GHG Removals & Carbon Offsets
ESRS E1-7 requires separate disclosure of GHG removals and carbon offset purchases. Offsets cannot be netted against gross emissions — they must be disclosed transparently alongside your gross Scope 1, 2 and 3 figures. This ends ambiguous net zero accounting.
ESRS E1-7 requires separate disclosure of GHG removals and carbon offset purchases. ESRS E1-7 requires disclosure of: GHG removals from your own operations (e.
What ESRS E1-7 requires
ESRS E1-7 requires disclosure of: GHG removals from your own operations (e.g. reforestation, BECCS, direct air capture); GHG removals purchased from third parties (carbon offsets); and the mitigation contribution (offsets purchased to fund external projects).
Critically, none of these may be deducted from your gross Scope 1, 2 or 3 emissions. The gross figures are headline disclosures. Removals and offsets are additional disclosures that show your offset strategy separately.
This prevents companies from claiming low net emissions while hiding high gross emissions behind large offset purchases.
The quality criteria for carbon offsets
Not all carbon offsets are equal. ESRS E1-7 requires disclosure of which registry the offsets are certified under and the vintage (year the removal or emission reduction occurred).
High-quality offset registries: Gold Standard, Verra (VCS), American Carbon Registry, Climate Action Reserve.
Key quality criteria: Additionality (would the removal have happened without the offset funding?); Permanence (is the removal durable — especially for nature-based solutions?); No leakage (does the project shift deforestation to another area?); Verification (third-party verified).
Cheap forest protection offsets frequently fail on additionality — the forest was not at risk of being felled. These are likely to attract assurer scrutiny under ESRS E1-7.
Implications for net zero claims
The separate disclosure of gross emissions and offsets makes net zero claims verifiable and comparable. A company claiming net zero with gross emissions of 10 million tonnes CO2e and 10 million tonnes of purchased offsets now has to disclose this explicitly — investors and NGOs can judge the quality of the offsets and the pace of genuine emission reduction.
Expect assurers to challenge offset quality claims. Poor-quality offsets that do not meet the criteria above will be flagged as findings.
The EU Carbon Removals Certification Framework (adopted 2024) will establish EU-level quality criteria for carbon removals — companies should monitor how their offset purchases align with emerging EU standards.
Frequently asked questions
Can we include our forest landholdings as carbon removals?
Yes, if the removals are calculated according to the GHG Protocol Land Sector and Removals Guidance. Forest carbon sequestration can be included as biological removals in ESRS E1-7. The calculation must be verified and the methodology disclosed.
Do we need to separately disclose every offset we purchase?
Not individually — ESRS E1-7 requires aggregate disclosure by type (removal vs mitigation contribution) and registry, with vintage. Individual project-level disclosure is good practice but not mandatory.
What is the difference between removals and mitigation contributions?
Removals physically extract CO2 from the atmosphere (reforestation, BECCS, DAC). Mitigation contributions fund emission reductions elsewhere (renewable energy projects, methane capture) — these reduce someone else's emissions but do not remove CO2 from the atmosphere.