Disclosure focus
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 European Commission source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
-
Removal volume
Sustainability / Climate reportingThe total greenhouse gas removed and reported in carbon dioxide equivalent for the period, using the same basis as the rest of the emissions inventory.
Evidence Removal calculation file, project monitoring data, consolidation workbook, and sign-off from the climate reporting lead.
Watch for Does not reconcile to the removals schedule or inventory total, or mixes period activity with a different reporting cut-off.
-
Removal project type
Sustainability / Climate reportingThe kind of activity used to remove greenhouse gases, described in plain business terms so the reader can tell what sort of project it is.
Evidence Project documentation, methodology note, supplier or project developer description, and internal classification memo.
Watch for Project is described using a different category than the source project file, so the activity type is misclassified.
-
Storage permanence and reversal risk
Sustainability / Climate reportingA plain explanation of how long the removed carbon is expected to stay stored and what could cause it to be released again.
Evidence Permanence assessment, risk register, project monitoring reports, and any buffer or reversal analysis.
Watch for Permanence period and reversal exposure are taken from different project versions, so the stated storage profile does not match the underlying assessment.
-
Removal accounting method
Finance / Sustainability reportingThe approach used to measure, recognise and report the removals, including the basis for any estimates or assumptions.
Evidence Accounting policy, calculation methodology, working papers, and review notes from finance or sustainability control owners.
Watch for Methodology in the disclosure does not match the calculation workbook, or a different accounting basis is used for the same removals.
-
Credits retired
Finance / Carbon marketsThe amount of carbon credits that were cancelled or retired during the reporting period, stated in carbon dioxide equivalent where that is how the system records them.
Evidence Retirement certificates, registry extracts, broker confirmations, and the carbon credit ledger.
Watch for Retired credits do not reconcile to the registry or ledger, or the period includes cancellations booked outside the reporting window.
-
Credits planned
Finance / Carbon marketsThe amount of carbon credits the organisation expects to cancel or retire in future, stated on the same measurement basis used internally.
Evidence Forward purchase contracts, retirement plan, budget or forecast file, and approvals from the carbon programme owner.
Watch for Forecast quantity is taken from a different plan version or period, so planned credits do not match the approved procurement schedule.
-
Credit quality standard
Finance / Carbon marketsThe recognised quality benchmark or certification used to judge the carbon credits, named in the way the market or registry records it.
Evidence Registry listing, certification documents, supplier pack, and procurement approval showing the accepted standard.
Watch for Quality standard is reported from the supplier pitch rather than the registry record, so the stated benchmark is not the one actually held.
-
Credit project type
Finance / Carbon marketsThe type of project that generated the carbon credits, described in ordinary terms so the underlying activity is clear.
Evidence Project documentation, registry entry, supplier description, and contract schedule.
Watch for Project type is copied from a generic sales description and does not match the registry project classification.
-
Credits and targets
Sustainability / StrategyHow the organisation uses carbon credits in relation to its emissions target, including whether they support progress towards that target and in what way.
Evidence Target-setting paper, transition plan, carbon strategy, and board or management approval of the role credits play.
Watch for The role of credits is described differently from the target-setting document, so the disclosure overstates or misstates how credits support target achievement.
Before you start
- Have you decided which removals and credit-backed projects belong in this section, and which ones stay out?
- Have you fixed the period and measurement basis for the tonnage figures, so the numbers line up with the same reporting window?
- Can every tonnage figure be traced back to a source record or calculation file that someone else could follow?
- For each removal activity, have you settled the project type, how long the storage is expected to last, and how you are treating any reversal risk?
- For the credit-backed projects, have you agreed which credits were retired in the period, which are still planned, and what quality standard and project type apply?
- Have you aligned the way you describe the credits’ role in target delivery with the organisation’s own internal definitions and reporting approach?
How to prepare it
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.
Formal email template
Subject: Request for removals and carbon-credit evidence pack for [reporting period] Hi [name/team], We are preparing the climate reporting pack for [reporting period] and need your help with the records for removals and carbon-credit activity. Please send the following for [reporting boundary]: - the amount recorded for removals, with the supporting basis and unit - the project type used for each removal item - the note on how long the storage is expected to last and any reversal risk considered - the method used to account for removals - the amount of credits cancelled/retired - the amount of credits planned for use - the quality standard used for each credit batch - the project type for each credit batch - the explanation of how these credits support our target progress Please include the source file or system extract, the date it was produced, and the person who prepared or approved it. If your team uses different internal terms, please keep those terms in the response and add a short mapping to the reporting fields. Thanks, [preparer name] [role] [team]
Short Teams / Slack version
Hi [name/team] — could you share the removals / carbon-credit evidence pack for [reporting period]? Please include the amounts, project types, quality standard, storage/reversal note, accounting basis, and how the credits link to target progress. Add the source file/system, date, and owner. Use your team’s own terms if easier, and we’ll map them to the reporting fields. Thanks, [preparer name]
Industry examples
Manufacturing
Context. The company runs an internal decarbonisation programme and buys credits through treasury.
Adapted request. Please share the plant-level removals and carbon-credit pack for [reporting period], including the project register, retirement log, and the note on how each credit batch supports our emissions-reduction plan. Use the plant team’s own labels and include the source extract from the register and finance system.
Example response. A spreadsheet with columns for site code, internal project name, removals amount in tCO2e, project type, durability note, reversal-risk note, accounting method, credits retired, credits planned, quality standard, and target-progress note, plus links to the registry export and approval email.
Financial services
Context. The organisation uses a central sustainability team and a procurement-led carbon credit process.
Adapted request. Please provide the central carbon portfolio pack for [reporting period], including any removals booked, credits cancelled, credits planned for future use, the standard used to assess each batch, and the internal note explaining how the credits are being used in the transition plan. Keep your portfolio and procurement terms in the response and map them to the reporting fields.
Example response. A register extract showing portfolio ID, batch name, amount in tCO2e, project type, quality standard, storage/durability commentary, accounting note, cancelled amount, planned amount, and a short narrative on target contribution, with the contract and approval trail attached.
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
Download preparation tools for E1-9 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We excluded any credits that came from projects inside our own sites or elsewhere in our value chain when we prepared the credit totals.
Risk An assurer will test whether the boundary was applied consistently and whether any in-scope credits were left out or wrongly included.
Evidence to check Boundary memo or methodology note; project register showing project location and relationship to the group; credit inventory with inclusion/exclusion flags; reconciliation between source records and reported totals.
For each removal or storage project we included, we kept a short project note and identified the project type before publication.
Risk An assurer will check whether each project is described clearly enough to support the reported figure and whether the project type was classified consistently.
Evidence to check Project summaries; classification matrix for project types; underlying project documentation; review sign-off showing the descriptions were checked against source records.
We documented the method we used to compile the removal and storage information, including the main assumptions and calculation steps.
Risk An assurer will probe whether the method was complete, applied consistently, and matched the underlying evidence.
Evidence to check Methodology paper; calculation workbook; assumption log; version history; internal review notes confirming the method used for the reported period.
We tracked non-permanence, leakage, and any reversals during the period, and we kept records of how those risks were monitored.
Risk An assurer will look for evidence that monitoring was active, that reversals were captured in the right period, and that any risk controls were operating as described.
Evidence to check Monitoring reports; incident or reversal logs; project monitoring plans; correspondence with project owners or verifiers; period-end reconciliation of reversals and adjustments.
Before making any public neutrality statement, we checked that the credits we relied on were credible and met our internal acceptance criteria.
Risk An assurer will test whether the credits used for the claim were screened for quality and whether the basis for calling them credible was documented.
Evidence to check Credit due-diligence file; acceptance criteria; supplier or registry evidence; verification statements; approval record for the public claim.
We reviewed whether the public neutrality claim and any use of credits sat comfortably with our emissions-reduction plan and did not weaken it.
Risk An assurer will probe whether the claim could be seen as distracting from, or conflicting with, the organisation’s reduction pathway.
Evidence to check Net-zero or reduction plan; board or management papers on the claim; internal challenge notes; communications review showing the claim was checked against the reduction strategy.
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe request goes to the sustainability team alone, even though the figures and descriptions sit with project, finance, procurement, or carbon-credit owners.
- Framework language firstPeople 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 setThe team starts collecting data without stating which entities, projects, or credit transactions are in scope, so different contributors pull different populations.
- Wrong time basisOne team uses the reporting year while another uses purchase, cancellation, or project dates, which makes the dataset cover mismatched periods.
- Mixed counting basisRemovals and credits are gathered on different measurement bases and then combined as if they were directly comparable, which distorts the totals.
- Source labels lostOriginal 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 mergedCancelled credits, planned credits, and removals are put into one spreadsheet without clear splits, so items that should stay distinct get blended together.
- Evidence details missingThe collector keeps the number but not the supporting date, version, or document reference, leaving no audit trail for later review.
- No sign-off trailData is passed along by email or chat without named review and approval, so nobody can show who checked the figures before they were used.
Judgement needed
- Set the cut-off for acquisitions and disposalsDecide 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 operationsWhere 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 perimeterState 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 removalsExplain 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 estimatesIf 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 riskFor 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 totalsState 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 dataIf 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
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
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.
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.
Quality ladder
- Basic
I report 12,000 tCO2e of removals and 8,000 tCO2e of carbon credits used this year.
- Better
I report 12,000 tCO2e of removals from a forestry storage project, 8,000 tCO2e of credits cancelled from a verified cookstove project, and I use a market-based accounting approach.
- Best
I report 12,000 tCO2e of removals from a forestry storage project with long-lived storage and low reversal risk, plus 8,000 tCO2e of credits cancelled from a verified cookstove project under a recognised quality standard, and I use these only to support part of our target because our own cuts still do most of the work; the removals figure is lower than last year because one project was delayed.
Check your understanding
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.
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.
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.
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.
Ask the Knowledge Hub AI Assistant about this disclosure
Get practical answers for your reporting context.
Check your text
Paste one or two paragraphs. The fragment is used for this check only and is not stored in your conversation.
Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
E1-9
within ESRS E1: Climate Change
Related & explore
More in ESRS E1 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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