Newsletter

Excellent report. Good balance between the advantages and disadvantages of activity-based versus result-based CAP support. In reality, there are virtually no result-based payments being made in the current CAP and glacially slow progress towards it being possible in the future. The CRCF is pushing the frontiers and is not assisted by the current Performance Monitoring and Evaluation Framework for the CAP — which talks of result and impact indicators but only reports these at a national or regional level. Some movement is taking place in the DGAGRI Vision for Agriculture and Food and its discussion of data sharing and the need to establish "an on-farm Sustainability Compass". But the 100% non-compliance of Member States with the requirements of the Farm Sustainability Tool for Nutrients (should have been end of 2024) and the 80% non-compliance with the High Value Datasets Regulation of the Open Data Directive (should have been June 2024) leads one to think that only a strong compliance stick will persuade the MS to make IACS data available to evaluate "results" — whether this is for carbon or for nature credits.

A case in point is the collection of soils data, funded by government grants, which should be made available in a national system (as was planned in the FAST Platform). Recommendations in the report on interoperability with the Soil Monitoring Directive and the Nature Restoration Regulation are excellent. The discussion on "default emissions factors" could usefully have mentioned the need for a closer link between methods used for national GHG accounting to the UNFCCC and emerging CRCF methodologies — both for predicted emissions and for areas of different land uses. National reporting always separates CO2 from non-CO2 net emissions. It is not clear why separate targets are such a big deal at national level given that LULUCF reporting is in Chapter 6 of the Inventory and agricultural non-CO2 gases in Chapter 5 of the annual inventory reports.

Dear Credible team, thank you for the opportunity to contribute to the Credible 2025 consultation. Our feedback reflects hands-on implementation across markets and aims to inform how digital infrastructure can accelerate traceable, cost-effective carbon farming aligned with the CRCF. The following feedback is based on our work designing digital infrastructure for credit-level traceability, automated sustainability reporting, and integration with emerging standards. In the attached letter, we provide reflections and recommendations in response to the following five expert reports:

1. Barriers and incentives for sharing input data needed in carbon farming and MRV systems in Europe; 2.Earth Observation (EO) for MRV of Carbon Farming; 3. Unlocking data for MRV: Data sharing for effective carbon farming; Ensuring carbon farming delivers sustainability benefits and 5. An effective policy mix for scaling up carbon farming We share our input based on practical implementation experience and with the aim of supporting the development of effective, transparent, and farmer-accessible carbon farming and MRV systems across Europe. Our experience building MRV infrastructure aligns closely with the data architecture envisioned under the EU Carbon Removal Certification Framework (CRCF). In this submission, we provide actionable suggestions to support CRCF-compatible implementation, especially as it relates to credit traceability, automated disclosures, and co-benefit accounting.

Congratulations to the team behind the EU CREDIBLE Project for producing this timely and important report on policy options to scale up carbon farming. Some feedback for consideration:

1. Biofuels One area that could be further explored in future reports is the role of biofuels in agriculture and its likely future implications for carbon farming. If the objective is to incentivize carbon farming, the current incentives for biofuels under the Renewable Energy Directive (RED) deserve closer scrutiny. The lack of meaningful restrictions in the RED has led to the overuse of crop-based bioenergy at significant cost to biodiversity and climate goals. Converting crops into biofuels undermines climate action and food security, especially when that land could instead be used to grow food or restore natural carbon sinks. The impact has been severe: rising biomass demand has contributed to food insecurity, human rights violations, and land grabs. To support a climate- and nature-positive transition, the EU should: end all incentives for energy from dedicated crops, regardless of sector; enforce the cascading principle; and restrict bioenergy use to sectors without viable alternatives, making better use of scarce biomass resources.

2. Use Case and Legal Trends: The report could also deepen the analysis around the “use case” for carbon farming credits, particularly in light of emerging legal and market dynamics. Contribution claims are likely to become more commercially attractive as regulatory frameworks move away from offsetting. In this context, it would be valuable to explore: ongoing litigation trends related to greenwashing; the positioning and strategic value of CRCF credits under evolving corporate sustainability regulations.

3. LULUCF: While likely a deliberate choice, the absence of reference to the LULUCF sector is notable. Future iterations of the report might benefit from examining how carbon farming policy can enhance the EU’s LULUCF targets and frameworks.

Terminology coherence is important and a first step for the necessary step of MMRV coherence across private and public efforts. Our RFP with its cost-efficient and effective MRV already applied at scale serves to that cause. Co-efficients are a dangerous cause and can do more harm than good. Instead we must realize that the proxy and thus real-measuring technology is ready to date. Additionally, and agri-ets that targets the most concetrated parts of the agri-food supply in fusion with csrd and csdd should be assessed.

Measuring must return agency and motivation to farmers and heal the pains caused by years of practice-based incentivization. All public and private levers can work coherently and synergistically optimizing cost-effectiveness - only if they are underpinned by a shared data language and infrastructure (RFP KPIs).

Farmers need meaningful regulatory simplification, and the use of a harmonised data infrastructure will help to achieve this. This data will also inform performance-based incentives, financial and investment instruments, and tailored agronomic advice for farmers.

These combined factors will foster improved farmer livelihoods,bioeconomic productivity and ecosystem and human health. Using a harmonised data language (RFP KPIs) allows for a blended and stacked strategic approach to a complementary public-private transition framework co-enabling the regenerating full productivity of all farms in the EU.