Voluntary credit
Issued by a programme registry; bought to support a claim or a target.
Not named as a specified investment when traded spot (RAO Part III).The standards
Does it apply to you
Reporting under it
Start here
Dates and penalties
Doing it
What you must file
Doing it
Start here
Setting targets
Who and where
The UK duty
Doing it
The baseline
Europe
Reporting more widely
Carbon markets and trade
Packaging and net zero
Carbon accounting
Choosing
Carbon
Compliance and offsets
Software
Templates
Careers
Software · carbon credits, cited
Carbon credit software keeps the record of every credit an organisation buys, holds and retires, and turns that record into the claims and disclosures made about it.
In the UK the rules touching credits are a disclosure paragraph, general consumer law and government guidance, so the register has to hold the facts each of them asks about.
What the software does
Carbon credit software is a register: it records what was bought, from which programme and methodology, and what happened to each tonne.
Most platforms in this space are built by people who know the market well, and the good ones make each credit traceable from contract to registry retirement.
The reason a register matters is that each rule asks a different question of the same credits.
UK SRS S2 asks what you plan to use, consumer law asks whether a claim is true, and a buyer’s procurement team asks what you retired and when.
The neutrality claim itself is covered on carbon neutral software, and targets on net zero software.
Programme, methodology and version, vintage, project, price, contract terms.
Serial numbers on the registry, delivery status, pending units kept apart.
CCP status of the methodology version, dated; any rating, as an opinion.
Retirement on the registry, for a stated purpose and year.
Planned use under UK SRS S2 ¶36(e); claims tested against consumer law.
What UK SRS S2 asks
UK SRS S2 asks about carbon credits in one place, ¶36(e), and only where a net greenhouse gas target relies on them.
The paragraph covers “the entity’s planned use of carbon credits to offset greenhouse gas emissions to achieve any net greenhouse gas emissions target”, in the words of the standard.
For listed companies in UKLR 6, 14, 15, 16 and 22 this is comply or explain for periods beginning on or after 1 January 2027, under FCA PS26/19.
So the register has to hold planned purchases as well as retirements, because ¶B71 makes planned use the disclosure and retired credits optional context.
An entity with no net target owes nothing under ¶36(e), even if it buys and retires credits; the trigger is the target, not the purchase.
Gross emissions stay gross: the Scope 1, 2 and 3 figures under ¶29(a) are reported without deducting credits.
How UK SRS S2 handles targets more widely is on UK SRS S2.
Law, guidance or proposal
No UK instrument is written for voluntary carbon credits, so most of what binds is general law applied to claims.
The DMCC Act 2024 makes misleading commercial practices unlawful, and its Schedule 20 blacklist names nothing about carbon, climate or offsetting.
The government’s six integrity principles of 15 November 2024 are guidance, and the formal response to its 2025 consultation was promised for summer 2026.
On 2 June 2026 the minister told the Commons it “will be published later this year” (Hansard); this site had not found it as at 23 October 2026.
The checker beside this sorts each instrument by what it is today, so a proposal never reads as law.
Carbon credit rules · pick who you are
2 binding now · 0 made but applying later · 1 proposed only · 3 voluntary
| Instrument | Status | Source |
|---|---|---|
| UK SRS S2 ¶36(e) Binding now | Comply or explain for UKLR 6, 14, 15, 16 and 22 for periods from 1 January 2027: disclose planned use of credits toward any net GHG target. | FCA PS26/19; UK SRS S2 ¶36(e) |
| DMCC Act 2024, Part 4 Binding now | General misleading-practices law applies to any credit-based claim to consumers; Schedule 20 names nothing about carbon. | DMCC Act 2024 Part 4 |
| UK VCNM policy, formal response Proposed only | Consulted 2025; summary of responses 26 March 2026; formal response not found as at 23 October 2026. | DESNZ consultation page |
| UK VCNM integrity principles Voluntary | Six principles of 15 November 2024; “should”, not “must”. | DESNZ principles |
| ICVCM CCP label Voluntary | A market label on programmes and methodologies. | ICVCM |
| VCMI Claims Code Voluntary | A claims standard: Silver, Gold, Platinum. | VCMI v3.1 |
Each status is dated to the instrument linked beside it; a proposal is never shown as law.
Nothing is stored or sent.
Credit quality
| Signal | What it is | What it is not |
|---|---|---|
| ICVCM CCP-Eligible | A programme passed ICVCM’s governance assessment | A label on every credit that programme issues |
| ICVCM CCP-Approved | A methodology version passed | A judgement on a project’s delivery |
| VCMI claim (Silver, Gold, Platinum) | A claims standard for companies | “Carbon neutral” |
| Credit rating (AAA to D) | A provider’s opinion | A regulated rating with legal effect |
The ICVCM labels programmes and methodologies, not individual credits, and approval is version by version.
Its assessment status page listed 44 CCP-Approved methodologies as at 12 August 2026, against ten Core Carbon Principles.
VCMI’s Claims Code says credits underpinning a claim “are not counted as internal emission reductions”, which is the line a register must keep.
So a register should hold the methodology version and the date its status was checked, because a label can change after purchase.
Four quality signals
Four quality signals
Four quality signals
Compliance and voluntary markets
A UK ETS allowance is a compliance instrument an installation or operator surrenders against its verified emissions.
The cycle is a verified report by 31 March and surrender by 30 April, in DESNZ’s guidance, with an excess emissions penalty under article 52 of the scheme Order.
The Regulated Activities Order names UK ETS allowances as investments and does not name spot voluntary credits, though a future or contract for difference over one may be caught.
Software that holds both should keep two ledgers; scheme compliance is covered on UK ETS software.
The auction reserve price was set at £28 from 8 April 2026 by SI 2026/214.
The FCA’s perimeter guidance on allowances is at PERG 2.6.19D.
Issued by a programme registry; bought to support a claim or a target.
Not named as a specified investment when traded spot (RAO Part III).Created under the scheme Order; surrendered against verified emissions.
A specified investment; surrender by 30 April or pay the penalty.Removals and UK codes
Removal credits raise questions avoidance credits do not: how long the carbon stays stored, who monitors it, and what happens on reversal.
The UK has two government-backed domestic codes, the Woodland Carbon Code and the Peatland Code.
A Woodland Carbon Code Pending Issuance Unit is a promise of a future verified unit, so a register should never count it as a tonne already removed.
The EU’s Regulation (EU) 2024/3012 sets a voluntary certification for activities in the Union, so it cannot certify a UK project.
Removal credits
Removal credits
Removal credits
Claims to customers
From 27 September 2026, Directive (EU) 2024/825 bans claims to EU consumers that a product has a neutral, reduced or positive impact based on offsetting.
The separate EU Green Claims Directive has not been adopted and was not withdrawn, according to its procedure file.
In the UK, any credit-based claim is judged by general misleading-practices law, which is why the register’s retirement records matter to marketing as much as to reporting.
The wider rules on environmental claims are on green claims software.
The tests before you sign
Each question names the source it comes from and what a passing answer looks like.
Run them on one real credit you hold, because a demonstration portfolio is always clean.
There is no IFRS Accounting Standard specifically for carbon credits, according to the IFRS Foundation, so the finance team will want cost and status history as well.
Nothing on this page is a rating, ranking or recommendation of any product.
Carbon credit demo questions · tick the ones you need
The pass tests are our reading of the cited provisions.
Nothing you tick is stored or sent.
For the board
That record is what UK SRS S2, consumer law and a customer’s questionnaire all read.
Takeaways
| Fact | What it means for the register |
|---|---|
| UK SRS S2 asks for planned use only | Hold planned purchases, not just retirements (¶36(e), B71). |
| No UK law is written for credits | Claims are tested under the DMCC Act 2024. |
| ICVCM labels are version-level | Store the methodology version and the date checked. |
| UK ETS allowances are a different instrument | Keep a separate ledger. |
| EU offset-based product claims are banned from 27 September 2026 | Flag consumer claims for EU markets. |
Next: the questions that decide a neutrality claim are on carbon neutral software.
Frequently asked
Software that keeps a register of the carbon credits an organisation buys, holds and retires, with each credit’s programme, methodology, vintage and serial number, and turns that register into the disclosures and claims the organisation makes.
Some products also source credits; this page is about the record.
The terms are used for the same products.
“Offset” describes a use of a credit; the credit is the instrument.
UK SRS S2 itself speaks of “the entity’s planned use of carbon credits to offset greenhouse gas emissions”.
No UK instrument targets voluntary credits or offsetting claims.
General consumer law under the DMCC Act 2024 applies to any misleading claim, the government’s six integrity principles of November 2024 are guidance, and its formal response to the 2025 consultation had not been found as at 23 October 2026.
Paragraph 36(e) asks for the planned use of carbon credits to offset emissions to achieve any net greenhouse gas target: how far the target relies on credits, which scheme verifies them, their type, whether reduction or removal, and other factors such as permanence.
B71 says only planned use must be disclosed.
For listed companies in UKLR 6, 14, 15, 16 and 22 it is comply or explain for periods from 1 January 2027.
Not from the gross Scope 1, 2 and 3 figures UK SRS S2 asks for.
VCMI’s Claims Code also says credits underpinning a claim are not counted as internal emission reductions.
A label the Integrity Council for the Voluntary Carbon Market attaches to programmes (CCP-Eligible) and to methodologies (CCP-Approved), version by version.
As at 12 August 2026 its status page listed 44 CCP-Approved methodologies.
A credit from an eligible programme is not CCP-labelled unless its methodology version is approved.
Credit ratings from agencies such as BeZero, Sylvera and Calyx are private opinions: no UK or EU instrument gives their grades legal effect, and an AAA from two providers can mean two different things.
A register should store a rating as the provider’s dated opinion.
Removal credits carry questions avoidance credits do not: durability, monitoring and reversal.
The EU’s carbon removals framework, Regulation (EU) 2024/3012, is a voluntary certification for activities in the Union, and its carbon-farming and storage-in-products units are temporary and expire at the end of the monitoring period.
No. A UK ETS allowance is an instrument created under the scheme Order that an installation or operator surrenders against verified emissions.
It is a specified investment in the Regulated Activities Order; spot voluntary credits are not named there.
Keep the two in separate ledgers.
The Woodland Carbon Code and the Peatland Code are the UK’s two government-backed domestic codes.
A Woodland Carbon Code Pending Issuance Unit is a promise of a future verified unit, not a tonne that can be claimed now.
In the EU, from 27 September 2026, a claim to consumers that a product has a neutral, reduced or positive impact based on offsetting is banned by Directive 2024/825.
In the UK the test is general misleading-practices law under the DMCC Act 2024.
No. This page sets out what the rules ask a credit register to hold, each cited to its source, and ranks no product.
Sources
Every rule on this page traces to the instrument listed here.
Planned use of carbon credits toward a net target; only planned use must be disclosed.
Comply or explain for UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.
Six principles; guidance, not law.
Ran 17 April to 10 July 2025; 200 responses; formal response promised.
The minister: the response “will be published later this year”.
Labels attach to programmes and methodologies, version by version.
Ten principles in governance, emissions impact and sustainable development.
Silver, Gold and Platinum; credits are not internal reductions.
Offset-based neutrality claims to consumers banned, applying from 27 September 2026.
Not withdrawn; status on the procedure file.
General misleading-practices law; nothing on carbon in the blacklist.
Spot voluntary credits are not named; UK ETS allowances are.
The FCA’s guidance on emission allowances as investments.
The excess emissions penalty.
Verified report by 31 March; surrender by 30 April.
The UK ETS auction reserve price.
Pending Issuance Units are a promise of future units.
The UK’s peatland restoration code.
Voluntary EU certification for activities in the Union.
No IFRS Accounting Standard specifically for carbon credits.