MRV is crucial to demonstrating the meaningful climate contribution of projects, enabling their transparency and accountability, and building trust around these and the carbon removal industry as a whole. MRV is done according to rules and principles established by the standard to which the project adheres. Standards, whether set by governments, standard-setting bodies or other entities, include protocols (also referred to as methodologies) that detail the quantification requirements and other rules for ensuring high integrity in how projects are to measure, monitor, report and verify their activities.

Once the carbon removal activity has been measured, reported and verified, and the monitoring process has been clearly defined, it can be certified. Certification involves assessing the effectiveness and environmental integrity of credits produced from carbon dioxide removal (CDR) projects to provide the ‘stamp of approval’ for the quality of the removal. Once the activity is certified as a carbon removal credit, it can be sold within voluntary or compliance carbon markets.

Certification and MRV are strongly linked to each other. MRV protocols are specific to individual CDR pathways, while certification provides a common framework that cuts across various MRV systems with overarching rules and standards. In other words, certification determines what can count as carbon removal, while MRV describes how to account for a carbon removal activity.

The most notable policy in development in Europe that is relevant to MRV is the EU Carbon Removal Certification Framework (CRCF). The CRCF would create the first-ever government-led regulatory framework to monitor, verify and certify activities that remove CO₂ from the atmosphere.

There is less emphasis on government policy to guide MRV for CDR in the US. Currently, no comprehensive MRV standards or regulations for CDR have been introduced, although some MRV requirements for certain aspects of CDR do exist at both the federal and state level.

The EU Carbon Removal Certification Framework

In November 2022, the European Commission proposed a voluntary regulatory framework for the certification of carbon removals (CRCF), which will be the first government-led certification framework for CDR. The CRCF aims to foster and accelerate the scale-up of high-quality carbon removal. The framework covers a wide variety of CDR methods to be applied by land managers, industries, and others to remove and store atmospheric or biogenic CO₂. The CRCF is also intended to help fight greenwashing and to harmonise the European carbon removal market. Creating an effective and scientifically sound CDR certification framework that ensures that only high-quality CDR is credited would not only establish the EU as a leader in this space but would represent a significant step toward integrating carbon removal into EU climate policies.

Under the CRCF, the European Commission, assisted by an expert group, will develop methodologies for the certification of a range of carbon removal approaches and recognise whether existing certification schemes are compliant. The certification schemes recognised by the CRCF will be obligated to list certified removals in interoperable public registries, while certification bodies, supervised by member states, will carry out certification audits and the issuing of certificates.

The figure below shows the life-cycle of a carbon removal credit as it goes through a rigorous MRVL process. In this figure, MRV is complemented with a fourth component; “L” stands for liability and defines the responsible parties around the eventuality of reversal.

What is happening elsewhere in Europe?

The United Kingdom is taking the approach of reviewing all existing MRV frameworks that have been developed by credible actors in the voluntary carbon market (VCM) and through international standards. Based on this review, they draft a framework grounded in best practices within the voluntary market. Switzerland’s CO₂ Ordinance sets a general set of rules and criteria for emissions reductions and CO2 sequestration projects to be recognised nationally. Switzerland relies on third-party certification and MRV frameworks approved by the Federal Office of the Environment.

United States

While there is no policy equivalent to the EU’s CRCF for certifying carbon removal on the horizon in the US, there are some policies that include requirements on MRV, and there are efforts underway that could provide some level of MRV guidance for CDR. The existing MRV requirements across policies are primarily tied to CO₂ sequestration in geologic formations and therefore only pertain to a limited set of CDR approaches, such as direct air capture (DAC).

At the federal level, there are MRV requirements tied to the 45Q tax credit, which provides a tax credit at varying levels depending on the capture mechanism for qualifying the total tonnes of CO₂ captured and sequestered. These requirements are sequestration-specific and are tied to the EPA’s Class VI permit, which operators must receive to sequester CO₂ in geologic formations. Operators that sequester CO₂ in Class VI wells must also follow the ‘Subpart RR’ rule under the Greenhouse Gas Reporting Protocol and are required to submit an MRV plan to the EPA that follows specific requirements relevant to what is to be measured and monitored.

Prize competitors under the CDR Purchase Pilot Prize must submit an MRV plan to DOE, adhering to specific requirements (see Appendix 11 of the official rules document). The proposals with the most comprehensive plans will be prioritised by DOE. Although no official standard for MRV for CDR has been established at the federal level, this prioritisation is expected to set an implicit standard for what the government considers robust and high-quality approaches to MRV.

In California, the Carbon Capture and Sequestration Protocol under the Low Carbon Fuel Standard (LCFS) includes MRV requirements for DAC projects, which, amongst other measures, can be used to generate credits. Similar to the MRV requirements tied to 45Q, the Protocol’s MRV requirements are specific to the geological sequestration of CO₂.

Efforts in the voluntary carbon markets and at the UN level

To date, aside from the EU CRCF, most efforts aimed at regulating MRV have been in the VCM and by CDR companies themselves; companies often develop their own MRV protocols while other organisations in the voluntary carbon market establish standard-setting certification criteria – all with no overarching regulatory body governing these endeavours. However, there are efforts to ensure credit quality across all carbon credits, not just CDR credits. For instance, the Integrity Council for the Voluntary Carbon Market aims to regulate credit supply quality, and the Voluntary Carbon Market Integrity Initiative aims to regulate credit demand and how related claims are represented.

Within the United Nations framework, the Paris Agreement Article 6.4 Mechanism has been under development for the past several years. It is a market-based instrument that countries can use to trade credits from emissions reduction and removal projects to meet national climate goals. Within its remit, the Article 6.4 Supervisory Body is responsible for establishing guidance and procedures, approving methodologies, registering projects, and issuing credits. Methodologies may be developed by project participants, host countries, stakeholders or the Supervisory Body.