The carbon credit landscape has fundamentally shifted. With California’s SB 253 now requiring Scope 1 and 2 emissions reporting (first reports due mid-2026), the EU’s CSRD mandating separate disclosure of carbon credit usage, and high-quality removal credits trading at 300%+ premiums over low-rated alternatives, your 2026 procurement strategy must prioritize quality over quantity. This guide covers the regulatory changes now in effect, why removal credits are commanding premium prices, and how to build a procurement framework that withstands regulatory scrutiny and delivers genuine climate impact.
The Regulatory Landscape Has Changed—Permanently
If you’re a Chief Sustainability Officer at a Fortune 500 company, January 2026 marks a turning point. The regulatory frameworks that were “coming soon” for years have arrived. California’s SB 253 now requires any company doing business in California with over $1 billion in annual revenue to publicly report Scope 1 and Scope 2 greenhouse gas emissions.
The first reports are due to the California Air Resources Board (CARB) by mid-2026, covering fiscal year 2025 data. Third-party verification at a limited-assurance level is mandatory from day one.
This isn’t just a California issue. Given the state’s economic influence and the number of Fortune 500 companies operating there, SB 253 effectively establishes a national baseline for emissions transparency.
Meanwhile, the EU’s Corporate Sustainability Reporting Directive (CSRD) has fundamentally changed how carbon credits factor into corporate sustainability claims. Under CSRD, companies must disclose their emissions separately from purchased carbon credits. You can no longer blend carbon credit retirements into your emissions figures to show progress against reduction targets. The credits you purchase will be scrutinized—and low-quality offsets will be exposed.
The Quality Premium Is No Longer Optional
The voluntary carbon market has bifurcated. On one end, generic exchange-traded nature-based avoidance credits have fallen below $1 per ton. On the other hand, high-integrity removal credits command extraordinary premiums.
The market has bifurcated sharply. Generic avoidance credits have collapsed below $1/tonne, while high-integrity removal credits — particularly those with verified permanence and clean additionality — command substantial premiums. Credits rated BBB or higher traded at over 300% above lower-rated alternatives in 2025. The message is clear: buyers are willing to pay for quality, not quantity.
The ICVCM’s Core Carbon Principles: Your Quality Benchmark
The Integrity Council for the Voluntary Carbon Market (ICVCM) has established the Core Carbon Principles (CCPs) as the definitive benchmark for high-quality carbon credits . Credits carrying the CCP label trade at multiples of uncertified alternatives.
The CCPs are organized into three categories:
Governance:
- Effective program-level governance
- Registry-based credit tracking
- Full transparency
- Third-party validation and verification
Emissions Impact:
- Additionality (the project wouldn’t happen without carbon finance)
- Permanence (removals must be durable)
- Robust quantification
- No double counting
Sustainable Development:
- Social and environmental safeguards
- Compatibility with net-zero pathways
For your procurement team, this means every credit purchase should be evaluated against these principles. If a project can’t demonstrate additionality—meaning the carbon removal wouldn’t have occurred without the revenue from credit sales—it fails the most fundamental test of integrity.
The Additionality Imperative
Additionality remains the most misunderstood—and most critical—criterion for carbon credit quality.
At Dynamic Carbon Credits, we apply a rigorous framework:
- Baseline Scenario Analysis: Would this carbon removal have happened anyway through business-as-usual operations?
- Certification Verification: Is the project certified by recognized standards (Verra VCS, Gold Standard, American Carbon Registry, or ICVCM CCP-labeled)?
- Project Barrier Test: Were there financial, technological, or institutional barriers that carbon credit revenue helped overcome?
- Common Practice Test: Is this type of project already common in the region without carbon finance?
- The Ultimate Test: Does this project exist solely for carbon removal?
That final question is the benchmark that separates premium removal credits from commoditized offsets. When a crop is grown exclusively to capture atmospheric carbon, converted to stable biochar through pyrolysis, and returned to soil for centuries-long sequestration—that’s clean additionality. There’s no ambiguity about whether the carbon removal would have happened anyway.
Building Your 2026 Procurement Strategy
Given the regulatory environment and market dynamics, here’s how to structure your carbon credit procurement for 2026:
Step 1: Define Your Climate Goals with Precision
Before purchasing a single credit, document:
- Your verified Scope 1 emissions baseline
- Your direct reduction targets and timeline
- The residual emissions that genuinely require offsetting
- Your alignment (or gap) with the SBTi Net Zero Standard
Step 2: Prioritize the Mitigation Hierarchy
Carbon credits should address residual emissions after you’ve exhausted direct reduction opportunities:
- Eliminate: Electrification, process redesign, facility upgrades
- Reduce: Efficiency improvements, operational optimization
- Remove: High-quality carbon removal for what remains
Using credits as a substitute for internal decarbonization is a compliance risk under CSRD and a reputational risk in any market.
Step 3: Establish Quality Criteria
Your procurement policy should require:
- Certification by Verra, Gold Standard, American Carbon Registry, or ICVCM CCP-labeled programs
- Verified additionality documentation
- Permanence guarantees (minimum 100 years for removal credits)
- Third-party verification and transparent MRV (monitoring, reporting, verification)
Step 4: Consider Procurement Mechanisms
- Spot Purchases: For immediate needs, but subject to price volatility
- Long-Term Contracts: Lock in pricing and supply for high-quality removal credits
- Forward Contracts: Secure future delivery from projects under development
- Direct Project Partnerships: Maximum control over quality and co-benefits
Given constrained supply of high-quality removal credits—with repeat buyers securing capacity through multi-year offtake agreements—waiting until Q4 to procure is a strategic error.
Methods of Capturing Carbon
Solution
Cost Per Ton CO2
Scalability
Co-Benefits
ESG Impact
Direct Air Capture (DAC)
$600-$1,200+
Limited
Minimal
High Cost, Low Impact
CCS (Point Source)
$50-$100
Moderate
None
Prevents New Emissions
Biochar (Dynamic Carbon Credits)
Competitive
High
Soil Health, Community Value
High Impact, Mulit-faceted
The Cost of Getting This Wrong
The risks of a flawed carbon credit strategy extend beyond compliance penalties:
Regulatory Exposure: Under CSRD, your carbon credit usage will be disclosed separately from emissions reductions. Low-quality credits will be visible to investors, regulators, and stakeholders.
Reputational Risk: Greenwashing accusations have ended careers and damaged brands. The OECD has issued explicit guidance against misleading carbon neutrality claims.
Financial Risk: Low-quality credits may face future invalidation or require replacement. The price differential between quality tiers is only widening.
Strategic Risk: Companies that treat carbon credits as a substitute for decarbonization will find themselves increasingly out of step with SBTi requirements, investor expectations, and regulatory trajectories.
The Bottom Line
The 2026 carbon credit market rewards quality and punishes shortcuts. With removal credits trading at significant premiums, regulatory frameworks demanding transparency, and the ICVCM’s Core Carbon Principles establishing a clear quality benchmark, your procurement strategy must evolve.
The question isn’t whether you can afford premium removal credits. It’s whether you can afford the regulatory, reputational, and strategic costs of the alternative.
At Dynamic Carbon Credits, our crop-based Direct Air Capture approach delivers verifiable removal with clean additionality—carbon sequestration that exists solely because of the carbon removal mission. Our 144-day crop lifecycle aligns with corporate quarterly reporting, and our biochar’s permanence is verified under Puro.earth’s CORC200+ methodology.
The market has bifurcated. Which side of that divide will your company be on?
Ready to build a procurement strategy that withstands scrutiny?
Bill Ickes is VP of Sustainability at Dynamic Carbon Credits, where he leads corporate advisory services and procurement strategy for Fortune 500 clients.