ISO 14068-1 is the international standard for carbon neutrality claims. Section 11 sets out in precise, legally-structured language exactly which carbon credits may be used in a carbon neutrality claim, which crediting programmes may generate them, and — critically — what documentation the claiming entity must be able to produce. It is not a quality aspiration. It is a mandatory disclosure checklist. Every item in the 360° Impact Portfolio disclosure pack is mapped against it.
ISO 14068-1, published in 2023, is the first international standard specifically governing carbon neutrality claims by organisations, products, and services. It sits within the ISO 14060 family of GHG standards and is designed to be used alongside ISO 14064-1 (organisational GHG inventory) and ISO 14064-2 (GHG project quantification). For any organisation making a carbon neutrality claim — whether in a sustainability report, on a product, or in an investor disclosure — it is the primary standard your certification body, your external assurance provider, and your legal team will reference.
Section 11 of the standard addresses carbon credits specifically. It is structured in three parts. Section 11.2 defines what a carbon credit must be to qualify for use in a neutrality claim — the credit-level quality criteria. Section 11.3 defines what the crediting programme generating those credits must be — the programme-level eligibility criteria. Section 11.4 defines what the claiming entity must document to substantiate the claim — the mandatory evidence requirements. It is §11.4 that determines the contents of your disclosure pack.
For UK companies reporting under SECR, ISO 14068-1 provides the internationally recognised framework for structuring a carbon neutrality claim that will satisfy both domestic SECR disclosure obligations and the expectations of international stakeholders, investors, and assurance providers. DEFRA’s Good Quality Criteria for offsets are closely aligned with §11.2, but the ISO standard is more detailed, more recent, and carries international authority. Using both simultaneously is not duplication — it is comprehensive coverage.
Before §11.2 lists a single credit criterion, the standard establishes a mandatory sequencing obligation. Credits may only be used after the entity has reduced its GHG emissions and implemented GHG removals within its own boundary. The reasons for not going further must be justified and documented.
The mandatory sequence
The standard is explicit: the entity shall reduce GHG emissions, then implement GHG removals within its boundary, then offset unabated emissions using carbon credits. This is not a recommendation — it is a “shall” obligation. An organisation that purchases carbon credits without having first reduced emissions in line with its carbon neutrality management plan is not conformant with §11.1, regardless of the quality of the credits purchased. For SECR reporters, this means your Streamlined Energy and Carbon Reporting submission and your scope 1, 2, and 3 reduction plan are prerequisites for a valid neutrality claim, not alternatives to one.
The ex-ante prohibition
Contracted, future emission reductions and removal enhancements are explicitly encouraged as a way to provide early project financing. But they may not be used for a carbon neutrality claim until the mitigation is certified, the credits issued, and the credits subsequently retired. This prohibits forward-crediting entirely in the context of a neutrality claim. All credits used in a claim under ISO 14068-1 must be ex-post: the reduction or removal must have already occurred, been verified, and resulted in issued credits before retirement.
Double counting: entities and governments
The standard requires avoidance of double counting between multiple entities and between entities and governments. The §11.1 note explicitly states that the application of corresponding adjustments under Paris Agreement Article 6, paragraph 4 provides the mechanism for avoiding double counting between private buyers and host country governments. This is the normative basis for the Sovereign Portfolio: where CAs are applied, the host country has adjusted its NDC to account for the transfer, eliminating the sovereign double-counting risk that standard voluntary credits carry.
Residual emissions and removal credits
The standard includes a “should” requirement that when only residual GHG emissions remain — the irreducible minimum after all feasible reductions have been made — the entity should use carbon credits based on GHG removal enhancements rather than avoidance credits. This reflects the scientific consensus that permanent drawdown is ultimately necessary for net zero, and signals the direction of travel for credit portfolio composition as markets develop.
§11.2 lists the conditions a carbon credit must individually meet before it may be used in a carbon neutrality claim. These are credit-level requirements, not programme-level requirements. Three additional timing rules apply alongside them.
§11.2(a) — Real
The GHG emission reduction or removal enhancement must be real. This is a threshold condition that precedes all others: the physical climate benefit must actually exist. In the context of a crediting programme, this is established through the monitoring and verification process — actual data from the project demonstrating that the reduction or removal occurred as measured and reported.
§11.2(b) — Additional
The activity must be demonstrated to be additional using a robust assessment: the emission reduction or removal would not have occurred in the absence of the GHG project, represents mitigation that exceeds regulatory requirements, and exceeds business as usual. The assessment methodology must be approved by the crediting programme. This is the criterion most directly addressed by the ICVCM CCPs Principle 5, and the one most frequently examined by assurance providers.
§11.2(c) — Measurable
The reduction or removal must be quantified in accordance with approved crediting programme methodologies, using conservative estimation of GHG baselines. The standard references ISO 14064-2 for the quantification of GHG reductions and removal enhancements and the calculation of GHG baselines. Conservative is the operative word: where uncertainty exists in baseline setting or monitoring, the methodology must resolve it in the direction of understating the reduction, not overstating it.
§11.2(d) — Permanent
The reduction or removal must be permanent. If permanence risk exists, the crediting programme must have adequate safeguards to minimise reversal risk and, where reversal occurs, a mechanism that guarantees equivalent removal will be delivered. Buffer pools, contractual make-good obligations, and insurance solutions are the recognised mechanisms. For renewable energy projects — which are the primary project type in Carbon Essentials — permanence risk is structurally lower than for land-based projects because the avoided emission cannot be reversed.
§11.2(e) — Certified
The credit must be certified — that is, issued by a crediting programme that itself meets the programme-level requirements in §11.3. Certification at programme level is what Gold Standard and Verra CCP-Approved status represents in the ICVCM framework. A credit from a programme that does not meet §11.3 requirements is not eligible for use in a §11 neutrality claim, regardless of the quality of the underlying project.
Three additional timing rules — §11.2
Ex-post only. Only credits representing GHG emission reductions or removals that have already occurred may be used. Forward-issued or projected credits are not eligible.
Vintage limit: five years. Credits for which the end of the vintage is more than five years prior to the start of the period for which the entity is claiming carbon neutrality may not be used. If your reporting period begins 1 January 2025, you may not use credits with a vintage end date before 1 January 2020.
Retirement deadline: 12 months. Credits used to achieve carbon neutrality must be retired no later than 12 months after the end of the reporting period. If your reporting period ends 31 December 2025, retirement must be completed by 31 December 2026.
§11.3 establishes what the carbon crediting programme itself must be, independently of any individual credit or project. These are the conditions your procurement process must verify before sourcing credits from any programme. For Gold Standard and Verra, this verification has been completed at programme level by the ICVCM.
§11.3(a) — Transparent
The programme must be transparent, with publicly available documented information on the project cycle, including registration requirements, verification requirements, and procedures. If the programme does not publish its project cycle documentation, an auditor cannot independently verify that the credits meet the standard’s requirements. Transparency is the precondition for all subsequent verification.
§11.3(b) — Safeguards
The programme must provide safeguards with regards to impacts on ecosystems, biodiversity, communities, human well-being, human rights, and local economies, to avoid adverse impacts where applicable. This is the social and environmental safeguards requirement. For Gold Standard, this is addressed through its Safeguarding Principles and the requirement for Free, Prior and Informed Consent. For Verra, through the Climate, Community & Biodiversity Standards and the Sustainable Development Verified Impact Standard.
§11.3(c) — SDG identification
The programme must identify the Sustainable Development Goals to which each GHG project contributes. The standard notes that sustainable development co-benefits can be included in the description of the GHG project. This is the normative basis for the SDG co-benefit mapping in the 360° Impact Portfolio. Every project on Gold Standard and Verra is required to identify its SDG contributions as part of the project documentation. That mapping is sourced directly from the registry record and included in the disclosure pack.
§11.3(d) — Governance arrangements
The programme must provide information about the governance arrangements which sets out the roles and responsibilities of the organisation administering it. This is the institutional accountability requirement: who is responsible for the rules, who can change them, and how decisions are made. For an auditor, this determines whether the programme is subject to independent oversight or is self-governed by commercial interests.
§11.3(e) — Stakeholder consultation
The programme must include stakeholder consultation requirements and processes for the development of rules, procedures, methodologies, tools, and for GHG projects. This prevents programmes from developing standards in isolation from the communities and stakeholders affected by their projects. It also provides a procedural basis for identifying and addressing adverse impacts before projects are registered.
§11.3(f) — Independent verification
The programme must have independent verification of GHG emission reductions or removal enhancements enabling issuance of carbon credits. The verifier must be independent of the project developer and the programme itself. Accreditation requirements for verifiers must be in place. This is the assurance-chain requirement: without it, the claimed reductions cannot be considered independently substantiated.
§11.3(g) — Registry, serialisation, retirement, traceability, double counting, leakage
The programme must issue carbon credits that are listed in a public registry with transparent ownership and status information; issued with unique serial numbers; issued under procedures that provide for permanent retirement; and traceable back to the relevant GHG project. Additionally, the programme must have measures for avoiding double counting between entities and between entities and national governments, and measures to minimise leakage risk. This sub-clause is the technical infrastructure requirement: it establishes the registry, serialisation, and retirement architecture that makes the credits independently verifiable. It is the programme-level equivalent of the credit-level tracking requirement in ICVCM CCP 2.
§11.4 is the disclosure checklist. These are the mandatory documented information requirements for any entity claiming carbon neutrality under ISO 14068-1. If you cannot produce these five items, your claim is not conformant with the standard. The 360° Impact Portfolio disclosure pack is structured to satisfy all five.
§11.4(a) — Programme, project, and methodology
The entity shall identify and document the carbon crediting programmes and GHG projects, and the methodology or methodologies used to generate the carbon credits used for offsetting.
→ Disclosure pack: Programme name (Gold Standard / Verra), project ID, methodology name and version number for each project.
§11.4(b) — Specific project and location
The entity shall identify and document the specific GHG project or projects that generated the carbon credits, including the GHG project’s location.
→ Disclosure pack: Named project for each credit batch, country and region, link to registry project record.
§11.4(c) — Number of credits from each project
The entity shall identify and document the number of carbon credits obtained from each GHG project.
→ Disclosure pack: tCO₂e retired from each project, broken down by project where the portfolio contains multiple projects. Total must equal the entity’s carbon footprint for the claiming period.
§11.4(d) — Vintage information
The entity shall document information about the year in which GHG emission reductions or GHG removal enhancements occurred and the year in which the carbon credits were issued — the vintage of the carbon credits.
→ Disclosure pack: Vintage year per credit batch (year reductions occurred) and issuance year (year credits issued by the registry). Both recorded. Vintage compliance with the five-year limit confirmed.
§11.4(e) — Evidence of retirement
The entity shall document evidence that the carbon credits have been retired, including a link to the registry in which the retirements have been made in the name of the entity claiming carbon neutrality and the serial numbers of the carbon credits that have been retired in the name of the entity claiming carbon neutrality.
→ Disclosure pack: Registry retirement certificate issued in the client’s legal entity name. Direct link to the retirement record on the Gold Standard Impact Registry or Verra Registry. Serial numbers of every credit retired, by project. Retirement date confirmed within 12 months of end of reporting period.
Note on §11.4 and the 12-month retirement deadline
The §11.4(e) retirement evidence must confirm that credits were retired in the name of the entity claiming carbon neutrality. Retirement in a third-party’s name, or in the name of a holding entity rather than the claiming entity, does not satisfy this requirement. The legal entity name used in the registry retirement record must match the entity named in the neutrality claim. The 360° Impact Portfolio retires credits directly in the client’s legal entity name as specified at onboarding.
SECR does not mandate carbon neutrality. It requires large UK companies to report their scope 1 and scope 2 emissions, an intensity ratio, and at least one energy efficiency action. What ISO 14068-1 provides is the recognised international framework for going beyond that mandatory minimum — for making a neutrality claim that will be understood, scrutinised, and increasingly expected by your board, your investors, your customers, and your supply chain.
The practical challenge for a sustainability manager at a mid-market UK company is that ISO 14068-1 is a standard written for certification bodies, lawyers, and assurance providers. It uses precise, qualified language that requires interpretation. “Shall” and “should” carry different legal weight. “The entity shall ensure that those carbon credits are generated under carbon crediting programmes that...” is a due diligence obligation, not a statement of aspiration. Reading §11 in full and translating it into a procurement process and a documentation system is a non-trivial task for a team without specialist carbon market knowledge.
The seven-framework environment compounds this. §11.4 tells you what documents you need. It does not tell you how to draft the VCMI-aligned claim language that goes in those documents. It does not resolve the corresponding adjustments question. It does not cross-reference the ICVCM CCPs by name. And it was written without knowledge of CORSIA eligibility requirements or the SBTi v2.0 consultation draft that will govern how your SBTi commitment interacts with your contribution claim.
The disclosure pack provided with every 360° Impact Portfolio transaction is designed to satisfy §11.4 in full, alongside the parallel requirements of VCMI, ICVCM, DEFRA, and CORSIA where relevant. The aim is that a sustainability manager receives a complete, auditor-ready document rather than a starting point for further internal work. See what the evidence pack contains →
The following summarises how the process applied to every transaction maps to the requirements of §11.2, §11.3, and §11.4. The full methodology is available separately.
Credits are sourced exclusively from Gold Standard and Verra. All are ex-post. Vintage compliance with the five-year limit is confirmed at point of sourcing. Methodology reference and vintage year are recorded per credit batch. Retirement is completed in the client’s name within the 12-month deadline.
Gold Standard and Verra satisfy §11.3(a)–(g) requirements. Both hold ICVCM CCP-Approved status, providing the independently assessed programme-level qualification. SDG mapping is sourced from the registry project record per §11.3(c). Safeguards documentation is referenced per §11.3(b).
Programme name, project ID, methodology reference, project location, tCO₂e per project, vintage year (reductions), and issuance year (credits issued) are recorded for every credit batch and included in the project schedule in the disclosure pack.
The registry retirement certificate is issued in the client’s legal entity name. The direct registry link and serial numbers of every retired credit are included in the disclosure pack. Retirement is completed and confirmed within 14 working days of transaction.
The model disclosure opposite demonstrates how all five §11.4 documented information requirements are satisfied within a single, readable disclosure statement. The references in the model correspond to the documents included in the disclosure pack.
Programme & methodology
Named crediting programme and methodology version cited in the disclosure and detailed in the project schedule.
Project, location & quantity
Named project, country, and tCO₂e retired from each project recorded in the project schedule appended to the disclosure.
Vintage & retirement evidence
Vintage year, issuance year, registry link, and serial numbers of retired credits in the client’s legal entity name. Provided on the retirement certificate.
Model disclosure for illustrative purposes only. Exact wording should be reviewed by legal and sustainability advisers before publication. VCMI-aligned claim language is provided separately in the disclosure pack.
ISO 14068-1 §11 defines the disclosure obligation. Six other frameworks define credit quality, claim language, compliance eligibility, and the science-based transition pathway.
Integrity Council for the Voluntary Carbon Market
Ten threshold requirements a carbon credit must satisfy. The most rigorous programme-level quality assessment available. CCP-Approved status of Gold Standard and Verra satisfies §11.2(e) and §11.3 programme requirements. The primary credit quality framework referenced in the sourcing process.
Voluntary Carbon Markets Integrity Initiative
Governs the public claim language an organisation may use. The VCMI-aligned claim statement included in the disclosure pack sits alongside the §11.4 documentation and addresses the claim framing requirements that ISO 14068-1 does not prescribe in detail.
UK Government · SECR Guidance
Seven criteria for offsets used in SECR reporting. Closely aligned with §11.2 credit criteria. For UK companies, satisfying both simultaneously provides domestic regulatory coverage alongside international standard conformance. The disclosure pack is structured to satisfy both.
International Civil Aviation Organization
Compliance scheme for international aviation. Credits with corresponding adjustments satisfy both CORSIA and §11.1 CA requirements simultaneously. Relevant to aviation-sector clients and the Sovereign Portfolio. Eligibility status per programme included in the disclosure pack where relevant.
University of Oxford · Smith School
Four science-based principles governing net zero-aligned offsetting. The Oxford Principles address the portfolio composition question that ISO 14068-1 §11.1 raises with its removal-credits recommendation — providing the scientific basis for the shift toward higher-durability project types over time.
Science Based Targets initiative · Consultation draft Nov 2025
Emerging standard for corporate net zero including mitigation impact contributions. Integrity principles are aligned with §11.2 credit criteria. Uses “contribution” framing consistent with §11. Does not require corresponding adjustments under its Mitigation Impact Contribution framing.
Every transaction includes a disclosure pack structured to the five documented information requirements of ISO 14068-1 §11.4, alongside VCMI, ICVCM, and DEFRA Good Quality requirements. Credits retired in your legal entity name. Registry links and serial numbers provided. The 30-minute discovery call is the starting point.