Claims Codeof Practice
Building integrity involuntary carbon markets
November, 2023. v.2

vcmintegrity.org

About VCMI
VCMI is an international initiative to drive
credible, net-zero-aligned participationin voluntary carbon markets. VCMI wasestablished to help ensure that voluntarycarbon markets make a significant,measurable, and positive contribution
to achieving the Paris Agreement goals,
while also promoting inclusive andsustainable development. The imperativeof keeping global average temperature
increase to below 1.5 degrees Celsius
requires the world to avoid, reduce,and remove as large a quantity ofgreenhouse gas (GHG) emissions as
possible, as quickly as possible.
To help do so, VCMI coalesces
stakeholders around a shared vision,
enabling high-integrity voluntarycarbon markets to make a meaningful
contribution to climate action while
also supporting the achievement of
the UN SDGs. VCMI connects with andamplifies initiatives that share this vision.

Contents
Executive Summary
Pg 4
Letter from VCMI Co-Chairs
Pg 9
The aims of the VCMI Claims Code of PracticePg 11
Governance and VCMI’s role in voluntary carbon markets
Pg 14
The VCMI Claims Code of PracticePg 16
Glossary
Pg 36
Acknowledgements
Pg 40
How to access additional information
Pg 42

The VCMI Claims Code of Practice and its accompanying documents, including, without limitation, the Background Document,
Supplementary Guidance, and Explanatory Notes, are designed to promote credible, net-zero-aligned participation in voluntarycarbon markets. They have been developed through a multistakeholder public consultation and road testing. While VCMI encourages
use of the Claims Code of Practice and its accompanying documents by all relevant organizations, any and all statements, claims
and actions made or taken based fully or partially on the Code and/or its accompanying documents are the full responsibility of
those engaging in them, whether or not in a way aligned with the recommendations therein. Neither VCMI, nor other individuals
and organizations who contributed to the Code and/or its accompanying documents assume responsibility for any consequences
or damages, legal or otherwise, resulting directly or indirectly from any use of, or as a result of relying on, the Code and/or its
accompanying documents, or their contents, or otherwise arising in connection therewith. Organizations are recommended to takeindependent legal advice on their intended use of the Code and/or its accompanying documents in each relevant jurisdiction.

3

Executive
Summary

4

Executive Summary
The purpose of the Claims CodeVoluntary carbon markets have the potential to help fill gaps in financing for climate mitigation, enhance corporate
efforts to transition to net-zero, and support the achievement of countries’ Nationally Determined Contributions toclimate action and sustainable development objectives. They can also support and accelerate the introduction ofrobust, well-designed climate policies.
However, this potential can only be realized if voluntary carbon markets operate with high integrity. This means thatcarbon credits must be generated by activities that truly go beyond business-as-usual and benefit host communities– the supply side – and that their use increases overall greenhouse gas mitigation rather than just substituting forexisting actions – the demand side. Without clear, high-integrity rules for both these aspects, voluntary carbon markets
will rightly continue to be viewed with suspicion, companies will be afraid to invest, and their potential will be lost.
The VCMI Claims Code of Practice addresses integrity on the demand side by guiding companies and other nonstate actors on how they can credibly make voluntary use of carbon credits as part of their climate commitments
and on how they communicate their use of those credits. It provides clarity, transparency, and consistency on whatthese commitments and claims mean and will give confidence to all those engaging with voluntary carbon markets.
Together, VCMI and ICVCM work in close partnership to create and end-to-end model to achieve a voluntary carbon
market with integrity, by providing clear guidance from both the demand and supply sides.
The Claims Code is the result of two years of research and engagement with stakeholders across all sectors andregions, including road-testing of a provisional version, published in 2022, and two public consultations. Following
the publication of the VCMI Claims Code in June 2023, VCMI carried out extensive engagements with a diverse
set of stakeholder groups, including a VCMI Stakeholder Forum, Early Adopters Group and Expert Advisory
Group. These stakeholders have been critical to the updates outlined in this version 2 of the Claims Code, andin the development of the VCMI Monitoring, Reporting and Assurance (MRA) Framework, which outlines clear
procedures for companies to follow in order to make a VCMI Claim. This work has taken place in the context
of an emerging, coherent governance framework across voluntary carbon markets and increasing corporate
accountability. The Claims Code has deliberately been designed in coordination with existing standard settersin order to align with and complement their work, thereby increasing clarity for businesses, their stakeholders,
and the wider public. The extensive engagements with external stakeholders that took place between June andNovember 2023 gave VCMI the opportunity to understand in detail the practical challenges faced by companies
and other non-state actors (NSAs) in meeting the requirements set out in the Claims Code. As such, the Claims
Code was improved in November 2023 to address some of the challenges raised and provides more clarity tocompanies and other NSAs on how to achieve a VCMI Claim.

Who the Claims Code is for
The VCMI Claims Code of Practice is designed for:• companies seeking to make credible, voluntary use of carbon credits and receive validation in the form of a
VCMI Claim;• individuals, businesses, and other buyers of goods and services seeking to make net-zero-aligned purchases;• investors and other stakeholders who want to evaluate the credibility of a company's climate ambition and its
actions, including its use of carbon credits, alongside broader decarbonization efforts; and• governments and their regulatory agencies considering how to incentivize non-state actors to use carbon
credits credibly and to structure their claims to be truthful, clear and informative, through governmentdeveloped or endorsed corporate reporting requirements, advertising and consumer protection standards andother policies, measures or guidance on the use of carbon credits.

5

VCMI—Claims Code of Practice5How the VCMI Claims Code works
The Claims Code is based on a four-step process.

FOUR-STEP PROCESS

01

Comply with theFoundational Criteria

02

Select a VCMI Claim to makeand demonstrate progress
towards meeting near-termemission reduction targets

03

Meet the required carbon
credit use and quality
thresholds

04

STEP

FOUR

Obtain third-party assurance
following the VCMI Monitoring,
Reporting & Assurance (MRA)
Framework

To make an enterprise-wide VCMI Claim, companies must:
1: COMPLY WITH THE FOUNDATIONAL CRITERIA
These are designed to be aligned with the long-term goals of the Paris Agreement and represent current corporate
best practice. The Foundational Criteria require companies to:• maintain and publicly disclose an annual greenhouse gas emissions inventory;• set and publicly disclose science-aligned near-term emission reduction targets, and publicly commit toreaching net-zero emissions no later than 2050;• demonstrate that the company is making progress on financial allocation, governance, and strategy towards
meeting a near-term emission reduction target; and• demonstrate that the company’s public policy advocacy supports the goals of the Paris Agreement and does
not represent a barrier to ambitious climate regulation.

6

VCMI—Claims Code of PracticeFigure 1. Carbon Integrity Claims
2: SELECT A VCMI CLAIM TO MAKE AND DEMONSTRATE PROGRESS TOWARDS MEETING NEAR-TERM
EMISSION REDUCTION TARGETS

VCMI has defined three claims that companies and other non-state actors can make. All three represent action
above and beyond companies’ internal decarbonization efforts. These claims are appropriate for companies thatare taking action now to accelerate global net-zero, by going above and beyond science-aligned emissions cuts
through the additional use of high-quality carbon credits and that are either making progress to meet their nearterm emission reduction target during interim years or have already met their targets.
• Carbon Integrity Silver requires the purchase and retirement of high-quality carbon credits in an amountequal to or greater than 10%, and less than 50%, of a company’s remaining emissions once it has
demonstrated progress towards its near-term emission reduction targets.
• Carbon Integrity Gold requires the purchase and retirement of high-quality carbon credits in an amountequal to or greater than 50%, and less than 100%, of a company’s remaining emissions once it has
demonstrated progress towards its near-term emission reduction targets.
• Carbon Integrity Platinum requires the purchase and retirement of high-quality carbon credits in an amountequal to or greater than 100% of a company's remaining emissions, once it has demonstrated progress
towards its near term emissions reduction targets.
All claimants must have met the Foundational Criteria and be able to demonstrate emission reductions incomparison to their base year on an absolute and / or intensity basis. In addition, the percentage of total remaining
emissions to be covered by carbon credits must increase in each subsequent year after a company makes its
Carbon Integrity Silver or Gold claims.

3: MEET THE REQUIRED CARBON CREDIT USE AND QUALITY THRESHOLDS
The carbon credits a company uses must be of the highest quality, both to underpin the credibility of its claims
and to help drive integrity across the market. VCMI defines high-quality carbon credits as those that meet
the Integrity Council for the Voluntary Carbon Market (ICVCM) Core Carbon Principles1 and qualify under its
Assessment Framework.
All Carbon Integrity Claims require the purchase of carbon credits representing mitigation—either emission
reductions or removals—achieved outside the value chain of the company. This is also defined as ‘beyondvalue chain mitigation’, through which companies play a key role in achieving climate goals and accelerating thecollective effort to reach global net-zero emissions.

1

7

VCMI has developed a set of transitional measures for companies to adhere to in the interim as supply of CCP-Approved credits scale
up in the market. These transitional measures are detailed in Section 5 'VCMI Claims Code of Practice' of this document, and in the
VCMI MRA Framework.

VCMI—Claims Code of Practice4: OBTAIN THIRD-PARTY ASSURANCE OF REPORTED INFORMATION
To substantiate a Carbon Integrity Claim, transparent reporting and assurance of information is essential.
Claimants must demonstrate that all Foundational Criteria and Carbon Integrity Claim-specific requirements havebeen met, and must disclose key information related to the carbon credits purchased.
While Carbon Integrity Claims are limited to voluntary action, we believe that robust, comprehensive policies andregulations are essential if the world is to avoid catastrophic climate change. VCMI hopes that the Claims Code will
constitute a valuable contribution to this emerging policy architecture.
VCMI welcomes engagement and feedback. Please email: info@vcmintegrity.org

8

VCMI—Claims Code of PracticeLetterfrom VCMI
Co-Chairs

9

VCMI—Claims Code of PracticeLetter from VCMI Co-Chairs
On behalf of the Voluntary Carbon Markets Integrity Initiative (VCMI) Steering Committee and Secretariat, we arepleased to present this Claims Code of Practice on the voluntary use of carbon credits. Such guidance is essential
to ensure the integrity of voluntary carbon markets. Integrity underpins trust, and trust will underpin the growth— in the short, medium and long term — of high-value and purposeful voluntary carbon markets which make ameaningful contribution to the Paris Agreement goals while at the same time to the UN Sustainable Development
Goals (SDGs).
VCMI released its provisional Claims Code in 2022. We then undertook a public consultation and road-tested theprovisional Code with around 70 companies. VCMI thoroughly evaluated the feedback received, processed all thecomments, and released an operable2 Claims Code in June 2023. In doing so, we clarified the main concepts andprovided clear and practical guidance for companies to lay the foundations for the credible use of carbon credits.
The Claims Code has now been complemented with additional guidance and research. These include branding for
Carbon Integrity Claims and our Monitoring, Reporting and Assurance (MRA) Framework, which provides essential,
process-driven guidance on how companies can obtain a claim.
This approach was intended to ensure that all outstanding issues identified during the consultation process havebeen adequately addressed. This process included consultation with the VCMI Expert Advisory Group (EAG) andthe Stakeholder Forum, alongside the Country-Contact Group and the Early Adopters Program. VCMI is leading
the way, while leaning on the expertise, inputs and feedback from the experts and stakeholders who so generously
devote their time to ensuring that voluntary carbon markets can deliver real and additional benefits.
We are deeply grateful to all those who have given their time and talents to the development of this Claims Code.
Companies now have clear guidance on how to act. Companies are now able to make Carbon Integrity Claims, andall information relating to the requirements included in the Claims Code can now undergo an assurance process as
outlined in the newly-released MRA Framework.
VCMI has worked in partnership with other key voluntary standards, recognizing the important role they play, andwe will continue to do so. We will only be able to maximize the impact of high-integrity voluntary carbon markets
towards keeping global warming to below 1.5 degrees Celsius if we are able to coordinate and complement ourefforts, rather than duplicate or overlap them.
VCMI’s Claims Code goes hand in hand with the Integrity Council for the Voluntary Carbon Market (ICVCM)’s Core
Carbon Principles (CCPs). The release of these two streams of work in 2023 is building confidence in a highintegrity voluntary carbon market that can accelerate global net-zero. This has only been achieved thanks to close
partnerships with many stakeholders committed to mutual goals. Companies now know how to make credible useof carbon credits. Now it is time for implementation.

Tariye Gbadegesin and Rachel Kyte
VCMI STEERING COMMITTEE CO-CHAIRS

2

10

An operable Claims Code meant that a company could go through the process, meet all Foundational Criteria, and comply with thefirst three steps. As of November 2023, a company is able to make Carbon Integrity Claims, as the VCMI Monitoring, Reporting andAssurance (MRA) Framework has been put in place.

VCMI—Claims Code of PracticeThe aims of
the VCMI
Claims Codeof Practice11

VCMI—Claims Code of PracticeThe aims of the VCMI
Claims Code of Practice
About the VCMI Claims CodeThe primary purpose of the VCMI Claims Code is:• to provide clear requirements, recommendations, and supporting guidance to companies and other nonstate actors3 on when they can credibly make voluntary use of carbon credits as part of their near-termemission reduction objectives and long-term net-zero commitments; and• to provide guidance on how to describe the use of those credits.
All stakeholders need to ensure that their use of carbon credits accelerates—rather than undermines—their contribution
to global climate action. Today, thousands of companies are making climate commitments, such as to reduce emissions
to certain levels by specific dates and to decarbonize their supply chains. However, there is a lack of clarity about
what these commitments and related claims mean. There is often insufficient transparency about corporate climate
performance, and inconsistent use of terminology. These shortcomings risk undermining confidence in the integrityof voluntary carbon markets and in corporate commitments more broadly, even when those commitments are genuine.
Many stakeholders are concerned that the use of carbon credits could hinder, delay, or replace efforts bycompanies to reduce greenhouse gas (GHG) emissions within their operations and supply chains. Without clear
and transparent guidance about the voluntary use of carbon credits for underpinning credible claims, investors
and consumers are not able to effectively allocate capital and direct their purchasing power to incentivize realcompany leadership on climate mitigation. Companies making non-credible claims when using carbon credits
face significant risks, ranging from reputational damage, due to accusations of overstating climate performance,
to potential fines by domestic authorities and litigation (where such claims are deemed false or misleading). The
negative impacts may also extend to companies making credible claims, as reputational risks may lead to a moreconservative approach and undermine climate action.
Many companies around the world want to understand how they can use carbon credits in their climate strategies
in a way that is accepted by investors, civil society, government regulators, and policymakers. Providing this clarity
is the goal of this Claims Code. The claims delineated in the Claims Code will help companies at different levelsof ambition and action to demonstrate that they are using carbon credits appropriately as a tool to deliver climate
mitigation that is additional to that already taking place within their value chains.
Carbon Integrity Claims will give the most innovative companies already performing well on climate mitigation an
incentive to go further and inspire other companies to follow. For those companies and other stakeholders that do
not yet qualify for a Carbon Integrity Claim, the robust claims system will help them understand what actions need
to be taken for them to embark on the decarbonization journey and progress towards meeting the Foundational
Criteria and making a Carbon Integrity Claim.
The Claims Code is designed for:• companies seeking to make credible, voluntary use of carbon credits and receive validation in the form of a
VCMI Claim;• individuals, businesses, and other buyers of goods and services seeking to make net-zero-aligned purchases;• investors and other stakeholders who want to judge the credibility of a company's climate ambition andactions, including its use of carbon credits, alongside broader decarbonization efforts; and• governments and their regulatory agencies considering how to incentivize non-state actors to use carbon
credits credibly, and to structure claims to be truthful, clear and informative, through government-developedor endorsed corporate reporting requirements, advertising and consumer protection standards, and otherpolicies, measures, or guidance.
312

For convenience, we use the term ‘company’ throughout this document, but all guidance can be applied equally to other non-state actors.

VCMI—Claims Code of PracticeThis document represents the second part of a two-part release of the Claims Code in 2023. Details of how it fits
into the full Claims Code package can be found in Box 1.

BOX 1: VCMI’S FULL CLAIMS CODE DEVELOPMENT
This Claims Code of Practice builds on the provisional Claims Code released in 2022 and thesubsequent feedback received. It sets out the steps that companies and other non-state actors musttake for the credible use of carbon credits to make a Carbon Integrity Silver, Gold, or Platinum Claim
as part of net-zero transitions. Carbon credits cannot be counted towards the achievement of withinvalue chain emission reduction targets. Carbon Integrity Silver, Gold and Platinum Claims are made bycompanies that are taking action now to accelerate global net-zero, by going above and beyond sciencealigned emissions cuts through additional use of high-quality carbon credits.
With the branding and MRA Framework now complete – drawing on consultation with the VCMI
Stakeholder Forum, Expert Advisory Group, Country Contact Group and Early Adopters Program, as
well as externally commissioned research-companies are now able to make a Carbon Integrity Claim.
In addition, VCMI has launched the beta version of a Scope 3 Flexibility Claim, designed to provide
greater accessibility to companies not yet able to meet their Scope 3 emissions reduction targets. . . Thisadditional guidance complements and builds on what was already contained in the first iteration of theClaims Code.
VCMI acknowledges that the claims presented in the Claims Code may not be achievable for small andmedium-sized enterprises (SMEs), many companies in the Global South, and companies with low profit
margins. VCMI will therefore explore possible special provisions to promote accessibility to the Claims
Code for these companies and other non-state actors.

13

VCMI—Claims Code of PracticeGovernanceand VCMI’s
role involuntarycarbonmarkets

14

VCMI—Claims Code of PracticeGovernance and VCMI’s rolein voluntary carbon markets
The integrity—and therefore the value—of VCMI Claims depends on functional and reliable overall governance ofvoluntary carbon markets and a credible MRA Framework, the latter of which has now been completed. Claims
must be credible to be of value to companies, investors, regulators, and other stakeholders evaluating climate
commitments and achievements, as well as to those seeking to create programs that rely on a credible claims regime.
Our approach to addressing governance and infrastructure gaps is two-fold. First, VCMI recognizes the need for
a Claims Code that is part of a coherent governance framework across voluntary carbon markets and corporate
accountability spaces. Accordingly, VCMI has designed an MRA Framework that builds on and aligns with—rather
than duplicates—existing benchmarks and corporate accountability frameworks. VCMI respects and recognizes
the role each organization plays in voluntary carbon markets and engages in ongoing coordination efforts with the
Science Based Targets initiative (SBTi), the Greenhouse Gas Protocol (GHG Protocol), CDP, We Mean Business,
and ICVCM, among other key corporate voluntary standards bodies. The Claims Code makes clear reference tothese other institutions and their guidance, when applicable. It acknowledges their role and contribution alongsidethat of VCMI and works to ensure that there is alignment in the use of definitions adopted, so that companies
are clear on terminology and on how these different institutions come together in the voluntary carbon market
ecosystem.
Second, we recognize that VCMI’s role in voluntary carbon market governance is one piece of a larger puzzle.
Ensuring the effective wider governance of voluntary carbon markets requires a broader convergence of actors
and resources to fill the need for assurance services, among other components.
We remain committed to working with the larger community, and with governments, to address this overarching
governance need. For example, VCMI closely followed the High-Level Expert Group on the Net-Zero Emissions
Commitments of Non-State Entities (HLEG), established by the UN Secretary-General (UNSG), to ensure that the
Claims Code’s contribution to leveraging the integrity of the market is recognized.
VCMI acknowledges that the climate finance gap to meet the Paris Agreement is significant and that mobilizing
finance – including through voluntary carbon markets – is urgently needed. VCMI firmly believes that high-integrity
voluntary carbon markets can unlock private finance and drive financial resources where they are most needed,leading to not only GHG emissions reductions but also to job creation, income generation, and improvements inwell-being. An enabling policy environment for high-integrity voluntary carbon markets will help ensure they deliver
maximum benefits for climate and socio-economic prosperity. That is why VCMI released its Access Strategy
Toolkit based on our engagement with policymakers in countries hosting carbon market activities globally. The
Toolkit sets out the steps required to access voluntary carbon market finance as part of a holistic approach toclimate finance.
The VCMI Claims Code of Practice outlines requirements, recommendations, and supporting guidance forcompanies so that they can prepare to make a Carbon Integrity Claim, as presented in Section 5. Requirements
refer to those actions that must be implemented by companies as a necessary condition to move forward in theprocess of making a claim. Recommendations and supporting guidance, meanwhile, provide companies withsuggestions and additional sources of information to highlight best practice measures that companies should
implement or work towards.

15

VCMI—Claims Code of PracticeThe VCMI
Claims Codeof Practice16

VCMI—Claims Code of PracticeThe VCMI Claims Code of PracticeThis document provides guidance for the credible voluntary use of carbon credits by companies and othernon-state actors and on how they communicate their use of those credits. The Claims Code builds on theprovisional Claims Code released by VCMI in June 2022, and subsequent feedback received, and expands on therequirements of other leading climate change initiatives4.
The content of the Claims Code is driven by VCMI’s Principles for High Ambition and High Integrity Voluntary
Corporate Climate Action (Please refer to Background Document – section A).

VCMI Enterprise-wide Claims
The VCMI Claims Code sets out how companies can make assurable enterprise-wide claims, which reflect thecredible voluntary use of carbon credits in support of collective efforts to reach global net-zero no later than 2050.
This section outlines the four key steps that companies must take to make a VCMI Claim. By following these steps
and adhering to the requirements, a company will be able to obtain one of the enterprise-wide claims described inthis Claims Code: Carbon Integrity Silver, Carbon Integrity Gold, or Carbon Integrity Platinum.
Carbon Integrity Claims will be appropriate for companies that are taking action now to accelerate global net-zero,by going above and beyond science-aligned emissions cuts through the additional use of high-quality carbon
credits, and by either making demonstrable progress towards meeting their near-term emission reduction target ininterim years, or having already met their targets.
For companies wishing to make a VCMI Claim that covers their enterprise-wide emissions, there is a four-stepprocess to be followed.

417

Including the Carbon Pricing Leadership Coalition’s (CPLC) Report of the Task Force on Net-Zero Goals and Carbon Pricing; the full suiteof Science Based Target initiative’s (SBTi) target setting guidance and standard; Gold Standard’s Scope 3 Value Chain Interventions
Guidance; The Oxford Principles for Net-Zero Aligned Carbon Offsetting; the UNSG’s HLEG; and the GHG Protocol’s Corporate Value
Chain (Scope 3) Accounting and Reporting Standard.

VCMI—Claims Code of PracticeThe four steps for making a VCMI claim
The following sections outline specific requirements, recommendations andsupporting guidance for making a VCMI Claim5.

01

1. Maintain and publicly disclose an annual greenhouse gas emissions inventory
2. Set and publicly disclose science-aligned near-term emission reduction targets, andpublicly commit to reaching net zero emissions no later than 2050
3. Demonstrate that the company is making progress on financial allocation, governance,and strategy towards meeting a near-term emission reduction target
4. Demonstrate that the company’s public policy advocacy supports the goals of theParis Agreement and does not represent a barrier to ambitious climate regulation

Complywith theFoundational
Criteria

02

Select a VCMI
Claim to makeand demonstrateprogress towards
meeting nearterm emission
reduction
targets

03

18

Carbon Integrity Silver(≥ 10% and < 50%)

Meet therequired carbon
credit use
and quality
thresholds

04

5

Select a VCMI Claim to make and meet the respective requirements.
Each Carbon Integrity Claim requires the purchase and retirement ofhigh-quality carbon credits proportionate to its remaining emissions
once a company has met, or demonstrated progress towards meeting,its near-term emission reduction targets:

Obtainthird-party
assurance
following the
VCMI MRA
Framework

Carbon Integrity Gold(≥ 50% and < 100%)Carbon Integrity
Platinum (≥ 100%)

Purchase and retire high-quality carbon credits following
the ICVCM’s Core Carbon Principles and transparently
report relevant information pertaining to retired credits,
including authorization of credit by the host country.

To substantiate a VCMI Claim, it is essential thatcompanies provide information relating to theFoundational Criteria and claim-specificrequirements, including information relating to theretirement of high-quality carbon credits. The VCMIMRA Framework outlines procedures for reportingand independent third party assurance of key
metrics which companies shall adhere to in order tomake a VCMI Claim.

VCMI may update or revise the Claims Code of Practice (“Claims Code”) at any time and such updates and revisions will take effect for any
subsequent VCMI Claims. Any updates or revisions to the Claims Code will have no effect on the validity of existing VCMI Claims.

VCMI—Claims Code of Practice1. Comply with the Foundational Criteria
What are the VCMI Foundational Criteria?
The VCMI Foundational Criteria are designed to be aligned with the Paris Agreement’s long-term mitigation goals.
They draw on best practice guidance developed by leading global initiatives such as the SBTi and the UN-led Raceto Zero Campaign, as well as guidance from existing and emerging regional and national regulatory frameworks.
The Foundational Criteria serve as the backbone for a robust climate strategy and therefore must be addressed
first as part of making a VCMI Claim.

FOUNDATIONAL CRITERIA

Before making voluntary use of carbon credits (and making a VCMI Claim), companies shall adhere to all fourFoundational Criteria.

1 Maintain and publicly disclose an annual greenhouse gas emissions inventory
and publicly disclose science-aligned near-term emission reduction targets, and2 Setpublicly commit to reaching net-zero emissions no later than 2050

that the company is making progress on financial allocation,
3 Demonstrate
governance and strategy towards meeting a near-term emission reduction target

that the company’s public policy advocacy supports the goals of the
4 Demonstrate
Paris Agreement and does not represent a barrier to ambitious climate regulation

REQUIREMENTS FOR EMISSIONS INVENTORIES
Companies are required to:Foundational Criterion 1:
Maintain and publicly
disclose an annual
greenhouse gas
emissions inventory

19

VCMI—Claims Code of Practice• Make an enterprise-wide GHG emissions inventory publicly available
on the company’s website and update it annually.
• Report its GHG emissions inventory in accordance with the most up todate GHG Protocol Corporate Accounting and Reporting Standard, the
GHG Protocol Corporate Value Chain (scope 3) Accounting and ReportingStandard, and the forthcoming Land Sector and Removals Guidance.
• Include in the GHG emissions inventory company-wide scope 1 and2 emissions, separately disclosing scope 2 emissions calculatedusing the location-based and market- based approaches, as per the
GHG Protocol Scope 2 Guidance. However, a single and consistentaccounting approach (either market-based or location-based) must
be used for setting and tracking progress towards targets, in line with
SBTi’s near-term emission reduction target criteria. Companies shallalso include scope 3 emissions for all existing emissions sources,
according to the minimum boundary established for each of the fifteen
scope 3 categories as set out by the most up to date GHG Protocol
Corporate Value Chain (Scope 3) Accounting and Reporting Standard.
• Provide clear explanations and estimations of how any structuralchanges to the company, methodological changes, or changes toactivity data or emission factors applied have affected the most recent
reporting year’s inventory. This will make it possible to separate any
impacts that are resulting from the methodological changes from
impacts due to mitigation actions. If structural changes or changes
in methodology or data sources result in significant differences inemissions, companies are required to recalculate base year emissionsin accordance with the most up to date GHG Protocol Corporate
Accounting and Reporting Standard and the Corporate Value Chain(scope 3) Accounting and Reporting Standard. In the absence of abase year emissions recalculation policy, a company must agree toapply a 5% significance threshold for emission recalculations.

RECOMMENDATIONS AND SUPPORTING GUIDANCE:• Companies may report their inventory through any of the following formats: its CDP Climate
Disclosure; the reporting company’s annual sustainability report or annual statement of GHG
emissions; its Global Reporting Index (GRI) disclosure, that includes GRI 305-1, 305-2, and 305-3; orits Sustainable Accounting Standards Board (SASB) index.
• VCMI acknowledges that data availability is a challenge for many companies. However, in the pursuitof net-zero, VCMI encourages companies to take measures to expand and improve processes for
capturing better quality and more comprehensive data across all scope 3 emissions that exist for thecompany. For guidance on collecting emissions data, please refer to the most up to date GHG Protocol
Corporate Value Chain (Scope 3) Accounting and Reporting Standard (see Chapter 7: Collecting Data).

Foundational Criterion 2:
Set and publicly disclosescience-aligned nearterm emission reduction
targets, and publicly
commit to reaching netzero emissions no later
than 2050

Science-aligned targets are those that follow what the latest climate sciencesays is necessary to limit global warming to 1.5 degree Celsius with no or
limited overshoot, as highlighted by the Intergovernmental Panel on Climate
Change (IPCC) through its model pathway of CO2 emissions reductions. VCMI
acknowledges that deep, rapid and sustained reductions in GHG emissions areurgently needed to achieve global net-zero by the middle of this century.
REQUIREMENTS FOR NEAR-TERM EMISSION REDUCTION TARGETS• Companies must set and publicly disclose near-term emission reduction
targets covering scopes 1, 2 and 3. These targets must be set following
the most up to date criteria for setting near-term emission reduction
targets from SBTi or an equivalent science-aligned target setting
framework, henceforth or equivalent6. SBTi requires near-term targets
to be within 5–10 years, i.e., a maximum of 10 years into the future fromthe date the target was set7. Targets can be set in absolute or intensity
terms, following SBTi’s criteria for setting near-term targets.

6

In 2024, VCMI will work to identify equivalent target setting frameworks which it deems acceptable for the purposes of making a VCMI Claim.

7

From 2030 onwards, all subsequent near-term reduction targets must be no more than five years apart.

20

VCMI—Claims Code of Practice• Companies must follow the most up to date SBTi or equivalent criteria
for setting the target boundary and emissions coverage (this means
95% coverage of scopes 1 and 2 emissions, and 67% coverage ofscope 3 emissions, if scope 3 emissions represent over 40% of theinventory from all scopes). For power companies, SBTi sector specificcriteria must be followed, including setting a third target covering
100% of emissions from downstream use of fossil fuels.
• For companies with targets following the SBTi near-term target setting
criteria, but which have not had these targets validated, they must
submit a target to SBTi for validation within 24 months8. To obtaina VCMI Claim, the company must provide evidence of the SBTi
commitment letter as part of the formal SBTi commitment process.
VCMI will review the target setting landscape in the coming years andupdate the Claims Code to reflect additional robust, science-aligned
standards as they become available.

REQUIREMENTS FOR LONG-TERM NET-ZERO EMISSION
REDUCTION TARGETS
Companies are required to:• Make a public commitment to achieve net-zero emissions no later
than 2050, including scopes 1, 2 and 3 GHG emissions, as well as
land-based GHG emissions where applicable;• Disclose the definition of net-zero adopted, in line with globally
recognized sustainability frameworks or guidance, as well as theprinciples and/or methodology they have used or intend to use to set
their net-zero target; and• Use the same base year for the long-term net-zero target, once it isset, as that used for the initial near-term target.
RECOMMENDATIONS AND SUPPORTING GUIDANCE:• Companies are encouraged to set the most recent year with available data as their base year.
• Companies are encouraged to set a long-term emission reduction target, in line with theircommitment to reaching net-zero no later than 2050, within 24 months of obtaining a VCMI Claim.
• Regarding communicating the scope of emissions included within targets, VCMI suggests that theemissions coverage of companies’ targets, expressed as a share of total scope 1, 2 and 3 emissions,be prominently displayed and communicated alongside any target-related communication made by
the company. For example, if a company sets a target to reduce emissions by 30%, covering 75% of
its total value-chain emissions, it should disclose the 75% coverage in any communication related tothe 30% target, so as not to mislead stakeholders.
• Companies are encouraged to align with the recommendations set out by the UN High Level Expert
Group on the Net Zero Emissions Commitments of Non-State Entities and the UN-led Race to Zero,which require companies to halve emissions by 2030. Companies are also encouraged to join the
UN-led Race to Zero campaign.

8

21

The 24-month period to submit a target for SBTi validation is aligned with the formal SBTi commitment process.

VCMI—Claims Code of PracticeFoundational Criterion 3:
Demonstrate that thecompany is making
progress on financial
allocation, governance,and strategy towards
meeting its near-termemission reduction
targetTo operationalize Foundational Criterion 3, VCMI has established a set ofreporting requirements which it deems to be representative of whether
a company is making progress towards meeting its near-term emission
reduction target. They are designed to assess whether a company is taking
sufficient measures to decarbonize, including by funding GHG mitigation
activities and setting up appropriate climate governance structures. These
reporting requirements represent recommended best practice as outlined in
major climate transition plan frameworks (see Box 2).

REQUIREMENTS FOR FINANCIAL ALLOCATION
Companies are required to:• Publicly disclose total financial allocation9 dedicated to GHG mitigation
made during the most recent reporting year across the company’svalue chain. Companies shall disclose information relating to at least
one of the requirements below:• The percentage of annual revenue dedicated to GHG
mitigation; or• The percentage of capital expenditure (CAPEX) andoperational expenditures (OPEX) dedicated to GHG
mitigation. Companies shall disclose the definition chosen
for CAPEX and OPEX metrics using existing definitions fromglobal or regional taxonomy; or• If a company cannot disclose either of the aforementioned
metrics, it shall provide a statement to explain why, and aqualitative description and analysis of financial allocation
made and steps taken related to GHG mitigation.
• Total planned financial allocation dedicated to GHG mitigation
across the company's value chain. Companies shall disclose
information relating to at least one of the requirements below:• The percentage of annual revenue earmarked for GHG
mitigation; or• The percentage of CAPEX and OPEX that will be dedicatedto GHG mitigation. Companies shall disclose the definition
chosen for CAPEX and OPEX metrics using existing
definitions from global or regional taxonomy; or,• If a company cannot disclose either of the aforementioned
metrics, it shall provide a statement to explain why, and aqualitative description and analysis of financial allocation
made and steps taken related to GHG mitigation.

922

For more details on how to report on requirements for financial allocation, please refer to page 21–24 of the MRA Framework
VCMI—Claims Code of PracticeREQUIREMENTS FOR STRATEGY AND GOVERNANCE
Companies are required to:• Publicly disclose the following information related to the company`sgovernance structure for overseeing progress in reaching near-termtargets10. Companies shall disclose at least one of these metrics:• Whether their Board or senior-management-level compensation islinked to climate performance indicators11. If yes, then companies
shall disclose a description of the Board or senior-managementlevel compensation policy and indicators related to climate
performance; or• Whether their Board members or senior-management level havecapabilities or expertise on climate-related issues. If yes, thencompanies shall provide a description of the climate-related
capabilities and expertise held by board members or seniormanagement level; or• Whether they conduct board-level reviews on progress towards
meeting near-term emission reduction targets. If yes, thencompanies shall disclose the frequency of these board-level reviews.

RECOMMENDATIONS AND SUPPORTING GUIDANCE:• VCMI recommends that companies draw on guidance established by the most up to date Task
Force on Climate-related Financial Disclosures (TCFD) framework and the specific provisions of
the International Sustainability Standards Board (ISSB) International Financial Reporting Standards
Foundation S2 Climate-related Disclosures. Many companies may already be communicating theabove disclosure requirements as part of their annual reporting, including to CDP.
• If applicable, VCMI recommends that companies publicly disclose any changes in capital allocationfrom the most recent reporting year that were made to address climate-related risks andopportunities12.

10

For more details on how to report on requirements for Strategy and Governance, please refer to pages 26 and 27 of MRA Framework.

11

Compensation directly tied to GHG emissions reduction or progress against near-term emission reduction targets (year-to-year orbaseline comparison).

12

Based on the definition from ISSB IFRS S2 Climate-related Disclosures. ISSB has proposed seven cross-industry metrics to address
climate-related risks and opportunities: GHG emissions; transition risks; physical risks; climate-related opportunities; capital deployment;internal carbon prices; and the percentage of executive management remuneration.

23

VCMI—Claims Code of PracticeBOX 2: CLIMATE TRANSITION PLANS
A climate transition plan, sometimes referred to as a net-zero transition plan, is an entity’s overall
strategy that lays out the targets, actions or resources for its transition towards a lower-carbon economy,
including actions such as reducing its greenhouse gas emissions13 . Generally spanning several decades,
it outlines a set of objectives, policies, steps, and firm plans to reach net-zero. At the corporate level, aclimate transition plan helps a company demonstrate accountability and transparency by translating
net-zero commitments into actionable steps. However, there is no universal definition of a ‘transition plan’,and the specific elements vary across institutions, jurisdictions, and individual companies.
VCMI acknowledges the contributions on net-zero transition plans made by the UK Transition Plan Taskforce(UK TPT Disclosure Framework), the Glasgow Financial Alliance for Net-Zero (GFANZ), and UNSG’s HLEG.
During COP27, UK TPT released its Disclosure Framework and accompanying Implementation Guidancefor consultation. Subsequently, the final iteration of the TPT Disclosure Framework was officially released in
October 2023. The TPT Disclosure Framework represents a development of the recommendations of TCFD
and ISSB to disclose transition plans, aligned with the GFANZ transition plan framework, and consistent with
the UNSG HLEG’s recommendations. It comprises five key elements, guided by the principles of Ambition,
Action and Accountability, and focuses on the implementation of short-term corporate climate actions.
These elements include GHG emissions, financial indicators, and governance-related measures.
VCMI supports the UK TPT’s direction of travel and has drawn key disclosure elements from theDisclosure Framework into the Claims Code. In relation to the third Foundational Criterion, VCMI has
identified performance indicators from UK TPT and key disclosure frameworks that allow for a comparable,
quantitative, and qualitative assessment of a company’s credible continuous participation along the netzero pathway. VCMI encourages companies to report on other transition plan elements at their discretion.
13

ISSB IFRS S2 Appendix A definition of climate-related transition plan

REQUIREMENTS FOR PUBLIC ADVOCACY
Companies are required to:Foundational Criterion 4:
Demonstrate that thecompany’s public policy
advocacy supports
the goals of the Paris
Agreement and does
not represent a barrier
to ambitious climate
regulation• Submit a public statement describing how their advocacy activities are
consistent with the goals of the Paris Agreement.		
• In cases where companies are not taking part in public policy
advocacy activities, they shall publicly disclose that they do not
engage in any activities, either directly or indirectly, that might
influence policies, laws, or regulations with potential climate impact.
This includes activities through trade associations, professional bodies
or other organizations of which they are a member.

RECOMMENDATIONS AND SUPPORTING GUIDANCE:• Companies can refer to the Global Standard on Responsible
Corporate Lobbying and its four categories (i.e., Policy andCommitment, Governance, Action, and Specific Disclosures)as best practice to describe alignment of advocacy activities
with the goals of the Paris Agreement.

24

VCMI—Claims Code of Practice2. Select a VCMI Claim to make anddemonstrate progress towards meetingnear-term emission reduction targets
Once a company has met the VCMI Foundational Criteria, it should review whether it is able to meet the VCMI
Claim requirements detailed below, with particular consideration for efforts made to minimize total emissions within
its GHG emissions inventory, as well as the progress it is making towards meeting its near-term emission reduction
targets. VCMI recognizes companies may not have complete control or influence over all emission sources (scope
3 in particular), and as such have excluded specific emission sources from their near-term targets. It is, however,essential for all companies to make efforts to reduce overall GHG emissions in order to limit global temperatures
increases to less than 1.5°C and achieve the goals of the Paris Agreement.
Acknowledging the diversity of metrics and indicators used to monitor emission reductions across companies,
VCMI allows companies to demonstrate emission reductions achieved, in either absolute or intensity terms, bydisplaying total GHG emissions as reported in the GHG emissions inventory. To complement this, companies
must provide an explanation or description of whether and why they consider themselves to be making progress
towards their near-term targets, acknowledging that for many companies emissions reductions do not occur
linearly and can be significantly impacted by external factors. Although companies are accountable for reducing
emissions within their target boundary to meet near-term targets, it is also crucial for companies to have a longterm view of reducing overall emissions to ultimately achieve their net-zero ambitions.
The emissions profile of a company in the year of making a VCMI Claim, and the average cost per carbon credit,
will influence the associated costs of making a Carbon Integrity Claims. Companies that have made significant
progress to reduce emissions, either overall or at least within their target boundary, will therefore need to purchasefewer carbon credits to cover remaining emissions, in order to make a Carbon Integrity Claim. To take into accountthe varying constraints faced by companies with different emissions profiles, VCMI has created three Carbon
Integrity Claims, which are aligned with SBTi and the UNSG’s HLEG.

REQUIREMENTS FOR SELECTING A CARBON INTEGRITY CLAIM TO MAKE
Companies are required to:• Publicly disclose a statement asserting they have complied with the Foundational Criteria and all additional
requirements outlined in the VCMI Claims Code of Practice corresponding to the chosen Carbon Integrity
Claim. Please refer to the Supplementary Guidance document for clarity on how to communicate VCMI Claims.
Companies shall meet the requirements relating to the specific claim they seek to make, as outlined below:• Meet the Foundational Criteria.
• Publicly disclose the percentage of emissions reductions achieved in total GHG emissions in the mostrecent reporting year in comparison to the total GHG emissions reported in the base year (i.e. base year
used in the near-term target). This reduction can be demonstrated either on an absolute or intensity basis.
• Publicly provide an explanation that outlines whether and why the company considers that it has madeprogress towards meeting its near-term emission reduction target.

25

VCMI—Claims Code of Practice• Each Carbon Integrity Claim requires the purchase and retirement of high-quality carbon credits
proportionate to the company's remaining emissions14, once a company has met or demonstrated
progress towards meeting its near-term targets, with those credits only used to accelerate global net-zero.
• Carbon Integrity Silver (≥ 10% and < 50%)
• Carbon Integrity Gold (≥ 50% and < 100%)• Carbon Integrity Platinum (≥ 100%)• The percentage of carbon credits to be purchased and retired must increase in each subsequent year
after a company makes a Carbon Integrity Silver or Carbon Integrity Gold Claim.
Carbon credits underpinning Carbon Integrity Claims are not counted towards the internal emissions reductions
that a company undertakes to meet decarbonization targets. Rather, these purchases are used in support ofachieving the company’s climate goals and accelerating the collective effort to reach global net-zero emissions.

RECOMMENDATIONS AND SUPPORTING GUIDANCE:• When referencing the Claims Code, companies should include a hyperlink to the document toprovide an explanation of what the specific VCMI Claim means.

Figure 2. Carbon Integrity Claims

PlatinumGold
SilverCarbon Integrity Silver
requires the purchase andretirement of high-quality
carbon credits in an
amount equal to or
greater than 10%, and lessthan 50%, of a company’s
remaining emissions once
it has demonstrated
progress towards its
near-term emission
reduction targets.

14

26

Carbon Integrity Goldrequires the purchase andretirement of high-quality
carbon credits in an
amount equal to or greaterthan 50%, and less than
100%, of a company’s
remaining emissions once
it has demonstrated
progress towards its
near-term emission
reduction targets.

Carbon Integrity Platinum
requires the purchase andretirement of high-quality
carbon credits in an
amount equal to or
greater than 100% of acompany’s remaining
emissions, once it has
demonstrated progress
towards its near termemissions reduction
targets.

VCMI defines remaining emissions as the emissions that remain in a given year as a company progresses towards the delivery of its
near- and long-term targets

VCMI—Claims Code of PracticeBOX 3: BETA VERSION OF A SCOPE 3 FLEXIBILITY CLAIM
VCMI's new Scope 3 Flexibility Claim – launched as a beta version on November 28th 2023 as astandalone document made publicly available through VCMI's website – is designed to drive climate
action on corporate pathways to net-zero.
The new claim permits a company to make limited use of high-quality carbon credits to close thegap between its estimated scope 3 greenhouse gas (GHG) emission reduction target level, and its
current scope 3 emissions in a given year, as long as it has already taken other steps to reduce current
emissions.
Many companies experience difficulties in meeting their near-term scope 3 emission reduction targets(The Climate Board, unpublished report). The new claim will unlock demand for carbon credits fromcompanies making progress towards science-aligned targets, but unable to fully meet them.
The claim provides a mechanism to incentivise corporates back to making progress towards meeting
their targets, while also helping to mobilise urgently needed climate finance. Recent analysis suggeststhat the emissions gap between companies’ scope 3 emissions reduction targets and their current scope
3 emissions is around 1.4 gigatonnes of carbon dioxide equivalent currently (rising to be over 7 GtCO2e
by 2030) (MSCI Carbon Markets – formerly Trove Research, 2023).
The Scope 3 Flexibility Claim draws on extensive feedback from consultation with a broad and diverse
group of stakeholders. VCMI has launched this new claim as a beta version, because further fine-tuning isneeded, Alongside the beta version, VCMI has set out a roadmap towards fully operationalizing the claim in
2024 including strengthening the ecosystem interoperability and will examine current and upcoming legal
requirements relevant to this area. VCMI invites other standard-setting and accountability organizations
to work collaboratively with us on these issues. Until this work is completed, companies will not be able to
make a Scope 3 Flexibility Claim. Nevertheless, we invite them to join VCMI in testing this beta version.

27

VCMI—Claims Code of PracticeGraph 1 visually presents Carbon Integrity Silver, Gold and Platinum Claims, and the respective thresholds that
represent the amount of credits retired, proportional to the remaining emissions (total scopes 1, 2 and 3 emissions
within the GHG emissions inventory) in the year that a company makes a claim, having reduced emissions incomparison to the base year.

Remaining emissions
in VCMI claim year

Emissions reductions
since base year

Base year

Total GHG emissions inventory

Graph 1: Carbon Integrity Claims

Carbon credits retired

Min
10%

28

Min
50%

Max
50%

SILVER

PLATINUM

VCMI—Claims Code of Practice100%
or more

GOLD

Max
100%

3. Meet the required carbon credit use
and quality thresholds
Irrespective of the type of claim being made, companies should seek out and use carbon credits of the highest
quality, both to underpin the credibility of their claims and to help drive integrity across the market.
Carbon credits, with or without any associated corresponding adjustments, can be used to underpin Carbon
Integrity Silver, Gold and Platinum Claims. The carbon credits underpinning Carbon Integrity Claims are notcounted as internal emission reductions that a company undertakes to meet its own decarbonization targets; they
do not represent a substitution for internal emission reductions. Rather, these purchases are used in support ofachieving the company’s climate goals and accelerating the collective effort to reach global net-zero emissions.

REQUIREMENTS FOR THE PURCHASE AND RETIREMENT OF HIGH-QUALITY CARBON CREDITS
Companies shall purchase and retire Core Carbon Principles (CCP)-Approved credits when they become available.
CCPs that have been published by the ICVCM (see Box 4) constitute a basis to assess the quality of carbon
credits and, in the absence of the more detailed rules, are a useful framework to guide carbon credit purchases.
Published in early 2023, the program level CCPs are intended to identify high-quality carbon credits that createa verifiable climate impact, based on the latest science and expertise. The ICVCM, an independent governancebody for the voluntary carbon market, aims to provide the building blocks of viable, trustworthy and high-integrity
voluntary carbon markets by providing a benchmark for carbon credit quality.
The ICVCM announced that the assessment phase for carbon crediting programs will begin in late-2023, and for
categories of carbon credits soon thereafter. It expects to begin announcing carbon crediting programs that are
CCP-Eligible, and carbon credit categories that can be labelled CCP-Approved, in early 2024.
At the time of publication, these credits were not yet available, and will likely only be available in limited supply inthe near-term as ICVCM begins its assessments of programs and categories. VCMI therefore offers companies
two approaches to demonstrate the procurement of high-integrity credits during this transition phase until CCPApproved credits become widely available in the market.

Option 1: Purchase and retire
CORSIA eligible credits

Option 2: Disclose how existing
due diligence processes alignwith ICVCM’s CCPs

29

VCMI—Claims Code of Practice

When a specific activity type has not yet been assessed by the ICVCM,
companies may alternatively purchase and retire credits included in the
ICAO document CORSIA Eligible Emission Units approved for the 20212023 Compliance Period (Pilot Phase) or the 2024-2026 Compliance
Period (First Phase), pending assessment by the ICVCM. Once an activity
type has been assessed by the ICVCM, only CCP-Approved credits shall bepurchased and retired. Any CORSIA Eligible Emission Units retired before
assessments are made by the ICVCM for a given activity type will contributetoward meeting a VCMI Claim in a given year. These are carbon credits thatpass screening under the ICVCM's Assessment Framework. This framework,
which assesses credit quality at the carbon crediting program and carbon
credit category level, is underpinned by the ICVCM’s CCPs.

VCMI acknowledges that companies may have existing carbon credit
procurement agreements that were established prior to CCP-Approved
credits becoming available on the market. At the same time, companies may
have rigorous due diligence processes in place to ensure high-quality credits
are purchased and retired.

As such, as an additional transitionary measure while the volumes of
CCP-Approved credits scale up in the market, to satisfy the credit quality
requirement, companies may disclose how their due diligence process for
identifying credits of sufficient quality and integrity aligns with all 10 CCPs.
This must be a public disclosure and will need to take the form of a statement
included in a company’s annual or sustainability report, or other company
controlled public disclosure method.
For VCMI Claims made on or after January 1, 202615, to comply withthis VCMI Claims Code requirement, companies must transition topurchasing and retiring CCP-Approved credits. After this date, no further
public disclosure of alignment to the 10 CCPs will be accepted. Option 2
represents a logical transition and path towards ramping up high-quality andintegrity credits in the form of CCP-Approved credits in the coming years16.
For further guidance and insight on carbon credit quality and approaches tousing carbon credits, please refer to Background Document – section D.

REQUIREMENTS FOR REPORTING HIGH-QUALITY CARBON CREDITSIn addition to meeting the quality thresholds for carbon credit use, companies are required to publicly disclose key
information related to each carbon credit retired, including:• Number of credits purchased and retired that the company applied towards the VCMI Claim. While CCP
approved credits are not widely available in the market, CORSIA eligible credits or existing contractuallycommitted carbon credits supported by the company’s due diligence process alignment to ICVCM’s
10 CCPs, will be accepted as an interim measure until the ICVCM Assessment Framework has been
implemented. Companies shall transition to purchase and retire CCP-Approved credits by January 1, 202615.
• Certification standard name, project name, project ID, retirement serial number, retirement date, and issuingregistry for each credit used.
• Host country, credit vintage, methodology, and project type.
• Whether or not the carbon credit is associated with a corresponding adjustment in accordance with Article 6of the Paris Agreement. If the carbon credit is reported as being associated with a corresponding adjustment,
applied either currently or in the future, this shall be evidenced by authorization by a participating Party or
Parties, including information on the authorized use or uses, timings of the authorization, and the applicationof the corresponding adjustment.
• If associated with additional third-party certification regarding social or environmental integrity (e.g., SDGs
label, SD Vista, Climate, Community and Biodiversity Standards, etc.), companies must provide information
related to how the credit promotes equity and generates co-benefits to ecosystems and local economies.

15

VCMI reserves the right to revise this date, subject to changes in the availability of CCP-Approved carbon credits. Any revisions to thisdate will have no effect on the validity of pre-existing VCMI Claims.

16

VCMI recognizes the implications of this transition measure on existing long-term contracts and we welcome stakeholders within
voluntary carbon markets to collaborate on identifying appropriate solutions.

30

VCMI—Claims Code of PracticeBOX 4: ICVCM’S 10 CORE CARBON PRINCIPLES

A. Governance

Effective governance: the carbon-crediting program shallhave effective program governance to ensure transparency,
accountability, continuous improvement, and the overall quality ofcarbon credits.
Tracking: the carbon-crediting program shall operate or makeuse of a registry to uniquely identify, record, and track mitigation
activities and carbon credits issued to ensure credits can be
identified securely and unambiguously.
Transparency: The carbon-crediting program shall provide
comprehensive and transparent information on all credited
mitigation activities. The information shall be publicly available
in electronic format and shall be accessible to non-specialised
audiences, to enable scrutiny of mitigation activities.
Robust independent third-party validation and verification: thecarbon-crediting program shall have program-level requirements
for robust independent third-party validation and verification of
mitigation activities.

B. Emissions Impact

Additionality: the GHG emission reductions or removals from themitigation activity shall be additional, i.e., they would not haveoccurred in the absence of the incentive created by carbon
credit revenues.
Permanence: the GHG emission reductions or removals from themitigation activity shall be permanent or, where there is a risk ofreversal, there shall be measures in place to address those risks
and compensate reversals.
Robust quantification of emission reductions and removals: theGHG emission reductions or removals from the mitigation activity
shall be robustly quantified, based on conservative approaches,completeness and scientific methods.
No double counting: the GHG emission reductions or removals
from the mitigation activity shall not be double counted, i.e., theyshall only be counted once towards achieving mitigation targets orgoals. Double counting covers double issuance, double claiming,and double use.

C. Sustainable
development

Sustainable development benefits and safeguards: the carboncrediting program shall have clear guidance, tools and compliance
procedures to ensure mitigation activities conform with or go
beyond widely established industry best practices on social andenvironmental safeguards while delivering positive sustainable
development impacts.
Contribution toward the net-zero transition: the mitigation activity
shall avoid locking-in levels of GHG emissions, technologies orcarbon-intensive practices that are incompatible with the objectiveof achieving net-zero GHG emissions by mid-century.

31

VCMI—Claims Code of PracticeBOX 5: REMOVAL AND REDUCTION CREDITSVCMI does not specifically require companies to purchase and retire either reduction or removal credits
in order to make Carbon Integrity Silver, Gold, and Platinum Claims. From VCMI's perspective, companies
may invest in carbon credits issued from either emission reduction or removal projects for the global
transition to net-zero. They should prioritize projects based on the quality of the climate mitigation andco-benefit impacts they are expected to deliver. However, the importance of early investment in carbon
removal projects should be reinforced. As highlighted by the IPCC AR517, these solutions are fundamental
to achieving net-zero emissions and need to be scaled up. VCMI encourages companies to use carbon
dioxide removals as part of their carbon credits portfolio and invest in future carbon removals. Further
guidance is set out in Background Document – section D.

17

32“Summary for policymakers”, in Climate Change 2022: Mitigation of climate change, Intergovernmental Panel on Climate Change, April 4, 2022.

VCMI—Claims Code of Practice4. Obtain third-party assurance of reported
information following the VCMI Monitoring,
Reporting & Assurance (MRA) Framework
To substantiate a VCMI Claim, transparent reporting is essential to demonstrate that:• Foundational Criteria requirements have been met;
• VCMI Claim-specific requirements have been met, including the provision of information demonstrating
commitment to meeting near-term targets; and• Key information related to the carbon credits used to meet the VCMI Claim has been disclosed.
The metrics that companies must report in the first year of making a VCMI Claim are listed in the VCMI MRA
Framework. Reporting shall be made publicly available to stakeholders either on a company’s website, in a standalone
report (e.g., a climate strategy report), or within a more comprehensive report (e.g., a sustainability report).
The MRA Framework outlines the requirements and standards that bring integrity and rigor to the VCMI Claims
Code, ensuring that underlying information is appropriately evaluated, evidenced and verified for each claim.
Specific independent assurance requirements, as well as public disclosure requirements, are outlined in the
MRA Framework. These have been defined through an assessment of the corporate disclosure landscapeand through extensive stakeholder engagement. VCMI will continuously assess the assurance requirementsof evolving regulatory disclosure frameworks and update the MRA Framework accordingly. As detailed in the
Assurance Providers and Standards section of the MRA Framework, assurance shall be performed in line with
the International Standard on Assurance Engagements (ISAE), or the American Institute of Certified Public
Accountants (AICPA), or a specific International Organization for Standardization (ISO) Standard. If a company
has already undergone an independent, third-party assurance process for metrics relating to any of the VCMI
requirements, it can provide assurance documentation (e.g., assurance reports or statements) as evidence thatit has complied with that specific criterion. However, all companies are subject to a full reporting process, asdetailed in the MRA Framework, and will need to submit evidentiary documentation via the VCMI Claims Reporting
Platform. The VCMI Claims Reporting Platform and user guide can be accessed here.

The VCMI Monitoring, Reporting and Assurance (MRA) Framework sets out what, when, how andwhere companies should submit information to demonstrate adherence to VCMI requirements inorder to make a VCMI Claim.

33

VCMI—Claims Code of PracticeReferences
SectionReferences

Step 1 Foundational
Criterion 1

1. GHG protocol. (2022). Land Sector and Removals Guidance. Available at https://
ghgprotocol.org/land-sector-and-removals-guidance. Accessed November 2023
2. GHG protocol. (2015). Scope 2 Guidance. Available at https://ghgprotocol.org/sites/
default/files/2023-03/Scope%202%20Guidance.pdf. Accessed November 2023
3. GHG protocol. (2015). Corporate Accounting and Reporting Standard. Available athttps://ghgprotocol.org/sites/default/files/standards/ghg-protocol-revised.pdf.
Accessed November 2023
4. GHG protocol. (2011). Corporate Value Chain (Scope 3) Accounting and ReportingStandard. Available at https://ghgprotocol.org/sites/default/files/standards/
Corporate-Value-Chain-Accounting-Reporing-Standard_041613_2.pdf. Accessed
November 2023

Step 1 Foundational
Criterion 2

5. Science Based Targets initiative. (2023). SBTi Criteria and recommendations fornear-term targets. Available at https://sciencebasedtargets.org/resources/files/
SBTi-criteria.pdf. Accessed November 2023
6. High Level Expert Group on the Net Zero Emissions Commitments of Non-State
Entities. (2022). Integrity matters: Net zero commitments by businesses, financial
institutions, cities and regions. Available at https://www.un.org/sites/un2.un.org/
files/high-level_expert_group_n7b.pdf. Accessed November 2023
7. Race to Zero. (2022). Starting Line and Leadership Practice 3.0. Available athttps://climatechampions.unfccc.int/wp-content/uploads/2022/06/Race-toZero-Criteria-3.0-4.pdf. Accessed November 2023

Step 1 Foundational
Criterion 3

8. UK Transition Plan Taskforce. (2023). TPT Disclosure Framework. Available athttps://transitiontaskforce.net/wp-content/uploads/2023/10/TPT_Disclosureframework-2023.pdf. Accessed November 2023
9. Glasgow Financial Alliance for Net Zero. (2022). Recommendations and Guidanceon Financial Institution Net Zero Transition Plans. Available at https://assets.
bbhub.io/company/sites/63/2022/09/Recommendations-and-Guidance-onFinancial-Institution-Net-zero-Transition-Plans-November-2022.pdf. Accessed
November 2023
10. Task Force on Climate-related Financial Disclosures. (2021). Guidance on
Metrics and Targets, and Transition Plans. Available at https://assets.bbhub.io/
company/sites/60/2021/07/2021-Metrics_Targets_Guidance-1.pdf. Accessed
November 2023
11. International Financial Reporting Standards Foundation. (2023). IFRS
Sustainability Disclosure Standard: Climate-related Disclosures. Available
at https://www.ifrs.org/content/dam/ifrs/publications/pdf-standards-issb/
english/2023/issued/part-a/issb-2023-a-ifrs-s2-climate-related-disclosures.
pdf?bypass=on. Accessed November 2023

34

VCMI—Claims Code of PracticeSection

References

Step 1 Foundational
Criterion 4

12. Global Standard on Responsible Corporate Lobbying. (2022). Available at https://climate-lobbying.com/. Accessed November 2023

Step3

13. Integrity Council for the Voluntary Carbon Market. (2023). The Core Carbon
Principles. Available at https://icvcm.org/the-core-carbon-principles/. Accessed
November 2023
14. International Civil Aviation Organization. (2019). CORSIA Emissions Units.
Available at https://www.icao.int/environmental-protection/CORSIA/Pages/
CORSIA-Emissions-Units.aspx. Accessed November 2023
15. Intergovernmental Panel on Climate Change. (2022). Climate Change 2022:
Mitigation of Climate Change - Summary for Policymakers. Available athttps://www.ipcc.ch/report/ar6/wg3/downloads/report/IPCC_AR6_WGIII_
SummaryForPolicymakers.pdf. Accessed November 2023

Step 4

16. International Standard on Assurance Engagements. (2020). International
Standard on Assurance Engagements (ISAE) 3000 (Revised). Available at https://www.frc.org.uk/getattachment/2dc92f3e-df64-47d8-a9de-0292795fc8c3/ISAE(UK)-3000-Jul-2020.pdf. Accessed November 2023
17. American Institute of Certified Public Accountants. (2021). Audit, Attest andQuality Control Standards. Available at https://www.aicpa-cima.com/resources/
landing/audit-attest-and-quality-control-standards. Accessed November 2023
18. International Organization for Standardization. (2023). ISO homepage. https://www.iso.org/home.html. Accessed November 2023

Where the Claims Code of Practice and/or its accompanying documents rely on guidance, standards, codes andother third-party documents, these are only non-exhaustive examples of such third-party documents and neither
VCMI nor other individuals and organizations who contributed to the Code and/or its accompanying documents
assume responsibility for the accuracy of the information or processes outlined in such third-party documents,
and any consequences or damages, legal or otherwise, resulting directly or indirectly from any use of, or as aresult of relying on, these third-party documents or their contents, or otherwise arising in connection therewith.
Organizations are recommended to consult the primary sources of all guidance, standards, codes and other thirdparty documents referred to in the Code and its accompanying documents, make an independent evaluation of
their credibility and take independent legal advice on their intended use in all relevant jurisdictions.

35

VCMI—Claims Code of PracticeGlossary36

VCMI—Claims Code of Practice

37

Term

Definition

Article 6

A section of the Paris Agreement, under the UN Framework Convention on Climate
Change, which consists of nine paragraphs providing principles for how countries can“pursue voluntary cooperation”, including through international carbon markets, toreach their climate targets, as well as additional context to support its implementation.

Assurance

An engagement in which a practitioner seeks sufficient appropriate evidence toexpress a conclusion designed to enhance the degree of confidence of the intended
users other than the responsible party about the subject matter information provided(ISAE 3000, 2000).

Beyond value chain
mitigation (BVCM)

Mitigation action or investment that takes place outside of an organization’s value
chain. This includes activities that avoid or reduce GHG emissions, and those thatremove and store GHGs from the atmosphere. The purchase of high-quality carbon
credits beyond a company’s value chain is an example of BVCM (SBTi, 2023).

Carbon credit

A tradeable unit issued by a carbon crediting program/standard that represents averified reduction or removal of GHGs from the atmosphere equivalent to one metrictonne of CO2e. Carbon credits are uniquely serialized, issued, tracked, and cancelled
or retired by means of an electronic registry.

Carbon Offsetting
and Reduction
Scheme forInternational
Aviation (CORSIA)

A global market-based mechanism, adopted by the International Civil Aviation
Organization (ICAO) in 2016, to address CO2 emissions from international aviation.
CORSIA is the first global market-based measure for an individual sector. It
pursues a cooperative approach, involving governments, industry, and internationalorganizations, that attempts to replace a patchwork of national or regional regulatory
initiatives. CORSIA aims to stabilize, from 2021, international civil aviation CO2emissions at 2019 levels, including through the use of carbon credits that are
determined by ICAO to meet the CORSIA Emissions Units Eligibility Criteria. (Foradditional information, see ICAO, 2021).

Claim

A message used to describe or promote a product, process, business, or service withrespect to its sustainability attributes or credentials (ISEAL, 2015).

Corresponding
adjustment

An accounting rule under the Paris Agreement’s Article 6 to ensure that, when acountry authorizes and first transfers a mitigation outcome, emissions reductions or
removals are not counted by the country that agreed to transfer it (WRI, 2019).

Decarbonization

The measures through which an entity reduces or avoids its GHG emissions.

Double counting

A situation in which a single greenhouse gas emission reduction or removal is counted
by more than one Party toward achieving its Nationally Determined Contribution.

Free Prior andInformed Consent(FPIC)

Consent for any project, plan, or action given in advance and independently decided
upon, based on accurate, timely, and sufficient information provided in a culturally
appropriate way.

Greenhouse Gas
ProtocolThe Greenhouse Gas Protocol provides a comprehensive global standardized
framework to measure and manage GHG emissions from private and public sector
operations, value chains, and mitigation actions. Building on a 20-year partnership
between the World Resources Institute (WRI) and the World Business Council for
Sustainable Development, the GHG Protocol enables consistent and robust GHG
accounting across entities. (For additional information, see GHG Protocol).

VCMI—Claims Code of Practice

38

Term

Definition

Integrity Council
for the Voluntary
Carbon Market(ICVCM)An independent governance body that is developing and enforcing a set of Core
Carbon Principles (CCPs) that establishes a new threshold standard for high-quality
carbon credits in the voluntary carbon market. The ICVCM will oversee a process todetermine the Eligibility of carbon-crediting programs as well as which carbon credit
Categories will become CCP-Approved. (For additional information, see ICVCM, 2023).

Leakage

When a carbon crediting project or program does not halt emission-generating
activities, but instead displaces them outside the project or program boundary.

Long-term net-zerotargetA company commitment to reduce emissions across its value chain (scopes 1, 2
and 3) to zero, or to a residual level aligned with global net-zero, no later than midcentury. All residual emissions are balanced out by permanent removals (including
high-quality removal carbon credits).

Mitigation
contribution

Credits that are not authorized for transfer to be used against the NDC of anothercountry, or for other international mitigation purposes, i.e., a credit generated throughArticle 6.4 to which a host country will not apply a corresponding adjustment.

Mitigation hierarchy

Prioritized steps to limit negative impacts, as much as possible, through mitigation(or reduction), restoration, and beyond value chain mitigation (WWF, 2020).

Mitigation outcome

An ex-post emission reduction or removal of GHGs determined by quantifying abaseline for emissions within a given boundary and then measuring how mucha given intervention avoids, reduces, or removes and sequesters carbon fromthe atmosphere. A mitigation outcome can then be unitized and, in some cases,
serialized for it to be traded as a carbon credit.

Most recent
reporting year

The year related to an entity’s most recent financial reporting year.

Nationallydetermined
contributions(NDCs)The national climate plan put forward by a Party to the Paris Agreement, including
climate-related targets, policies and measures the government aims to implement
in response to climate change and as a contribution to global climate action(UNFCCC, 2015).

Negative emissions

The emissions level beyond net-zero where removals exceed emissions.

net-zeroNet-zero emissions are achieved when anthropogenic GHG emissions in theatmosphere are balanced globally by anthropogenic removals over a specified period(as defined by the IPCC’s AR6 report and adopted by VCMI).

Permanence

The capacity of reduced, avoided, or removed emissions to not re-enter theatmosphere. In practical terms, this means giving the purchaser of a carbon credit
confidence that declared emission reductions will not be reversed by a future event(for example, that the forest planted to absorb a certain amount of emissions will not
be cut down or be set on fire) (WRI, 2010).

Remaining
emissions

Emissions that remain in a given year as a company progresses towards the delivery of
its near- and long-term targets (SBTi, 2023).

VCMI—Claims Code of Practice

39

Term

Definition

Removals (a.k.a.
carbon dioxide
removals)

Anthropogenic activities removing CO2 from the atmosphere and durably storing it in
its geological, terrestrial or ocean reservoirs, or in products (IPCC, 2018).

Residual emissions

Represent the emissions that cannot be completely eliminated or reduced to zerodespite implementing all available mitigation measures contemplated in pathways
that limit warming to 1.5 degrees Celcius with no or limited overshoot (SBTi, 2023).

Retirement ofcarbon credits

The transfer to a retirement account or the cancellation of a carbon credit. Once
retired, the credit is considered ‘used’ and cannot be counted again toward a
climate target. The owner of the retired credit can accurately claim to have reduced
emissions and use those emissions to meet its climate commitments.

Science Based
Target initiative(SBTi)

An initiative that mobilizes companies to set emission reduction targets based on
climate science. A collaboration between CDP, the UN Global Compact, the WRI, andWWF, the SBTi defines and promotes best practice in science-based target setting,offers resources and guidance to reduce barriers to adoption, and independently
assesses and approves companies’ targets. Adopting an SBTi-approved target isone of the We Mean Business Coalition commitments (For additional information,see SBTi, 2023).

Science-based/aligned target

A target that is in line with the latest climate science consensus on safe upper
limits for global warming. Alignment with an IPCC model pathway of CO2 emission
reductions that limits global warming to 1.5 degrees Celsius with no or limited
overshoot is the ultimate objective (SBTi, 2023). ‘Science-based’ is used whenadhering to SBTi’s standards, while ‘science-aligned’ may not necessarily follow
SBTi’s standards.

Scopes 1, 2, and 3
emissions

Scope 1 emissions are emissions from operations that are owned or controlled
by the reporting company. Scope 2 emissions are emissions from the generationof purchased or acquired electricity, steam, heating or cooling consumed by thereporting company. Scope 3 emissions are all indirect emissions (not included inscope 2) that occur in the value chain of the reporting company, including both
upstream and downstream emissions.

Value chain
emissions

Emissions from the upstream and downstream activities associated with theoperations of the reporting company. Scope 3 emissions include all indirectemissions (not included in scope 2) that occur in the value chain of the reporting
company, including both upstream and downstream emissions (GHG Protocol, 2011).

VintageIn relation to carbon credits, the year in which the emission reduction or removal
took place. The verification process can take two to three years from project
inception, so projects may generate credits for already-reduced emissions (Foradditional information, see Gold Standard, 2023).

Voluntary carbon
marketA marketplace that encompasses transactions of carbon credits that are notpurchased with the intention to surrender into an active regulated carbon market. It
includes carbon markets purchased with the intent to resell or retire to meet carbon
neutral or other environmental claims.

VCMI—Claims Code of PracticeAcknowledgements

40

VCMI—Claims Code of PracticeAcknowledgments
Developing the VCMI Claims Code of Practice over the last months has required the dedicated efforts of a large
number of people, many of whom generously donated their time and expertise. We wish to express our sincere
gratitude to:
The Steering Committee, co-chaired by Rachel Kyte and Tariye Gbadegesin, and comprised of Manuel Pulgar
Vidal, Usha Rao-Monari, Pedro Moura Costa, Zita Schellekens, Sonia Medina, Akim Daouda and Anirban Ghosh.
All those who participated in the public consultation and corporate road test of the provisional Claims Code. The
responses were thoughtful, rich, and varied, and have directly informed updates and amendments to the Claims
Code. We are also extremely grateful to Boston Consulting Group for its sterling work in guiding companies
through the road test, and to both Boston Consulting Group and Climate Focus for their support in synthesizing
the feedback received.
The Expert Advisory Group (EAG), which includes nearly 20 global experts with gender balance and from different
geographies, for giving so much of their time and expertise to the development of the Code.
Participants in VCMI’s Country Contact Group, whose knowledge and experience in carbon markets and climate
finance continues to provide valuable insights and perspectives to help shape VCMI outputs and objectives.
Stakeholder Forum members for having acted as a market sounding board, highlighting priority issues to beclarified and improved and providing us with a clear sense of how guidance developed was being perceived.
Early Adopter companies that followed up closely on the development of additional guidance and paving the way forcompanies to confidently make Carbon Integrity Claims and celebrate credible climate action at COP28 and beyond.
Our close partners in the United Nations Development Programme (UNDP) and the UK Department for Energy
Security and Net-Zero (DESNZ) for their invaluable outreach and diplomacy, and to regional alliances such as
the Africa Carbon Markets Initiative for their collaboration in accelerating the implementation of high-integrity
voluntary carbon markets where they are needed most.
All of our NGO partners, including, but not limited to: SBTi, We Mean Business, CDP, GHGP and ICVCM, as well as
the business groups that we are engaged with and the support received from Bloomberg BNEF.
Our creative and design team at Regency; Clyde&Co for its support of the legal analysis; ISEAL for its guidanceon system development for improving claims and assurance systems as well as on the stakeholder engagement
process; Baker Tilly for having led the development of the MRA Framework; Deloitte for providing us with valuablecomments and suggestions on the MRA Framework; Ramboll for the valuable work to refine strategy andgovernance indicators; MSCI Carbon Markets (formerly Trove Research) for the crucial analysis on assessing thebenefits and risks of companies using carbon credits in the near-term when an emissions gap is identified; The
Climate Board, for the valuable survey conducted with companies; Carbon 4412 for contributing with analysis tofurther refine finance contribution indicators; 73bit for developing the VCMI Claim Reporting Framework thatwill enable companies to make a Carbon Integrity Claim; and Winrock, for embarking on this journey since thebeginning, being part of the team and for putting in so much effort and dedication to make it successful.
Rockefeller Philanthropy Advisors, Meridian Institute and the Secretariat team.
And, of course, our past and current funders, Children’s Investment Fund Foundation, Ballmer Group, Bezos EarthFund, Packard Foundation, Google LLC, and UK BEIS, for allowing for this vital initiative to be possible.
On behalf of the Secretariat and with heartfelt appreciation,

Mark Kenber
EXECUTIVE DIRECTOR, VCMI

41

VCMI—Claims Code of PracticeHow toaccessadditional
information
For further information on the
VCMI Claims Code of Practice andother VCMI publications, please
visit www.vcmintegrity.org.
Email: info@vcmintegrity.org
For updates and news from VCMI
about the Claims Code and relevant
events or activities, visit our news page(www.vcmintegrity.org/latest-news)
or register to receive our newsletter(www.vcmintegrity.org/newsletter).
You can also find VCMI on Twitterand LinkedIn (@wearevcmi).
If you have specific questions about
the VCMI Claims Code of Practice,or to directly get in touch with VCMI,
please contact info@vcmintegrity.org.

42

The Voluntary Carbon Markets
Integrity Initiative is an international
initiative to drive credible, net-zeroaligned participation in voluntarycarbon markets.

vcmintegrity.org