Commission Implementing Regulation (EU) 2025/2358 of 20 November 2025 laying down detailed rules for certification schemes, certification bodies and audits under the Union Framework for permanent carbon removal, carbon management and storage carbon in products (Regulation (EU) 2024/3012).

The main objective of this Regulation is to ensure correct and harmonized functioning certification schemes, which is necessary to determine the compliance of carbon removals and land emission reductions with EU requirements. Implementing rules should be proportionate, limited to the minimum necessary, and serve to ensure adequate and harmonised verification of compliance with the requirements, while minimising the risk of fraud.

Strengthening systems integrity and governance

Certification systems are mandatory to implement reliable management structure, which guarantees the necessary legal and technical capacity, impartiality and independence. The governance includes a board of independent members and a technical committee that provides expert advice. To ensure integrity, a system of checks and balances must be put in place to prevent conflicts of interest, while stakeholders with a vested interest in the outcome must be excluded from decision-making.

At the same time, a high level of transparency is required. Certification systems must make publicly available and free of charge on their websites key information about management and operations, including rules, procedures for handling complaints and an annual report on operations.

To support comparable information, the following are established: standardized patterns for key documents such as the action plan and monitoring plan to be submitted by the operator or group of operators. The action plan must include, for example, a description of the eligibility, geo-referenced boundaries, start date of the action and the expected net carbon removal benefit.

Requirements for audits and certification bodies

The reliability of certification is ensured through independent audits. Certification bodies must be accredited by a national accreditation body according to relevant Union technical standards (e.g. EN ISO/IEC 17065) or recognised by a competent national authority. Auditors shall have the necessary technical skills and audit experience, including at least two years of experience in life cycle assessment and specific experience in greenhouse gas emission calculations. Certification and recertification audits shall be carried out at the level of reasonable assurance.

For operators carbon agriculture – often small actors – has been established group audit. A group audit is permitted if the activities are geographically close, have similar soil-climatic characteristics and if the group has implemented an internal control system managed by a group leader. The audit in this case is carried out on the basis of a sample of members, the size of which is equal to the square root of the total number of group members, taking into account the level of risk.

Addressing non-compliance and transparency of registers

Certification schemes must establish a comprehensive system for addressing cases of non-compliance that are classified as critical, serious or minor.

• Critical breach of duty includes fraud, irreversible non-performance or intentional misrepresentation of the description of the activity that compromises the integrity of the system. The discovery of a critical non-performance during an audit leads to immediate withdrawal of the certificate.
• Serious breach of obligation represents a potentially reversible, repeated violation revealing systematic problems, e.g., finding incorrect documentation in more than 10 % claims in a sample. This leads to immediate suspension of the certificate, and if not corrected within 90 days, to revocation.
• In case minor breach of obligation a period for correction is determined, which may not exceed 12 months.

To prevent double counting and fraud, certification registries (until a central Union registry is established by 2028) must comply with strict requirements, including registration and tracking of the identity of operators, and must prevent the issuance of certified units if they have already been issued for the activity by another system. In the event of erroneous or fraudulent issuance of units, registries must apply corrective measures, such as suspension of the operator's account and possible compensation.

These harmonised rules are designed to increase the reliability and credibility of the carbon removal certification process across the European Union. The entire regulatory framework acts as a watchdog, ensuring that environmental carbon claims are backed by rigorous and independent verification, thereby protecting the integrity of the EU green market. JRi