Setting Baselines Below Business-as-Usual

In Verra’s Version 5 consultation on the Verified Carbon Standard (VCS), Eco Sustainability contributed feedback on a deceptively technical issue that could make or break market integrity: how should baselines be set?

Here’s why this matters. Baselines are the yardstick. They decide whether a carbon credit represents a real emissions reduction, or just an inflated number. If “business-as-usual” is drawn too high, projects can issue credits for reductions that were never going to happen. That’s not conservativeness. That’s over-crediting.

We support Verra aligning its baseline rules with PACM, the Paris Agreement’s crediting mechanism, and with CORSIA. This ensures VCS credits don’t fall behind global best practice. Conservative baselines - and tightening ambition over time - are the foundation of integrity.

Downward adjustments are essential. Without them, we risk rewarding projects for standing still. Baselines must always sit below business-as-usual, otherwise we create credits with no real climate benefit.

Some have called for flexibility across countries, sectors, or project types. We believe that’s dangerous. Flexibility too easily becomes a loophole. A credit from one country should mean the same thing as a credit from another. If any deviation is allowed, it must be backed by clear justification, robust data, and independent validation.

Finally, we urged Verra to think about the future. Baselines can’t stay frozen while the world changes. National commitments evolve. Technology improves. Sectors decarbonise. Baselines should move too - dynamically, over time. And the assumptions behind them must be disclosed publicly so trust can be built.

Carbon markets don’t collapse because they are too strict. They collapse when buyers and regulators lose trust that a credit represents something real. Version 5 is Verra’s opportunity to strengthen credibility by insisting on conservative, transparent, and dynamic baselines.

About Eco Sustainability

As a trusted advisor on sustainability and climate policy, Eco Sustainability is not only aligned with global standards - we help shape them by contributing to technical consultations and international standard-setting processes.