Disclosure focus
This disclosure asks an organisation to explain any greenhouse gas removals it relies on, and any mitigation projects it has financed using carbon credits. In practice, the report should make clear what was done, what part of the value chain or footprint it relates to, and how the organisation treats those removals or credits in its climate reporting. The focus is on transparency about the role these instruments play in the overall climate picture, rather than presenting them as a substitute for reducing emissions within the business.
Practically, the organisation should cover the full scope of relevant activity, not just a few flagship sites or isolated projects, unless it clearly explains the boundary used. It should distinguish between actions that directly reduce or remove emissions and those that are financed through credits, so readers can see where the organisation is acting within its own operations and where it is relying on external projects. The key question is whether the reporting gives a complete and consistent view of how removals and carbon-credit-financed mitigation are used across the organisation.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show E1-9 sub-elements (LRA working checklist)
Set out the method used to account for removals.
State the quantity of removals recognised.
Describe the kind of removals project involved.
Explain how long the storage is expected to last and the chance it could be reversed.
Describe the type of carbon credit project used.
Name the quality standard applied to the carbon credits.
State how many carbon credits have been cancelled.
State how many carbon credits are planned for cancellation.
Explain how carbon credits are used in meeting the target.
How to prepare it
1Set the reporting boundary first, then decide which activities, projects and time period feed into this disclosure. Make sure the same scope is used for both the removals information and the credit information so the figures and narrative line up.
2Define the categories you will use for each item before collecting data: the amount of removals, the type of removal project, the storage life and reversal exposure, the accounting approach, the volume of credits cancelled, the volume of credits intended for future use, the credit quality benchmark, the credit project type, and how credits support target delivery.
3Gather source records for every number and statement. For the removals amount and the two credit quantities, collect the underlying calculations or registers that support the tCO2e totals. For the text fields, collect the project descriptions, methodology notes, quality-standard references and any internal papers that explain the role of credits in meeting targets.
4Build the disclosure by entering the numeric totals with the unit shown where required, and by writing concise narrative for each text item. Keep the wording specific enough to distinguish the project type, storage characteristics, accounting basis, quality standard, project type for credits, and the way credits are used in target achievement.
5Record any exclusions, estimates, restatements or changes in approach that affect the figures or descriptions. If a figure is not directly measured, note how it was derived; if a method changed from the prior period, explain what changed and why the current presentation is the one being used.
6Check the completed disclosure back against the official source before sign-off. Confirm that every required item is present, the units are shown where needed, the narrative matches the evidence, and the scope, definitions and calculations are consistent across the whole disclosure.
Request the data
Request the removals and carbon credit evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What removals and carbon-credit activity did we record in the reporting period, and what evidence supports the amounts, project details, quality checks, and how they link to our target progress?
Use your organisation’s own labels first, then map them to the reporting fields. For example, if your team talks about offsets, retirements, retirements/cancellations, removals, or climate projects, keep that internal wording in the request and only translate it into the reporting terms when you prepare the disclosure pack. Check the source text before sign-off.
Weak request
Please provide the ESRS E1-9 data for removals and carbon credits, including all required datapoints and evidence.
Why it fails: It uses framework language only, so the owner may not know which internal records to pull. It also does not say which system, team, period, or internal labels to use, so the response is likely to be incomplete or hard to map.
Better request
Please send the climate-project and carbon-credit records for [reporting period] from [source system/register], using your team’s own labels. We need the booked removals amount, project type, storage/durability note, accounting basis, cancelled and planned credit amounts, quality standard, project type, and the explanation of how these credits support target progress. Include the file extract, date, and reviewer.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Set out the basis used to measure and account for removals and credits, including how project types, storage durability, reversal risk and any quality standard were defined for reporting.
Context note
Explain what the figures mean in practice by linking removals and credits to the organisation’s climate target, and by distinguishing what has already been used from what is still expected to be used.
Fluctuation statement
If the numbers move materially, describe the operational or portfolio reasons behind the change, such as a different mix of project types, changes in the amount cancelled, or updates to the expected use of credits.
Content index entry
E1-9 GHG removals and GHG mitigation projects financed through carbon credits — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to the sustainability team alone, even though the figures and descriptions sit with project, finance, procurement, or carbon-credit owners.
Framework language first
People ask for answers using disclosure labels instead of the organisation’s own terms, so the source team cannot tell which internal record or process is being requested.
No boundary set
The team starts collecting data without stating which entities, projects, or credit transactions are in scope, so different contributors pull different populations.
Wrong time basis
One team uses the reporting year while another uses purchase, cancellation, or project dates, which makes the dataset cover mismatched periods.
Mixed counting basis
Removals and credits are gathered on different measurement bases and then combined as if they were directly comparable, which distorts the totals.
Source labels lost
Original file names, registry references, or internal record IDs are stripped out during collection, so the team cannot trace each figure back to its source.
Separate groups merged
Cancelled credits, planned credits, and removals are put into one spreadsheet without clear splits, so items that should stay distinct get blended together.
Evidence details missing
The collector keeps the number but not the supporting date, version, or document reference, leaving no audit trail for later review.
No sign-off trail
Data is passed along by email or chat without named review and approval, so nobody can show who checked the figures before they were used.
Where judgement is often needed
Set the cut-off for acquisitions and disposals
Decide whether to include removals and credit activity only from the date control starts or ends, explain the cut-off used, and keep the same approach across the period unless a change is clearly described.
Use one country rulebook for mixed operations
Where local schemes define project types, quality labels, or storage risk differently, map them to one internal classification, explain the mapping, and note any country-specific differences that affect the figures or labels.
Define who sits inside the reporting perimeter
State how you treat joint ventures, leased sites, outsourced operations, and other borderline activities, then explain any exclusions or partial inclusion so readers can see what sits inside the totals.
Choose the measurement date for credits and removals
Explain whether you use the transaction date, retirement date, delivery date, or another internal cut-off for the year-end figures, and apply that basis consistently to both amounts and descriptions.
Separate measured data from estimates
If some volumes or project attributes are not directly observed, disclose which parts are estimated, the main assumptions behind them, and whether later true-up could change the reported numbers.
Decide how to treat reversals and durability risk
For storage projects, explain the basis used to assess permanence and reversal exposure, including any internal thresholds or monitoring rules that drive the classification you report.
Round without distorting the totals
State the rounding rule used for tonnes and any related percentages or counts, and make sure the rounded figures still reconcile to the underlying unrounded records.
Aggregate sensitive location or partner data
If naming a site, partner, or project would expose confidential or personal information, group the data at a higher level, explain the aggregation basis, and keep the reported totals internally consistent.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
We report 120 tCO2e of removals this year, all from 120 tCO2e of biochar applied to soil; we treat the storage as long-lived, with a low but non-zero chance of reversal, and we measure it using a project-level approach that recognises the removals only when they are verified and retained. - We cancelled 80 carbon credits this period and have 40 more already contracted for cancellation next year; all of them came from verified reforestation projects under a recognised quality label, and we use them only to help close the gap to our near-term target rather than to replace emissions cuts.
Synthetic example for training only. It shows how a reporter might describe removals and carbon credit use in plain language while keeping the figures internally consistent.
Illustrative (synthetic) example — Food and beverage
Our group records 45 tCO2e of removals, all from 45 tCO2e of direct air capture with geological storage; we treat the storage as very durable, with reversal risk assessed as very low, and we account for the removals on a gross basis once the storage is confirmed. - We retired 30 carbon credits this year and expect to retire 20 more under signed purchase agreements; these credits are from mangrove restoration projects certified to a high-integrity standard, and we use them as a supplementary measure after our own reduction actions when tracking progress towards our long-term goal.
Synthetic example for training only. It demonstrates a different sector and a different mix of removals and credits, while keeping the narrative concise and numerically consistent.
How companies report E1-9 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Schneider Electric S.E.
Electrical Equipment and Machinery · France · 2025
Schneider Electric's 2025 Universal Registration Document references greenhouse gas (GHG) emissions and related topics such as carbon credits and removals, with mentions on pages 268, 270, 331, and 511 indicating discussion of Scope 1, 2, and 3 emissions and related risks (p.268, p.270, p.331, p.511). The report includes a target to reduce value chain emissions by 25% by 2030 and to be "Net-Zero ready" (p.332). However, the report does not provide clear quantitative disclosures of emissions values (tCO2e), and the methodology or narrative details for emissions reporting remain unclear or absent.
EDP, S.A.
Electric Utilities / IPP / Energy Traders · Portugal · 2025
EDP, S.A.'s 2025 Integrated Annual Report provides a specific emissions value for total greenhouse gas removals and storage, reporting zero ktCO2e for both 2024 and 2025 (p.88). The report references governance and oversight mechanisms related to GHG inventory and intensity targets (p.81), and mentions standards and guidelines followed, including sustainability commitments (p.571). However, the report lacks detailed narrative explanations or methodology regarding emissions data, and no additional emissions values beyond removals and storage are provided, leaving some aspects unclear or not found.
Ferrovial SE
Construction and Engineering · Netherlands · 2024
Ferrovial SE’s Integrated Annual Report 2024 includes some references to greenhouse gas (GHG) emissions and related metrics, such as GHG emissions per revenue and Scope 1 and 2 absolute emissions targets, with specific figures mentioned on pages 55 and 90. The report also references energy consumption and water footprint objectives on page 109. However, the report lacks explicit headline values for total emissions in tCO2e, and no clear, quotable emissions values are provided, with only partial narrative context found on page 288.
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Scenarios to work through
A group has bought 12,000 tCO2e of credits and retired 9,500 tCO2e by year-end. The sustainability team also has a small woodland project that is expected to store carbon for a long period, but it has a known fire exposure.
QWhat should the preparer decide to capture for the removals and the credit-backed project, and how should the risk be described?
Reveal model answer →Hide answer ↑They should separate the two items. For the woodland project, they should record the amount of carbon removed, name the project type in plain terms, explain how long the storage is expected to last, and describe the chance that the stored carbon could be released again. For the credits, they should report the retired amount as 9,500 tCO2e, not the full 12,000 tCO2e bought, because only the cancelled amount is the relevant figure here.
Why this matters · Keep removals and credit retirement distinct, and describe durability and reversal risk in a way that matches the project’s real profile.
A manufacturer has used credits from a cookstove programme to support its climate plan, but the finance team is unsure whether to list the credits as already used or only as planned purchases. The same team also has a note that the credits came from a standard it considers high quality.
QHow should the preparer decide what to report about the credits, their source, and their role in the target story?
Reveal model answer →Hide answer ↑They should report the amount already cancelled separately from any amount still intended for future use. They should identify the quality benchmark used for the credits, describe the type of project that generated them, and explain how those credits fit into the organisation’s path toward its climate target. If the credits are only planned and not yet cancelled, they belong in the planned figure rather than the cancelled one.
Why this matters · Show what has actually been retired, what is only planned, and how the credits support the target narrative.
An energy company has booked 4,200 tCO2e of removals from a soil-carbon project, but the accounting team has treated the figure as if it were the same as avoided emissions. The project note also says the storage period is uncertain because the land is under a short lease.
QWhat judgement should the preparer make about the accounting approach and the project description?
Reveal model answer →Hide answer ↑They should not treat removals as the same thing as avoided emissions. Instead, they should explain the method used to account for the removals, state the project type in ordinary language, and be clear about how durable the storage is likely to be given the short lease and the related reversal exposure. The reported amount should stay tied to the removals figure of 4,200 tCO2e.
Why this matters · Use a removals-specific accounting approach and make the storage period and reversal exposure transparent.
A retailer has 18,000 tCO2e of credits in its climate plan, but only 6,000 tCO2e have been cancelled so far. The remaining 12,000 tCO2e are expected to be retired next year, and the team wants to present the full 18,000 tCO2e as if it already supported the current-year target.
QWhat should the preparer do when deciding how to present the current-year position and the future intention?
Reveal model answer →Hide answer ↑They should report 6,000 tCO2e as the amount already cancelled and 12,000 tCO2e as the amount still planned, keeping the two figures separate. They should also explain the type of project behind the credits, the quality benchmark used, and the role the credits play in reaching the target. The full 18,000 tCO2e should not be presented as if it were already retired.
Why this matters · Separate current-year retirement from future intent, and link the credits to the target in a clear, non-overstated way.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Transition plan for climate change mitigation →Internal carbon pricing →Anticipated financial effects from material physical and transition risks and potential climate-related opportunities →Identification of climate-related risks and scenario analysis →Resilience in relation to climate change →Policies related to climate change mitigation and adaptation →Show all 10 related disclosures →
FAQ
Questions this page answers
For E1-9, what data points do I need to gather before I start drafting the disclosure?+−
The page says to prepare removal volume, removal project type, storage permanence and reversal risk, removal accounting method, credits retired, credits planned, credit quality standard, credit project type, and credits and targets. Use that list as your starting checklist before you draft anything.
How do I use the E1-9 step-by-step preparation section in practice?+−
Use it as a working sequence for collecting the right inputs, checking scope and method, and then turning the information into a draft. The page is designed to help you move from raw data to a disclosure-ready output.
What should I ask the data owner for when preparing E1-9 removal and credit information?+−
Ask for the specific datapoints listed on the page, plus enough supporting detail to explain how each figure was prepared. The page is aimed at helping a sustainability, HR or data owner provide the right inputs for the disclosure.
How do I decide the scope and methodology for E1-9 using this page?+−
The page points you to the removal accounting method, storage permanence and reversal risk, and the credit-related fields as the main methodology items to settle. It is intended to help you define the approach before drafting, rather than after the numbers are fixed.
Who should own the E1-9 data collection and sign-off process?+−
The page is written for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can provide and check the underlying data. Use the page to assign each datapoint to a clear owner and reviewer.
What evidence do I need in the E1-9 assurance pack?+−
The page includes an evidence pack with five items for assurance readiness, and it also lists six assurance claims to verify with claim, risk and evidence. Use those sections to build a file that shows where each reported figure came from and how it was checked.
What are the six assurance claims for E1-9 and how do I use them?+−
The page says there are six assurance claims to verify, each framed around claim, risk and evidence. Use them as a checklist to test whether the disclosure is supported, where the main risks sit, and what proof you can show an assurer.
What are the common reporting gaps or mistakes for E1-9?+−
The page lists common reporting gaps and mistakes to help you spot weak points before submission. Use that section as a pre-assurance review so you can fix missing data, unclear methods or unsupported statements early.
How can I use the synthetic example disclosure on the E1-9 page without copying it?+−
The example is there to show how the disclosure can be structured and how the quantitative table might look. Treat it as a formatting and logic guide only, and replace it with your own internally consistent data.
What should the E1-9 draft output include according to the page?+−
The page suggests draft-output elements such as visualisation ideas, narrative starters and a content-index line. Use those to turn the prepared data into a first-pass disclosure that is easier to review and assurance-check.
How do I use the E1-9 workbook and printable library card?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise the preparation and assurance steps, and the library card as a quick reference while drafting.
More questions this page can help with
E1-9 removal volume and credits planned: what should I collect before drafting?E1-9 storage permanence and reversal risk: how do I document this for assurance?E1-9 removal accounting method: how do I explain the method in plain language?E1-9 credit quality standard: what evidence should I keep?E1-9 credits retired versus credits planned: how do I separate these in the data pack?E1-9 removal project type and credit project type: how should I classify them?E1-9 evidence pack: what files should go into the assurance folder?E1-9 common mistakes: what are the usual gaps reviewers look for?E1-9 draft output: how do I turn the workbook into a disclosure narrative?E1-9 synthetic example: how do I use the example table to check my own numbers?E1-9 from company reports: how do I use the linked published reports as references?E1-9 content index line: what should I include so the disclosure is easy to navigate?
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312 published reports indexed
63171 pages with page-level citations
247 practitioner guides
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