0 moves faster: inactivation on March 1, 2027, with a request deadline of February 28, 2027.
Projects that meet those deadlines may keep applying v1.0 for the remainder of their current crediting period, but must update to an active version at the next renewal. Grouped projects face a specific rule: those renewing under VMD0049 v1.1 may add new project activity instances only through a project method if their location has left the positive list, while instances already registered under v1.0 remain eligible to continue crediting.
What to Watch
Three markers will show how the revision lands. First, the updated positive list itself: which countries and US states lose AC charging eligibility in the first v1.1 list will indicate how quickly the fast track is closing in leading EV markets. Second, developer behavior: whether off-list projects actually attempt the VT0008 route or abandon carbon finance will reveal how much of the pipeline depended on the shortcut. Third, buyer pricing: if credits from early-stage markets start trading at a premium to those from mature ones, the threshold design will have effectively created a two-tier EV charging credit market.
