Carbon offsetting, contribution, insetting: under ESRS E1, every external climate investment is now subject to formal audit. Most sustainability teams discover the gap between what they declared and what they can actually prove during the audit, not before.
We mapped what auditors systematically look for, in the order they ask, and built from real CSRD audit observations.
The Omnibus I package, formally adopted on 24 February 2026, narrowed CSRD scope to companies with more than 1,000 employees and net turnover exceeding €450 million but left the core carbon credit disclosure requirements under ESRS E1-7 fully intact.
Until 2024, climate investments lived in voluntary reports. Nobody verified the claims.
Since ESRS came into force, an external auditor examines the evidence. Carbon credits must be reported separately under ESRS E1-7, with no netting against gross emissions. The CRCF regulation (in force since December 2024, with certification methodologies rolling out from 2026) introduces strict criteria on additionality and reversal risk. The Empowering Consumers for the Green Transition Directive (ECGT, applying from September 2026) restricts public claims like "carbon neutral" or "net zero" that rely on offsetting without substantiation.
Three regulations. One audit. A new profession sitting between you and your sustainability report: the auditor.
A growing list of companies acted in good faith and could not document what they had said publicly:
Built from real audit observations, the guide is a working document, not a thought piece. It is structured around the 5 questions auditors systematically ask about external climate actions, in the exact order they come up. For each question, you get:
Soil Capital runs Europe's largest insetting and contribution programmes: 1,800 farmers, 500,000 hectares, 16 million euros paid to farmers for measured carbon outcomes. Our MRV is TÜV verified and ISO 14064-2 certified. We have sat next to sustainability teams during dozens of CSRD audits. This guide is the playbook we wish every team had before their first review.
Carbon offsetting, contribution, insetting: under ESRS E1, every external climate investment is now subject to formal audit. Most sustainability teams discover the gap between what they declared and what they can actually prove during the audit, not before.
We mapped what auditors systematically look for, in the order they ask, and built from real CSRD audit observations.
The Omnibus I package, formally adopted on 24 February 2026, narrowed CSRD scope to companies with more than 1,000 employees and net turnover exceeding €450 million but left the core carbon credit disclosure requirements under ESRS E1-7 fully intact.
Until 2024, climate investments lived in voluntary reports. Nobody verified the claims.
Since ESRS came into force, an external auditor examines the evidence. Carbon credits must be reported separately under ESRS E1-7, with no netting against gross emissions. The CRCF regulation (in force since December 2024, with certification methodologies rolling out from 2026) introduces strict criteria on additionality and reversal risk. The Empowering Consumers for the Green Transition Directive (ECGT, applying from September 2026) restricts public claims like "carbon neutral" or "net zero" that rely on offsetting without substantiation.
Three regulations. One audit. A new profession sitting between you and your sustainability report: the auditor.
A growing list of companies acted in good faith and could not document what they had said publicly:
Built from real audit observations, the guide is a working document, not a thought piece. It is structured around the 5 questions auditors systematically ask about external climate actions, in the exact order they come up. For each question, you get:
Soil Capital runs Europe's largest insetting and contribution programmes: 1,800 farmers, 500,000 hectares, 16 million euros paid to farmers for measured carbon outcomes. Our MRV is TÜV verified and ISO 14064-2 certified. We have sat next to sustainability teams during dozens of CSRD audits. This guide is the playbook we wish every team had before their first review.
