COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Roadmap towards Nature Credits
Date: 2025-07-07
Institutions: Directorate-General for Environment, European Commission
Subjects: EU action, EU environmental policy, biodiversity, economic instrument for the environment, ecosystem, environmental cooperation, environmental protection, private investment, public investment, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 7.7.2025  COM(2025) 374 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Roadmap towards Nature Credits  
 
 
Introduction 

Nature  is  our  strongest  ally  to  support  our  livelihoods,  health  and  prosperity.  It  provides 
essential ecosystem services such as retaining water, ensuring soil fertility and pollination. It 
contributes to climate mitigation, adaptation and resilience against disasters, often in a very 
cost-effective  manner.  For  companies,  it  contributes  to  determining  production  processes, 
credit  worthiness,  and  access  to  financing.  This  also  affects  the  risks  for  the  financial 
institutions that grant loans to these companies, which is why financial supervisors show an 
increasing interest in nature-related risks1.  

Nature is therefore a crucial foundation for a competitive and resilient economy. The people 
who are at the front lines of nature stewardship, such as farmers, foresters, landowners and land 
managers, fishers, users of sea and freshwater ecosystems, conservation area managers, and 
local communities, must be appropriately rewarded, through the marketplace, for contributing 
to safeguarding and improving the strategic economic asset that nature is. 

In the finance toolbox for biodiversity and nature, certification and credits2 are emerging as a 
potentially  valuable  way  to  complement  public  funding.  By  facilitating  investments  in 
activities that benefit nature, these innovative and voluntary tools can play a crucial additional 
role in preserving the health of our land and marine ecosystems and help reverse the decline in 
biodiversity. With  a  view  to  strengthening  the  bioeconomy,  these  tools  can  also  provide  an 
opportunity  to  generate  income  to  the  people  involved  in  the  protection,  restoration,  and 
sustainable management of ecosystems, as highlighted in the Vision for Agriculture and Food3, 
the Water Resilience Strategy4, and the European Ocean Pact5, while ensuring food security 
and the multifunctionality of forests. 

This  roadmap  sets  out  a  path  to  achieving  these  goals. The  aim  is  to  complement  different 
sources  of  nature  finance  such  as  public  funding  by  supporting  the  development  of  high-
integrity tools – nature credits – that will turn investment in nature into a reliable engine of 
value creation.  

1.  The economic and business case for nature-positive action 

1.1. Public investment in nature for our society and economy 

Nature is not only valuable for its own sake but also essential to address the interlinked crises 
of climate change, biodiversity loss and pollution. More than half of global GDP and two thirds 
of the EU’s added economic value depend on nature and its ecosystem services6. Around 72% 

1  European  Central  Bank, 

'Nature's 

bell 

tolls 

for 

thee, 

economy!', 

Speech, 

22  May 

2025. 

https://www.ecb.europa.eu/press/key/date/2025/html/ecb.sp250522~b371549cb6.en.html. 

2  Biodiversity is understood to be ‘the variability among living organisms from all sources including, inter alia, terrestrial, 
marine and other aquatic ecosystems and the ecological complexes of which they are part; this includes diversity within 
species, between species and of ecosystems’ (Article 2, Convention on Biological Diversity). Similarly to the Conceptual 
Framework of the International Panel on Biodiversity and Ecosystem Services (IPBES), ‘nature’ is a broader concept that 
encompasses the natural world, including biodiversity and its interactions with their environment.  

        The use of ‘certification’ and ‘credits’ is explained in Section 2. 
3  A  Vision  for  Agriculture  and  Food  Shaping  together  an  attractive  farming  and  agri-food  sector  for  future 

generations; COM/2025/75 final. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025DC0075  

4  European Water Resilience strategy; COM(2025) 280 final. https://circabc.europa.eu/ui/group/1c566741-ee2f-41e7-a915-

7bd88bae7c03/library/b560bc22-6a61-4b63-b62b-a7fe890ea177/details  

5 

The 

European 

Ocean 

Pact: 

COM(2025)281 

final. 

https://eur-lex.europa.eu/legal-

content/EN/ALL/?uri=comnat:COM_2025_0281_FIN  

6    World Economic Forum, 'Nature Risk Rising: Why the Crisis Engulfing Nature Matters for Business and the Economy', 19 
January  2020.  https://www.weforum.org/publications/nature-risk-rising-why-the-crisis-engulfing-nature-matters-for-
business-and-the-economy/.  

     Joint  Research  Centre, 

'The  EU  economy’s  dependency  on  nature',  JRC  140003,  28  February  2025. 

https://publications.jrc.ec.europa.eu/repository/handle/JRC140003 

1 

 
 
of euro area companies are critically dependent on ecosystem services, including those located 
outside the EU, notably in developing and emerging markets, reflecting the globalised nature 
of supply chains and economic interdependence. The loss of nature on land and at sea is now 
understood to be a major driver of economic losses and financial risks7. Investing in nature 
restoration is therefore crucial for Europe’s competitiveness, resilience, prosperity and security. 

However, despite pioneering work such as the EU integrated system of ecosystem accounts, 
which has estimated that ten ecosystem services generated EUR 234 billion benefits annually8, 
ecosystem services remain difficult to monetise and are not adequately reflected in market price 
signals. This contributes to over-exploitation and chronic underinvestment in nature restoration 
and protection.  

As  a  result,  nature  restoration  and  protection  mainly  rely  on  public  funding.  The  EU  has 
committed to dedicating 10% of its budget to supporting actions and investments that address 
biodiversity protection and restoration in 2026 and 2027 through several finance schemes and 
interventions9 and to double funding for external biodiversity action to EUR 7 billion for 2021-
2027.  This  is  in  line  with  the  Kunming-Montreal  Global  Biodiversity  Framework  (GBF)10 
under the Convention on Biological Diversity (CBD), which calls for substantially increasing 
financial  flows  from  all  sources,  mobilising  at  least  USD 200  billion  per  year  by  2030, 
including through innovative finance (Target 19). 

While such commitments represent important progress, they remain far from sufficient. The 
GBF highlights the scale of the challenge, estimating  a global biodiversity financing gap of 
USD 700 billion per year, a gap that cannot be bridged by public funding  alone. At the EU 
level, current public funding, whether from EU, national or local sources, is also insufficient 
to meet the investments needs, which are estimated at EUR 65 billion annually11. Continued 
and  significant  levels  of  public  funding  remain  essential,  including  EU  and  national 
contributions, in line with State aid rules12, but a combination of public and private finance is 
crucial to achieve the necessary scale and speed.  

7   Ceglar, A., Parker, M., Pasqua, C., Boldrini, S., Gabet, M., et al., Economic and financial impacts of nature degradation and 
2024. 

biodiversity 
https://www.ecb.europa.eu/press/economic-bulletin/articles/2024/html/ecb.ebart202406_02~ae87ac450e.en.html. 
8    These  ecosystem  services  are  crop  provision,  timber  provision,  pollination,  carbon  sequestration,  flood  control,  water 

Economic 

European 

Bulletin, 

Central 

(ECB) 

Bank 

Issue 

loss. 

6, 

purification, nature recreation, water provision, air filtration, marine fish capture.  

     European Commission: Eurostat, Vysna, V., Maes, J., Petersen, J.-E., La Notte, A. et al., Accounting – for ecosystems and 
their services in the European Union (INCA) – Final report from phase II of the INCA project aiming to develop a pilot 
for  an  integrated  system  of  ecosystem  accounts  for  the  EU  –  2021.  edition,  Publications  Office,  2020. 
https://data.europa.eu/doi/10.2785/197909. 

     La Notte, A., Grammatikopoulou, I., Zurbaran-Nucci, M., Marques, A., Ferrini, S. et al., Linking accounts for ecosystem 
services and benefits to the economy through bridging (LISBETH). Part II, How to use ecosystem services accounting to 
provide the financial sector with a more robust, systematic and consistent environmental metric, Publications Office of 
the European Union, 2022. https://data.europa.eu/doi/10.2760/010621. 

9   Over 2021-2027, contribution for biodiversity were estimated around EUR 64 billion from common agricultural policy, 
EUR  16  billion  from  cohesion  policies,  EUR  7  billion  from  Horizon  Europe:  European  Commission,  'Biodiversity 
mainstreaming', 
https://commission.europa.eu/strategy-and-policy/eu-
budget/performance-and-reporting/horizontal-priorities/green-budgeting/biodiversity-mainstreaming_en 

Commission 

European 

website. 

10   Kunming-Montreal Global Biodiversity Framework: Decision Adopted by the Conference of the Parties to the Convention 

on Biological Diversity: CBD/COP/DEC/15/4. https://www.cbd.int/gbf 

11   Environmental Implementation Review 2025 (forthcoming). 
12  European  Commission,  DG  Competition,  ‘State  aid  Legislation’.  https://competition-policy.ec.europa.eu/state-

aid/legislation_en. 

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1.2. The role of private finance for nature 

Alongside  public-sector  investment,  there  is  a  growing  business  case  for  private-sector 
engagement  in  nature,  particularly  through  nature-positive  action13  –  actions  that  halt  and 
reverse  nature  loss,  including  improving  and  maintaining  biodiversity.  For  businesses, 
recognising nature as a strategic asset can enable new approaches to manage risk, create value 
and  build  economic  resilience.  Integrating  biodiversity  considerations  into  business  models 
helps  reduce  reputational  and  operational  risks  such  as  pollinator  decline  affecting  crop 
yields14, or land degradation causing supply chain interruptions due to ecosystem collapse15. It 
also  helps  enhance  product  distinctiveness  and  potentially  unlock  new  revenue  streams. 
Examples  in  the  EU  include  agrifood  companies  supporting  farmers  in  transitioning  to 
regenerative  agriculture16  or  blended  finance  models  supporting  aquaculture  for  restoring 
marine biodiversity17.  

Companies that adopt nature-positive strategies can benefit from higher investor confidence, 
better financial conditions and greater long-term resilience18. Some financial institutions are 
also  starting  to  recognise  this  value  and  increasingly  integrate  biodiversity  into  risk 
assessments,  as  reflected  in  premiums,  lending  criteria  and  investment  decisions19.  For 
example,  insurers  create  nature-aligned  insurance  products  linked  to  green  investments  or 
invest in projects to restore ecosystems to reduce the insurance risk related to flooding20. By 
creating such value, companies therefore benefit not only stakeholders including employees, 
customers,  suppliers,  local  communities  and  society  at  large,  but  also  their  shareholders21. 
Disclosure  frameworks  under  the  Corporate  Sustainability  Reporting  Directive22,  the 

13  https://www.naturepositive.org/what-is-nature-positive/. See also Lammerant J. & Verhelst J., Nature positive in a business 
context: current working definition, Thematic Report on behalf of the EU Business @ Biodiversity Platform, December 
2022.  Available  https://green-forum.ec.europa.eu/news/how-positive-will-nature-positive-be-eu-bb-platform-thematic-
report-provides-meaningful-insights-2022-12-16_en.  

     And see Nature Positive Initiative: https://www.naturepositive.org/what-is-nature-positive/. 
14 Turo, K.J., Reilly, J.R., Fijen, T.P.M., Magrach, A., Winfree, R.  (2024) ‘Insufficient pollinator visitation often limits yield 
1612–1622.  Available 

systems  worldwide’,  Nature  Ecology  &  Evolution, 

8(9), 

pp. 

crop 

in 
https://www.nature.com/articles/s41559-024-02460-2. 

15 Marsden,  L.,  Ryan-Collins,  J., Abrams,  J.,  and  Lenton,  T.  (2024). Ecosystem  tipping  points:  Understanding  risks  to  the 
economy  and  financial  system.  UCL  Institute  for  Innovation  and  Public  Purpose,  Policy  Report  2024/03.  Available 
https://www.ucl.ac.uk/bartlett/public-purpose/2024/apr/ecosystem-tipping-points.   

16 Manshanden, M., Jellema, A., Sukkel, W., Hennen, W. H. G. J., Jongeneel, R, et al.  (2023) Regenerative agriculture in 
Europe:  An  overview  paper  on  the  state  of  knowledge  and  innovation  in  Europe.  Wageningen  Economic  Research. 
https://doi.org/10.18174/629483.  

    Borgman,  E.,  Fischer  Bogason,  R.,  Engelbrecht  Hansen,  A.,  Møller  Nielsen,  A.,  Bennun,  L.  (2023)  Biodiversity  and      

financing: Review of tools in the Nordic countries. 
https://norden.diva-portal.org/smash/record.jsf?pid=diva2%3A1803819&dswid=5871. 

17 Global Seaweed Coalition and EIB, ‘Financing opportunities for EIB in support of sustainable seaweed and bivalve sectors 
in  the  EU,  and  criteria  to  ensure  their  sustainability’,  13  March  2025.  https://www.safeseaweedcoalition.org/europe-
seaweed-bivalve-report/.  

18  World Economic Forum (2024) Financing the Nature-Positive Transition: Understanding the Role of Banks, Investors and 
Insurers. CEO briefing. https://www3.weforum.org/docs/WEF_Financing_Nature-Positive_CEO_Briefing_2024.pdf 
19  Network for Greening the Financial System (NGFS), ‘Nature-related Financial Risks: a Conceptual Framework to guide 
Action  by  Central  Banks  and  Supervisors’.  7  September  2023.  https://www.ngfs.net/en/press-release/ngfs-publishes-
conceptual-framework-nature-related-financial-risks-launch-event-paris 

20  European Investment Bank, Hudson, G., Hart, S. and Verbeek, A., Investing in nature-based solutions – State-of-play and 
in  Europe,  European  Investment  Bank,  2023. 

way  forward  for  public  and  private  financial  measures 
https://data.europa.eu/doi/10.2867/031133 

21  World Economic Forum, 'Davos Manifesto 2020: The Universal Purpose of a Company in the Fourth Industrial Revolution', 
https://www.weforum.org/stories/2019/12/davos-manifesto-2020-the-universal-purpose-of-a-

2  December 
company-in-the-fourth-industrial-revolution/ 

2019. 

22  Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) 
No  537/2014,  Directive  2004/109/EC,  Directive  2006/43/EC  and  Directive  2013/34/EU,  as  regards  corporate 
sustainability reporting (OJ L 322, 16.12.2022). https://eur-lex.europa.eu/eli/dir/2022/2464/oj 

3 

 
 
Sustainable  Finance  Disclosure  Regulation23  and  the  EU  Taxonomy  Regulation24  can 
contribute to expanding this trend. 

Despite this clear potential, the nature-positive transition is not without its challenges. Upfront 
costs,  data  gaps,  and  difficulties  in  measuring  biodiversity  outcomes  can  delay  short-term 
returns and deter investment. Innovative instruments and enabling frameworks are necessary 
to overcome these barriers and scale up nature-positive economy25. 

2.  Nature credits 

2.1. From certification to credits 

Nature credits can be a key tool to reward nature-positive action through private investment to 
the  benefit  of  nature  and  businesses,  including  farmers,  foresters,  landowners  and  land 
managers,  fishers,  users  of  sea  and  freshwater  ecosystems,  conservation  area  managers  and 
local communities. 

By enabling these actors and stakeholders to demonstrate their nature-positive action beyond 
individual  legal  obligations  and  the  mandatory  mitigation  hierarchy26,  a  shift  from  limiting 
damage to actively reversing the trend of nature loss can be stimulated. At the policy level, 
Member States could for example use nature credits to recognise individual contributions to 
national targets and obligations under the Nature Restoration Regulation27, or under the GBF. 
These tools could also support related uses, such as sustainable disclosures, green infrastructure 
financing or result-based payments. To ensure credibility of the process, strict criteria will need 
to be considered, underpinned by clear governance, transparency and safeguards. 

Certification  provides  assurance  that  specific  high-quality,  nature-positive  actions  are 
implemented in line with pre-defined criteria or principles. Such certification would assess the 
design,  the  implementation,  the  effects  achieved  and  those  still  expected,  providing  a 
recognised  signal  of  environmental  integrity  based  on  the  quality  of  the  intervention. As  a 
formal  recognition,  independently  verified,  that  the  intervention  meets  agreed  standards  for 
biodiversity relevance and good practices, the certificate can help reduce risks for funders and 
build early confidence. It may also support upfront investment and enable operators to access 
payments for certified actions. 

On that basis, a nature  credit could be considered as a unit that represents a nature-positive 
outcome,  derived  from  a  certified  and  independently  verified  action  and  quantified  using  a 
recognised biodiversity metric or indicator. These metrics and indicators can be multiple and 
adapted to context, reflecting the heterogeneity of ecosystems and outcomes. Frameworks such 

23  Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related 

disclosures in the financial services sector (OJ L 317, 9.12.2019). https://eur-lex.europa.eu/eli/reg/2019/2088/oj. 

24   Regulation  (EU)  2020/852  of  the  European  Parliament  and  of  the  Council  of  18  June  2020  on  the  establishment  of  a 
framework  to  facilitate  sustainable  investment,  and  amending  Regulation  (EU)  2019/2088  (OJ  L  198,  22.6.2020). 
https://eur-lex.europa.eu/eli/reg/2020/852/oj 

25  See  for  example,  the  NetworkNature's  'Task  Force  on  Finance  and  Business  Models  (for  NbS)  in  a  Nature-Positive 

Economy'. More information available at this link. 

26 The EU’s mitigation hierarchy, legally enshrined in the Birds and Habitats Directives (Directive 2009/147/EC and Council 
Directive 92/43/EEC) but also in the  EU guidance on integrating ecosystems and their services into decision-making, 
requires developers to avoid, minimise and only as a last resort compensate for residual effects. 

27  Regulation  (EU)  2024/1991  of  the  European  Parliament  and  of  the  Council  of  24  June  2024  on  nature  restoration  and 
amending Regulation (EU) 2022/869. (OJ L, 2024/1991, 29.7.2024). https://eur-lex.europa.eu/eli/reg/2024/1991/oj/eng 

4 

 
 
as the EU's Mapping and Assessment of Ecosystems and their Services28 and the UN System 
of  Environmental-Economic Accounting  –  Ecosystem Accounting29  offer  examples  of  how 
flexibility  across  ecosystems  can  be  combined  with  a  coherent,  standardised,  science-based 
structure of ecosystem-specific indicators and metrics. 

This two-step model – certification followed by crediting – could open the door to innovative 
financing mechanisms. Certificates help structure and catalyse nature-positive investment by 
providing the basis for contractual payments or guarantees, while credits could monetise the 
demonstrated impact, potentially offering dividends to suppliers and early investors. The role 
of certification is to structure interventions and ensure quality control, while credits translate 
observed,  verified  improvements  into  a  unit  that  may  be  registered,  pooled,  banked  and 
transacted. The process may include a mechanism to update the status of interventions over 
time in the certificate, facilitating transparency, adaptive management, and, where appropriate, 
the progressive issuance of credits based on validated milestones. 

For example, a group of farmers and land managers working together to enhance a wetland 
ecosystem may implement a series of practices. A recognised independent certifier assesses the 
project  plan, the methods  used and its intended  effects.  Based on this, the group receives a 
certificate,  a  formal  recognition  that  their  activity  meets  high-quality  standards  for  nature-
positive action. This certificate helps them attract financial support and build stakeholder trust 
to value their practices. Over time, the project is monitored and nature credits are progressively 
issued as results are demonstrated. The issuance must follow strict scientific and governance 
protocols  to  maintain  integrity  and  avoid  premature  claims.  The  nature  credit  value  chain 
includes  intermediaries  (such  as  aggregators  or  landscape-level  facilitators),  certifiers, 
registries,  and  buyers.  Buyers  may  include  companies  in  downstream  sectors  (e.g.  agrifood 
companies),  financial  institutions,  public  entities,  or  citizens,  particularly  in  the  context  of 
voluntary contributions, public procurement, or local benefit-sharing schemes. 

2.2. Building trust and integrity  

To ensure the credibility of the process, strict criteria and principles need to be established to 
ensure transparency, avoid conflicts of interest and safeguard against greenwashing and double 
counting. The separation of roles between project developers, certifiers, and registry operators 
is essential to preserve the system’s integrity and market trust.  

For many companies, from utilities to insurers, investing in nature is not a new phenomenon. 
Several nature financing tools already exist such as green bonds and payments for ecosystem 
services. Alongside these,  nature credits  based on certificates  could  add value by offering a 
verifiable and standardised format for investing in nature-positive action. Properly designed, 
they can become a key tool to channel private investments and reward nature-positive action.  

Where  possible,  certification  should  build  and  align  with  existing  EU  standards  and 
frameworks, for  example  the organic farming scheme30, to  minimise administrative burden. 

28 Vallecillo, S., Maes, J., Teller, A., Babí Almenar, J., Barredo, J. I. et al., EU-wide methodology to map and assess ecosystem 
condition – Towards a common approach consistent with a global statistical standard, Publications Office of the European 
Union, 2022, https://data.europa.eu/doi/10.2760/13048 

     Maes, J., Bruzón, A.G., Barredo, J.I., Vallecillo S., Vogt, P., et al. Accounting for forest condition in Europe based on an 

international statistical standard. Nat Commun 14, 3723 (2023). https://doi.org/10.1038/s41467-023-39434-0 

29  United  Nations  System  of  Environmental  Economic  Accounting,  'Ecosystem  Accounting',  UN  SEEA  website, 

https://seea.un.org/ecosystem-accounting 

30  Regulation  (EU)  2018/848  of  the  European  Parliament  and  of  the  Council  of  30  May  2018  on  organic  production  and 
labelling of organic products and repealing Council Regulation (EC) No 834/2007 (OJ L 150, 14.6.2018).  https://eur-
lex.europa.eu/eli/reg/2018/848/oj/eng. 

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Rather  than  functioning  in  isolation,  nature  credits  should  therefore  be  integrated  into  this 
broader framework and emerge as a transformative instrument. 

2.3. Recent initiatives and the emergence of new markets 

Although they are still at an early stage of development the estimated potential of nature credits 
is significant. At the global level, development has evolved rapidly in recent years, with over 
50  reported  initiatives  of  certification  and  nature  credits31.  International  initiatives,  led  by 
expert coalitions like the Biodiversity Credits Alliance (BCA)32, the World Economic Forum 
(WEF)33 and the International Advisory Panel on Biodiversity Credits (IAPB)34, and voluntary 
nature disclosure frameworks such as the Taskforce on Nature-Related Financial Disclosures 
(TNFD)35 and the Science-Based Targets  Network  (SBTN)36, are  converging  around shared 
principles for credible, high-integrity systems such as additionality, attribution, measurability, 
permanence,  no  double  counting,  transparency,  social  and  environmental  safeguards, 
alignment with global goals and potential uses.  

At  the  same  time,  several  Member  States  and  non-EU  countries  are  piloting  biodiversity 
finance  models  that  blend  public  and  private  capital.  Within  the  EU,  France  has  adopted  a 
system  based  on  the  creation  of  natural  compensation,  restoration  and  renaturation  sites37, 
Ireland has designed a voluntary financial scheme for peatland restoration38 and Finland has 
recently  implemented  a  voluntary  system  to  support  national  biodiversity  efforts39.  In  other 
Member  States  –  including  Belgium,  Germany,  Italy,  the  Netherlands,  Portugal,  Spain, 
Slovakia  and  Sweden  –  non-governmental  bodies  such  as  civil  society  organisations,  land 
managers and financial bodies are actively piloting biodiversity and nature certification and 
credit schemes. Moreover, the United Kingdom has recently implemented its Biodiversity Net 
Gain policy40, a mandatory scheme for land managers and developers to restore ecosystems. 

While  nature credit markets are evolving globally, the EU is  well-positioned to  lead in  this 
field, thanks to its a comprehensive regulatory framework, that ensures consumer protection, 
corporate accountability, and transparency in nature-positive investments. 

3.  Learning from and building on experience with carbon markets 

Nature credits face many of the same challenges as other systems relying on certification, such 
as  those  for  organic  farming  or  energy  efficiency  that  share  the  goal  of  identifying  and 
rewarding beneficial environmental outcomes. When it comes to creating markets for nature 
credits, carbon markets can offer useful insights for designing high-integrity, resilient, inclusive 
and trusted systems. 

Recent developments on voluntary carbon markets highlight both challenges and opportunities. 
Concerns around integrity and the risk of greenwashing caused a contraction of these markets, 
while at the same time, buyers’ preference and demand for high-quality projects that include 

31  See  open-source  database  developed  by  BloomLabs.  Or  see:  Pollination  Group,  ‘State  of  voluntary  biodiversity  credit 
markets’, October 2023. https://pollinationgroup.com/global-perspectives/understanding-the-current-state-of-voluntary-
biodiversity-markets/ 

32 More information on the BCA: https://www.biodiversitycreditalliance.org/ 
33 More information on the WEF: https://initiatives.weforum.org/financing-for-nature/biodiversitycreditsinitiative 
34 More information on the IAPB: https://www.iapbiocredits.org/ 
35 More information on the TNFD: https://tnfd.global/ 
36 More information on the SBTN: https://sciencebasedtargetsnetwork.org/ 
37 See: https://www.ecologie.gouv.fr/politiques-publiques/sites-naturels-compensation-restauration-renaturation.  
38 More information on Peatland Finance Ireland: https://peatlandfinance.ie/. 
39  See: https://ym.fi/en/voluntary-nature-values-market  
40 See: https://www.legislation.gov.uk/ukpga/2021/30/schedule/14/enacted 

6 

 
 
environmental and social co-benefits has remained strong41. This underscores the importance 
of laying strong foundations for nature credit markets at an early stage, including on both the 
supply  and  demand  sides.  It  is  therefore  important  to  prioritise  ambitious  and  scientifically 
rigorous standards, independent monitoring, clear use and claim cases and reliable governance 
to prevent reputational risks. 

The  EU  Regulation  on  Carbon  Removals  and  Carbon  Farming  (CRCF)42  establishes  a 
voluntary certification system for carbon removals and ecosystem-based emission reductions 
achieved in the EU, built on robust monitoring, reporting and verification. It introduces the 
two-step process of  certificates of compliance and certified units which simplifies access to 
private finance and anchors the system on strict criteria for quantification, additionality, long-
term storage and sustainability. In particular, it requires carbon farming activities to generate 
co-benefits for biodiversity and ecosystem services. Other voluntary co-benefits can also be 
included,  setting  an  important  precedent  for  future  biodiversity-focused  frameworks.  This 
matches a growing market trend: buyers increasingly value robust credits that offer co-benefits, 
particularly  those  linked  to  nature-based  solutions.  Integrating  biodiversity  into  carbon 
certification could not only strengthen the ecological credibility of the certified units but also 
familiarise buyers with  biodiversity outcomes, potentially laying the groundwork for stand-
alone  nature  credit  markets.  CRCF  secondary  legislation  under  development  will  include 
provisions  for  independent  third-party  verification  and  science-based  tools  to  assess 
permanence and reversal risks, to help restore trust in certified and accredited performance. 

Valuable lessons can be drawn from carbon markets in order to facilitate initial progress, policy 
coherence and minimise administrative burden. At the same time, specific features of nature 
credits need to be taken into account, including metrics, purposes and safeguards, as well as 
site-specificity,  measurability  and  latency  of  biodiversity  outcomes.  Nature  credits  can  also 
cover a broader scope, as they can apply to interventions and areas non-linked or with limited 
additional  carbon  sequestration  potential  but  high  biodiversity  value,  such  as  supporting 
pollinators or restoring dry ecosystems.  

4.  Developing nature credits  

Since the start of this mandate, the Commission has consulted Member States and stakeholders 
to  advance  the  work  on  this  topic.  These  consultations  showed  a  clear  need  to  set  up  a 
collaborative process – both within the EU and internationally – that is built on high-integrity 
principles,  transparency  and  scientifically  robust  input.  Stakeholders  highlighted  the 
importance of rewarding not only new interventions but also ongoing nature conservation and 
the maintenance of good practices. They also emphasised the importance of considering the 
challenges related to local aspects of biodiversity and landownership, the lessons learned from 
the carbon market, accessibility for small-scale operators, market incentives and the need for 
coherence with existing policies.  

Drawing on this input, developing nature credits will require several steps: 

•  Setting up close cooperation among Member States and stakeholders to harness their 
expertise  to  develop  a  common  understanding,  while  also  fostering  international 
cooperation; 

41  Ecosystem  Marketplace,  ‘State  of  the  voluntary  carbon  market,  Renewing  trust  in  carbon  finance’,  28  May  2025. 

https://www.forest-trends.org/publications/2025-state-of-the-voluntary-carbon-market/. 

42 Regulation (EU) 2024/3012 of the European Parliament and of the Council of 27 November 2024 establishing a Union 
certification  framework  for  permanent  carbon  removals,  carbon  farming  and  carbon  storage  in  products.  (OJ  L, 
2024/3012, 6.12.2024). https://eur-lex.europa.eu/eli/reg/2024/3012/oj/eng 

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• 

 Developing  high-integrity  and  transparent  methodologies  with  a  clear  focus  on 
simplicity and usability, while ensuring credible governance and safeguards to prevent 
reputational risks, including greenwashing, double counting and leakage; 
Identifying and developing market demand and supply; 

• 
•  Where necessary, providing public seed funding, such as derisking facilities, blended 

finance vehicles and technical assistance grants, to kick-start nature credits. 

These first steps will show if further regulatory action at EU level would be necessary, as well 
as what challenges and opportunities this would bring for key sectors. The specific needs and 
often local or regional dimensions of nature and biodiversity also suggest that these markets 
could be piloted locally first, before scaling them up. This could go in parallel with engagement 
at international level.  

4.1. Ensuring  strong  EU  stakeholder  cooperation  and  enhancing  international 

cooperation 

The effectiveness of a market depends on the buy-in of its actors. EU action will therefore start 
with building meaningful engagement among stakeholders across the EU and internationally.  

The  kick-start  the  process,  the  Commission  will  therefore  launch  a  call  for  expression  of 
interest  to  participate  in  a  new  EU  expert  group  on  nature  credits.  This  group  will  share 
knowledge, promote collaboration, identify best practices and provide inputs across different 
methodologies, certification systems, monitoring approaches and models of governance. The 
governance  of  the  group  will  ensure  streamlined  working  methods.  Participation  will  be 
inclusive, covering individual experts, Member States representatives, other public entities and 
a  comprehensive  range  of  stakeholders,  such  as  farmers,  foresters,  landowners  and  land 
managers, fishers, users of sea and freshwater ecosystems, conservation area managers, local 
communities, businesses and investors operating in the EU and internationally, including small 
and medium-size enterprises (SMEs), scientific communities, and civil society organisations. 
Particular  attention  should  also  be  paid  to  ensuring  that  Indigenous  Peoples  and  local 
communities (IPLCs) are meaningfully included, with full respect for their rights, knowledge 
systems, and roles as stewards of biodiversity. 

Action  [2025]:  The  Commission  will  set  up  an  expert  group  on  nature  credits  to  mobilise 
expertise, share best practices and provide inputs.  

The  Commission  will  contribute  to  this  work  through  its  research,  innovation  and  pilot 
initiatives, including from Horizon Europe and the LIFE programme. A range of pilot projects 
across  the  EU  and  beyond  are  already  testing  real-world  approaches  to  nature  credits, 
generating essential experience to guide future policy and practice. For example, in Estonia 
and France, pilot projects are exploring how nature credits could support nature-positive action 
in  forest  and  in  wetlands.  Outside  the  EU,  a  project  in  Peru  is  assessing  how  EU-based 
companies can contribute to biodiversity conservation abroad while meeting EU sustainability 
reporting  standards43.  Dedicated  projects  to  test  monitoring,  reporting  and  verification 
methodologies are also ongoing, including as regards the use of remote sensing and geo-spatial 
tools, with the assistance of the European Space Agency44 and the Copernicus Services45. Some 

43 European Commission, DG Environment, ‘EU delivers on global financing commitments to protect nature at COP 16', news 
article,  European  Commission  website,  31  October  2024.  https://environment.ec.europa.eu/news/cop16-eu-delivers-
global-financing-commitments-protect-nature-2024-10-31_en 

44 More information on ‘Leveraging Earth Observation for Nature Finance’: https://www.leon-naturefinance.org/ 
45 More information on Copernicus Services: https://www.copernicus.eu/en/copernicus-services 

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of these projects are directly supported by the Commission, while others are backed by national 
authorities, research institutions and/or civil society.  

At the international level, the Commission will seek to work even more closely within key fora 
such  as  the  Biodiversity  Credit Alliance,  the  World  Economic  Forum  and  the  International 
Advisory Panel on Biodiversity Credits. The goal is to ensure that EU policy development is 
informed  by  emerging  global  standards,  while  also  helping  to  internationally  shape  the 
development  of  nature  credit  markets.  In  parallel,  the  EU  should  foster  international 
cooperation ahead of key global milestones, including the next CBD Conference of the Parties. 

Action [2025-2026]: The Commission will engage in international fora and with likeminded 
international partners, including in preparation for CBD COP 17. 

4.2. Developing robust methodologies and governance 

4.2.1.  Carbon farming methodologies with biodiversity co-benefits 

Following the entry into force of the first methodologies, planned for early 2026, the CRCF 
framework  will  enable  the  certification  of  carbon  farming  activities  with  biodiversity  co-
benefits,  such  as  peatland  rewetting,  planting  of  trees,  and  sustainable  agriculture  and 
agroforestry, ensuring that carbon sequestration projects also protect and restore biodiversity 
and ecosystems. 

Action  [2026]:  The  Commission  will  adopt  the  first  carbon  farming  methodologies  under 
CRCF with mandatory co-benefits on biodiversity. 

4.2.2.  Designing EU methodologies and governance frameworks for nature credits 

Criteria and methodologies for the certification of nature-positive action must ensure a high 
level  of  transparency,  supply-side  and  demand-side  integrity  and  prevent  risks,  while  being 
simple and practical and relying wherever possible on existing principles or standards.  

The  Commission  will  invite  the  expert  group  to  provide  expertise  on  criteria  and 
methodologies, by mapping and exchanging  on existing  national  and international  practices 
and identifying main options and key challenges associated to nature credits.  

Action [mid 2026]: The Commission will invite the expert group to provide its expertise on 
criteria and methodologies for nature credit markets. 

Robust governance frameworks are also essential for credible nature credit markets. They must 
clearly define the rules for ownership, registration, transfer of credits, independent verification, 
as well as the liabilities associated with non-performance or reversal of nature-positive action. 
Currently, the absence of a  widely  accepted framework for the measurement,  reporting  and 
verification of nature credits, combined with the lack of mutual recognition across Member 
States, creates uncertainty and risks undermining market integrity. 

In  designing  a  governance  framework,  several  aspects  must  be  taken  into  consideration  for 
productive  sectors  to  integrate  nature  into  their  business  models,  while  safeguarding  the 
multifunctional role of land, freshwater and marine ecosystems. Attention should be paid to 
simplicity, usability and synergies with other EU policies, as well as ownership rights including 
related to data. It is also important to address the specific needs of smallholders and SMEs, in 
line with the ‘think small first’ principle.  

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Action  [2027]:  The  Commission  will  invite  the  expert  group  to  provide  its  expertise  on 
designing  governance  frameworks  for  nature  credits,  with  particular  considerations  for 
smallholders and Small and Medium Sized Enterprises. 

4.3. Fostering readiness for nature credit markets 

In parallel to the work on criteria, methodologies and governance, further work will be needed 
to  identify  market  supply  and  demand  and  address  potential  obstacles  or  bottlenecks.  This 
requires  further market  and trend  evaluation, in  particular  on investment  drivers  and on  the 
capacity of actors, including smallholders, to generate supply and demand for nature credits. 

Existing  EU  policies  can  be  an  important  driver  in  this  process.  For  example,  the  Nature 
Restoration  Regulation  provides  a  strong  framework  for  ecosystem  restoration,  creating 
predictable demand signals for public and private investors. It is a cornerstone for generating 
nature-positive actions that can be recognised and verified. The potential of nature credits to 
finance nature restoration, in complement to public funding and other private financing, will 
be acknowledged in the upcoming Report on Nature Restoration Financing46. 

Action  [2025-2026]:  The  Commission  will  carry  out  an  EU-wide  evaluation  of  supply  and 
demand for nature credits. Thereafter, on this basis, the Commission will invite the expert group 
to provide inputs on how to foster nature credit markets.  

4.4. Public seed finance to kick-start nature credits 

Developing  robust  and  scalable  nature  credit  markets  may  be  further  supported  by  targeted 
public or public-private seed finance or by de-risking mechanisms to reward and scale up early 
biodiversity certification and nature credits initiatives that are essential to attract private capital. 
Without this upfront support, it is likely that high transaction costs, fragmented information 
and uncertainty around returns will continue to limit the scale-up of nature finance. Exploratory 
work is already underway with the InvestEU Advisory Hub of the European Investment Bank47, 
including  on  peatland  restoration,  and  with  Green Assist  under  the  LIFE  programme48,  to 
develop practical approaches to bridging supply and demand for nature credits. 

While certification offers the possibility for upfront remuneration, it still involves a cost for 
operators. In addition, setting up the governance system also involves a cost and administrative 
burden  for  the  private  and  public  sectors,  though  the  cost  is  expected  to  be  covered  by  the 
valuation of nature credits. 

As a precursor for nature credits financed by the private sector, public seed finance, including 
from EU funds available to support EU competitiveness and innovative European projects in 
the clean transition, can play an important role, by providing guarantees and/or a predictable 
source of revenues to actors engaged in nature-positive action.  

Action [2025-2027]: A pilot project on nature credits will be launched and supported by EU 
funds available to support EU competitiveness and innovative European projects. 

46 Article 21(7) of the Regulation (EU) 2024/1991 of the European Parliament and of the Council of 24 June 2024 on nature 

restoration and amending Regulation (EU) 2022/86. 

47    More  information  on  the  InvestEU  Advisory  Hub:  https://investeu.europa.eu/investeu-programme/investeu-advisory-

hub_en 

48  More information on Green Assist: https://cinea.ec.europa.eu/green-assist-green-advisory-service-sustainable-investments-

support_en 

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4.5. Next steps 

Over the period 2025 to 2027, the Commission will take the actions described above to assist 
the  development  of  nature  credit  markets  in  close  cooperation  with  Member  States, 
stakeholders and international partners. As the engagement of farmers and foresters is key for 
the  success  of  nature  credits,  the  Commission  will  closely  involve  the  European  Board  on 
Agriculture and Food49. 

This collaborative work will pave the way for further exploring policy options, including how 
the existing carbon architecture could be leveraged to create a new strand dedicated to nature 
credits, limiting implementing costs in line with simplification objectives. As markets in nature 
credits are still nascent, broader mechanisms to support demand generation could be explored, 
including  incentivising  uptake  through  disclosure  and  procurement  rules,  tax  incentives, 
sectorial requirements, or other regulatory tools. 

Lessons learned from national schemes, pilot projects, international examples and academia 
will feed into this process, ensuring that any potential new instruments are grounded in science, 
practical feasibility and aligned with EU and international objectives. 

Action [2027]: Based on experience and consultations, and inputs from the expert group, the 
Commission will review progress made and consider next steps for the development and scaling 
up of nature credit markets. 

Conclusion 

The steps outlined in this roadmap set out a path to turn these foundations into policy action 
with robust methodologies, solid certification processes and inclusive governance frameworks, 
as well  as  the  enabling  of high-integrity  supply  and demand  sides  for nature credits. In  the 
process,  the  focus  will  be  on  ensuring  subsidiarity,  integrity,  simplicity  and  minimising 
administrative burden from the outset. 

All stakeholders are invited to submit their views and contributions on the elements set out in 
this roadmap as well as on any other issues that they wish to raise concerning nature credits. 

49 https://ec.europa.eu/transparency/expert-groups-register/screen/expert-groups/consult?lang=en&groupID=3976  

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