Carbon Markets Regulations in 2026: What Buyers Need to Know

The verified carbon market is not contracting. It is becoming more precise. Regulatory frameworks that spent years in development are now moving into implementation, and they are changing what a credible credit looks like, where it can be sourced, and what claims it can support. Buyers who engage with it now can position themselves ahead of the market.

Field monitoring of carbon credits projects in Africa, ensuring credible credits for 2026. AI generated picture.

This post breaks down the most significant regulatory developments of 2025 and their implications for carbon credit procurement in 2026: from the operationalisation of the Paris Agreement Crediting Mechanism to the EU's first government-issued certification framework, the convergence of voluntary and compliance markets, and what any buyer should check before completing a purchase today.

Article 6 Moves from Rulebook to Reality

The Paris Agreement Crediting Mechanism (PACM), established under Article 6.4 of the Paris Agreement, reached a significant milestone at COP30 in Belém in November 2025.

Parties endorsed the foundational standards adopted by the Article 6.4 Supervisory Body—covering baseline-setting, additionality, leakage, suppressed demand, and non-permanence and reversals—and acknowledged the first PACM methodology, covering landfill gas flaring and utilisation. The technical scaffold for a credible UN-managed carbon crediting mechanism is now in place.

Separately, COP30 confirmed the formal closure of the Clean Development Mechanism (CDM) by the end of 2026. The CDM, which has issued nearly 2.5 billion credits since 2001, will cease operations progressively throughout the year, with remaining CDM funds transferred to support PACM development. For buyers, this resolves a long-standing ambiguity: The legacy market is being wound down, and resources are now directed towards the newer mechanism.

One key caveat: The deadline for CDM projects to transition to Article 6.4 was extended by six months at COP30, despite having been set four years earlier. This means a new wave of CDM-era projects will seek PACM registration in the first half of 2026. Transition does not automatically confer quality. Buyers sourcing credits from recently transitioned projects should apply additional scrutiny to additionality claims and baseline methodology, particularly for projects originating before 2020.

What the Article 6.2 Landscape Looks Like

Article 6.2 governs bilateral agreements between countries for the transfer of carbon units. Over 60 countries now reference Article 6 mechanisms in their updated Nationally Determined Contributions (NDCs), and bilateral deals continue to grow.

The mechanism carries a fundamental requirement that matters directly to buyers: Credits traded under Article 6.2 must carry a corresponding adjustment, which is a formal acknowledgement from the host country that it has accounted for the transfer in its own national inventory, preventing double-counting.

Without a corresponding adjustment, a credit cannot support national climate claims or future compliance-linked use under Article 6 frameworks. Buyers procuring credits for long-term strategic purposes should confirm the corresponding adjustment status of any credit before purchase.

The EU CRCF: The World's First Government-issued Certification Framework

The EU Carbon Removals and Carbon Farming Regulation (CRCF, Regulation EU/2024/3012), adopted in December 2024, established the first government-issued voluntary certification framework for carbon credits anywhere in the world. Unlike existing private-sector standards such as Verra's VCS or the Gold Standard, the CRCF is built, governed, and recognised by a public authority—the European Commission.

In November 2025, the Commission adopted Implementing Regulation (EU) 2025/2358, establishing technical standards for certification schemes, certification bodies, and audit processes. In February 2026, the Commission adopted the first Delegated Act under the CRCF, covering three permanent carbon removal methodologies: Direct Air Capture with Carbon Storage (DACCS), Biogenic emissions Capture with Carbon Storage (BioCCS), and Biochar Carbon Removal (BCR). Carbon farming methodologies, including agroforestry, peatland rewetting, and afforestation, are expected to follow in mid-2026.

Agroforestry landscape in Africa. Ai generated picture.

Two additional developments are significant for buyers:

• The Commission must, by 31 July 2026, assess whether CRCF-certified permanent removals can be integrated into the EU Emissions Trading System (EU ETS). If approved, a subset of voluntary carbon credits could become compliance-eligible instruments, a significant shift in the market's architecture.
• An EU Buyers' Club for CRCF credits is being established in early 2026. By pooling demand from private companies, it will create a direct demand signal for carbon farming and removal projects certified under the framework.

For non-EU buyers, the geographic scope of CRCF is currently limited to EU-located activities, but the framework is explicitly designed as a global benchmark. Auditors, investors, and reporting frameworks including the EU's Corporate Sustainability Reporting Directive (CSRD) are already beginning to reference CRCF criteria when evaluating the quality of carbon credits.

The Voluntary–Compliance Boundary is dissolving

One of the most consequential shifts in the regulatory landscape is the growing convergence between voluntary carbon credit procurement and compliance obligations. Several developments are accelerating this.

The EU's 2040 Target and Article 6

The EU's legally binding 2040 climate target includes a flexibility mechanism allowing up to 3% of 1990 net EU emissions to be met via high-quality international Article 6 credits from 2036 onwards. This positions the EU as a future large-scale institutional buyer of sovereign-level carbon credits—a signal that should shape procurement strategies today.

CORSIA's First Real Compliance Requirement

CORSIA Phase I (2024–2026) has produced the first concrete compliance demand in aviation. Following ICAO's release of 2024 emissions data, approximately 58 million tonnes of CO₂ need to be covered under CORSIA-eligible credits for that year alone, with total Phase I demand potentially reaching 220 million units across 2024–2026. Airlines with flights between the 130 participating states must retire eligible credits by January 2028.

CORSIA-eligible credits must come from ICAO-approved programmes and carry a corresponding adjustment from the host country. The supply outlook remains constrained: As of mid-2025, only a fraction of potential supply has been issued. This creates a supply-side premium for credits that meet CORSIA eligibility criteria, making them an increasingly attractive benchmark for quality in the wider voluntary market.

A carbon compliance officer reviewing emissions data while overseeing airport operations and environmental impacts. AI generated picture.

Anti-Greenwashing Enforcement from September 2026

Although the EU Green Claims Directive was effectively suspended in June 2025, the anti-greenwashing framework remains fully active. The Empowering Consumers for the Green Transition Directive (ECGT), which entered into force in March 2024, must be applied by Member States from 27 September 2026. It explicitly prohibits 'carbon neutral' or 'climate neutral' claims based on carbon credits rather than actual in-value-chain reductions.

This matters directly for buyers. A credit purchased today to support a product-level environmental claim may not be legally defensible under EU consumer protection law from late 2026. The credit type, the claim language, and the underlying reduction or removal methodology all need to align.

What Is Changing in Registries and Project Eligibility

The ICVCM's Core Carbon Principles (CCP) label has become an increasingly recognised quality signal. By November 2025, the ICVCM had approved seven major carbon-crediting programmes and 36 methodologies, covering over 51 million credits in active use. In October 2025, six new carbon dioxide removal (CDR) methodologies received CCP approval, including five from Isometric and one from Gold Standard, alongside key forestry protocols covering Improved Forest Management (IFM) and Afforestation, Reforestation and Revegetation (ARR). CCP-labelled credits now command a price premium of up to 25% compared to other credits, according to market analysts.

On the CRCF side, existing certification schemes, including Verra, Gold Standard, and others, will need to apply for Commission recognition under the framework before they can certify activities against CRCF methodologies. The first recognition decisions are expected in late 2026. A Union Registry documenting the generation, trading, and use of CRCF-certified units is planned for launch by 2028.

For buyers, this creates a transitional period in which the CRCF is legally in force but the full registry infrastructure is not yet operational. Transparency during this period depends on individual scheme disclosures. Buyers sourcing credits intended to align with CRCF should confirm whether the relevant scheme has applied for, or is actively preparing, a Commission recognition application.

What Buyers Should Check Now

The regulatory shifts described above are not abstract. They translate into a concrete set of procurement questions that any buyer active in the carbon credit market should be asking before completing a purchase in 2026.

• Registry and programme status: Is the credit issued by a programme that holds ICVCM CCP-eligible status, or that is actively seeking recognition under the CRCF? CCP eligibility applies to the programme level; CCP approval applies to the specific methodology. Both are required for a CCP-labelled credit.
• Corresponding adjustment: Has the host country issued a corresponding adjustment for the credit? This is now required for use under CORSIA Phase I and is increasingly a prerequisite for future compliance-linked claims. Credits without this assurance are limited to voluntary-market use only.
• Vintage and transition history: Is the project transitioning from the CDM? If so, review the additionality documentation and baseline methodology carefully. A CDM-to-PACM transition extends the project's life but does not automatically update its quality criteria.
• CRCF alignment (EU buyers and EU-facing companies): Does the credit type fall within a CRCF-covered category? Has the developer indicated an intention to seek CRCF certification once the relevant Delegated Act is in force? For permanent removal credits specifically, CRCF alignment may become a procurement prerequisite as the framework matures.
• Claim compatibility: Does the intended claim align with the credit type? Under the ECGT, product-level 'carbon neutral' claims based on credits alone will be prohibited in the EU from September 2026. Contribution claims, acknowledging that credits support climate action, remain permissible, provided they are substantiated.
• Future compliance eligibility: Is the credit type likely to qualify under CORSIA, future CRCF-ETS integration, or other emerging compliance frameworks? Sourcing credits with compliance potential today may reduce procurement costs and reputational exposure as voluntary and compliance markets continue to converge.

A field verification team reviewing carbon credit compliance for forest-based projects in Africa. AI generated picture.

The Market Is Segmenting, And the Segments Are Becoming Permanent

The regulatory activity of 2025 is not a temporary wave of paperwork. It reflects a structural maturation of the carbon credit market. The frameworks now being operationalised—PACM, CRCF, CORSIA Phase I, CCP—are establishing durable distinctions between high-integrity and lower-quality credits. Those distinctions are increasingly backed by government authority, not just market norms.

For buyers, this means procurement decisions made in 2026 will have a longer tail than those made in 2020 or 2021. Credits sourced today may be audited under CSRD reporting requirements, scrutinised under anti-greenwashing law, or assessed for compliance eligibility in the years ahead. The question is not whether to engage with these frameworks—it is whether to engage with them now or catch up later.