The Voluntary Carbon Markets Integrity Initiative Claims Code of Practice, published in June 2023, establishes the conditions under which an organisation may make a credible public claim about its use of voluntary carbon credits. It does not assess whether a credit is high quality — that is the role of the ICVCM Core Carbon Principles. What it governs is the claim itself: who may make one, what conditions must be met before making one, and precisely what may and may not be said. For any organisation intending to communicate its carbon contribution publicly, the VCMI Claims Code is the framework your communications and legal teams need to understand before a single word is approved.
The Voluntary Carbon Markets Integrity Initiative was established to address a problem distinct from the one the ICVCM was created to solve. The ICVCM addresses credit quality: is this tonne real, additional, permanent, and verifiable? VCMI addresses claim quality: given that a company has purchased high-quality credits, what may it say about that in public? These are different questions with different answers, and conflating them is one of the most common sources of greenwashing exposure in corporate sustainability communications.
The Claims Code was developed because voluntary carbon markets had produced a proliferation of unstructured public claims — “carbon neutral,” “net zero,” “climate positive,” “carbon offset” — that varied enormously in what they meant, what evidence underpinned them, and what conditions had been met before they were made. Some claims substituted credit purchases for emission reductions that could and should have been made. Some claims implied neutrality at a level of ambition the underlying credits did not support. Some claimed verification against standards that did not address claim language at all.
The VCMI Claims Code establishes a tiered structure of defined, auditable claims that an organisation may make in proportion to the volume of credits it has purchased, subject to a set of mandatory pre-requisites and due diligence requirements. The framework is explicitly not a carbon neutrality standard — that is ISO 14068-1. It is a contribution claim standard: it governs claims about financing climate action beyond the value chain, framed as contribution rather than compensation. The distinction is material, particularly as greenwashing regulation tightens across UK and EU jurisdictions.
The Claims Code imposes a threshold that must be crossed before an organisation is eligible to make any VCMI claim at any tier. These pre-requisites are not aspirational — they are binary gate conditions. An organisation that does not meet all three may not make a VCMI claim, regardless of the quality or volume of credits it has purchased.
Pre-requisite 1 — A credible near-term science-based emissions reduction commitment
The organisation must have a credible, near-term science-based emissions reduction target, validated by the Science Based Targets initiative or a recognised equivalent body. The target must cover scope 1, 2, and 3 emissions and must be aligned with a 1.5°C pathway. This is the foundational condition that distinguishes a VCMI claim from a compensatory purchase: the organisation is not buying its way out of emission reductions, it is making a contribution above and beyond a reduction commitment it is already obligated to meet. An organisation without a validated near-term SBTi target cannot make a VCMI claim. This pre-requisite alone excludes a significant proportion of companies that currently purchase and retire credits with informal public claims attached.
Pre-requisite 2 — Annual public disclosure of scope 1, 2, and 3 emissions
The organisation must publicly disclose its scope 1, 2, and 3 GHG emissions on an annual basis, aligned with the GHG Protocol Corporate Standard. Disclosure of scope 3 specifically is required — not merely encouraged. This reflects the principle that a contribution claim cannot be properly understood or audited without knowing the baseline of emissions against which it is being made. For SECR reporters, scope 1 and 2 disclosure is already mandatory. Scope 3 disclosure under VCMI goes beyond SECR requirements and requires additional inventory work that many mid-market companies have not yet completed.
Pre-requisite 3 — Demonstrable progress toward the near-term target
The organisation must be making demonstrable progress toward its validated near-term science-based target. Setting a target and purchasing credits is not sufficient; the emission reduction trajectory must be moving in the direction the target requires. The VCMI is explicit that credits are not a substitute for the reductions an organisation has committed to make — they are an addition to them. An organisation that has set an SBTi target but whose emissions are flat or rising cannot make a credible VCMI claim.
The pre-requisite burden for mid-market companies
The SBTi near-term target pre-requisite is the most significant practical barrier for companies in the SECR/ESOS bracket. SBTi target-setting requires a scope 3 emissions inventory, a reduction pathway calculation, and SBTi validation — a process that typically takes six to eighteen months and requires specialist input. An organisation that wants to make a VCMI claim but does not yet have a validated SBTi target should treat target-setting as a parallel workstream, not a pre-condition that delays the decision to purchase and retire credits. Purchasing credits and retiring them in this period is legitimate and generates the registry evidence trail that will be needed once the claim is made.
Before specifying claim tiers, the VCMI Claims Code establishes the due diligence conditions that must apply to every credit used to support a VCMI claim. These are not quality aspirations — they are eligibility conditions. Credits that do not satisfy them cannot be used to support a VCMI claim at any tier.
Alignment with all ten ICVCM Core Carbon Principles
The VCMI explicitly recommends that companies conducting due diligence on carbon credit procurement align their process with all ten ICVCM Core Carbon Principles. This is the most direct statement of the relationship between the two frameworks: VCMI sets the claim standards; ICVCM defines the credit quality standard that the claims rest on. Credits used to support a VCMI claim should be sourced from CCP-Approved programmes — Gold Standard and Verra — or from programmes that can demonstrably be assessed against all ten CCPs. CCP-Approved status provides the most straightforward and publicly defensible basis for satisfying this requirement.
No credits representing reductions within the organisation’s own value chain
Credits must represent GHG emission reductions or removals that are genuinely beyond the organisation’s value chain. Credits generated by projects within the company’s scope 1, 2, or 3 boundary — for example, energy efficiency improvements at a supplier that the company has financed — do not satisfy this requirement. The contribution must be to the global carbon budget, not to the company’s own inventory management. This is the definitional boundary of beyond value chain mitigation.
No substitution for committed reductions
Credits may not be used to offset emissions that the company has committed to reduce as part of its SBTi target. The pre-requisite requirement for a near-term science-based target, and the progress-tracking requirement, both exist to enforce this. The integrity of the VCMI claim rests on the fact that the credits represent mitigation above and beyond what the company is already obligated to achieve in its own operations. Using credits to substitute for those reductions would undermine the entire framework.
No Kyoto-mechanism credits
Credits generated under the Kyoto Protocol mechanisms — Clean Development Mechanism (CDM) and Joint Implementation (JI) — are not eligible for use in VCMI claims. These mechanisms predate current integrity standards and in many cases do not satisfy the ICVCM CCPs, particularly on additionality and baseline credibility. The VCMI restricts eligible credits to those generated under voluntary carbon market programmes that meet current standards. All credits in the 360° Impact Portfolio are sourced from Gold Standard and Verra — voluntary market programmes — not from Kyoto mechanisms.
The three VCMI claim tiers are determined by the volume of credits purchased relative to the organisation’s scope 1, 2, and 3 emissions in the claiming year. Higher tiers require proportionally greater credit volumes. The tier calculation is the organisation’s own responsibility — it is not a service we provide. What we provide is the credits and the documentation that supports whichever tier the organisation determines is appropriate.
How tier is determined
The VCMI Claims Code defines tiers by reference to the volume of high-quality carbon credits purchased and retired in a given year as a proportion of the organisation’s total scope 1, 2, and 3 emissions for that year. The higher the proportion, the higher the tier to which the organisation is entitled to claim. Each tier carries a defined public claim statement — a specific form of words the organisation may use. The organisation may only use the claim language associated with the tier it has achieved; it may not interpolate its own language.
The entry-level contribution claim. The organisation has purchased and retired a defined minimum volume of high-quality carbon credits, satisfying the pre-requisites and due diligence conditions of the Claims Code. Suitable for organisations making their first formal contribution claim or in the early years of their BVCM programme.
The standard for organisations making a VCMI claim in a sustainability report, investor disclosure, or external communication. Requires a substantially greater credit volume than Silver. For most FTSE 350-adjacent companies, Gold is the tier that will satisfy the expectations of sophisticated institutional investors and external assurance providers.
The highest tier. The organisation has purchased and retired credits equivalent to 100% of its scope 1, 2, and 3 emissions in the claiming year, while also maintaining its SBTi-aligned reduction trajectory. Platinum represents full contribution to a net zero global pathway in respect of the organisation’s total annual emissions — it is not a carbon neutrality claim under ISO 14068-1, but the contribution is at the same scale.
Important: tier calculation is the organisation’s responsibility
The volume of credits required to achieve each tier is calculated by the organisation against its own disclosed scope 1, 2, and 3 emissions. This calculation requires the organisation’s annual GHG inventory as the basis. We provide credits of the quality required to support any tier claim, and documentation structured to support the claim. We do not calculate the tier threshold for a client or advise on which tier a client should target. That determination involves the organisation’s own emissions data, financial strategy, and communications positioning. We recommend it be made with specialist sustainability and legal advice.
Making a VCMI claim is not simply a matter of using the correct tier language. The Claims Code requires that the claim be accompanied by specified disclosure information, publicly available and auditor-accessible.
The claim itself
The public claim statement must use the tier-specific language defined in the Claims Code. It must be time-bounded — it applies to a specific reporting year, not the organisation generally. A claim made in a 2025 sustainability report about the 2025 reporting year is conformant; an evergreen claim made without a specific year is not.
Volume, project types, and registries
The disclosure must include the volume of credits purchased and retired (in tCO₂e), the types of projects from which they were sourced, and the registries on which they were retired. This is the information that allows any third party to independently verify that the credits meet the ICVCM CCP due diligence requirement and correspond to the tier claimed. The project schedule in the 360° Impact Portfolio disclosure pack provides this information at the level of detail the Claims Code requires.
SDG co-benefits
The disclosure should include information on the sustainable development co-benefits associated with the projects. The Claims Code references the SDG framework as the basis for co-benefit description. This requirement is satisfied by the SDG mapping sourced from the registry project record and included in the project schedule of the disclosure pack.
Annual reporting and the VCMI register
The Claims Code requires that VCMI claims be reported annually, with updated data for each reporting year. Claims must be registered on the VCMI’s public Claims Register, providing a centralised, publicly searchable record of organisations making VCMI claims and the tiers they have achieved. This register is available for scrutiny by investors, NGOs, regulators, and the public. Registering does not require third-party verification of the claim, but the information submitted must be accurate and consistent with the underlying documentation.
A sustainability manager at a mid-market UK company attempting to make a well-structured contribution claim faces four frameworks simultaneously: SECR as the mandatory reporting floor, ISO 14068-1 as the carbon neutrality standard, VCMI as the contribution claim framework, and SBTi as the reduction target pre-requisite. Each was developed independently, by a different organisation, for a different primary audience, addressing a different slice of the same problem. None of them refers to the others by name in a way that makes the integration intuitive.
The relationship in practice: SECR provides the annual scope 1 and 2 baseline. SBTi extends this into a forward-looking scope 1, 2, and 3 reduction commitment, which satisfies the VCMI pre-requisite. ISO 14068-1 §11 defines the credit criteria and documentation requirements for a carbon neutrality claim. VCMI defines what may be said publicly about the credits purchased against all of that. The ICVCM CCPs sit underneath all four as the credit quality standard that the others reference.
The interactions are not always simple. VCMI and ISO 14068-1 are not the same claim: a VCMI Gold claim is a contribution claim; an ISO 14068-1 carbon neutrality claim is a neutrality claim. They can be made simultaneously and are complementary, but they require different framing, different documentation, and are subject to different levels of scrutiny. A VCMI claim requires VCMI register entry; an ISO 14068-1 neutrality claim may require third-party certification. The wording that satisfies one does not automatically satisfy the other.
Making both claims correctly, simultaneously, against the same underlying credit purchase — while ensuring the ICVCM CCP due diligence is documented, the DEFRA Good Quality criteria are satisfied for SECR purposes, and the scope 3 disclosure required by VCMI pre-requisite 2 is in place — is the practical challenge. The 360° Impact Portfolio disclosure pack is designed to address all of these requirements in a single document, so that the sustainability team has the evidence it needs rather than a map of the territory to navigate independently. See the evidence pack →
The following summarises the process positions relevant to the VCMI Claims Code. Pre-requisite compliance is the client’s responsibility. Tier calculation is the client’s responsibility. What the process provides is the credit quality, the documentation, and the VCMI-aligned claim language draft.
At discovery call stage, we confirm the client’s SBTi status, scope 3 disclosure position, and reduction progress. If pre-requisites are not yet met, we advise on parallel workstreams and begin the credit programme to build the evidence trail ahead of the formal claim.
All credits sourced from Gold Standard and Verra — CCP-Approved programmes. No Kyoto-mechanism credits. No own-value-chain credits. Credits are beyond the value chain by design: all projects are in developing-economy contexts unconnected to the client’s operational boundary.
The disclosure pack includes a VCMI-aligned claim statement drafted to the tier the client has indicated, referencing the specific credits, registries, and volumes. The wording is for legal and sustainability team review before publication. Annual update process is straightforward from the same pack structure.
The project schedule and retirement documentation in the disclosure pack contains all the information required for a VCMI Claims Register entry. The register submission itself is the client’s action; the documentation provides the underlying data.
The model disclosure opposite demonstrates VCMI Gold claim language structured for use in a sustainability report or investor disclosure. It incorporates the required disclosure elements — tier, volume, project types, registries, and annual scope — within the VCMI-defined claim framing.
VCMI Gold
The specific tier is named. The claim is time-bounded to the reporting year. The language does not deviate from the tier-specific wording in the Claims Code.
Credits named and quantified
Volume in tCO₂e, project types, and registry platforms are all disclosed. The detail required for VCMI Claims Register entry is contained within the claim statement itself.
Contribution, not neutralisation
The claim does not assert carbon neutrality or net zero. It frames the credits as a contribution to climate action beyond the value chain, additive to the SBTi reduction commitment.
Model disclosure for illustrative purposes only. Exact wording must reflect the actual tier achieved, actual volumes, and actual project types. Legal and sustainability review required before publication. VCMI Claims Register entry is the client’s action.
The Claims Code defines what you may say. Six other frameworks define the credit quality, the disclosure structure, the UK compliance basis, the aviation compliance requirement, and the science-based transition pathway that together constitute the full evidence chain behind the claim.
Integrity Council for the Voluntary Carbon Market
The ten principles that the Claims Code requires credits to align with. CCP-Approved status of Gold Standard and Verra provides the programme-level quality assurance that the VCMI due diligence requirement references. The foundational credit quality framework.
International Organization for Standardization
The carbon neutrality standard. VCMI claims and ISO 14068-1 neutrality claims can and should be made simultaneously about the same credit purchase, but they require different framing and different documentation. The §11.4 documentation satisfies the evidence requirements that underpin both.
UK Government · SECR Guidance
The UK government’s criteria for offsets in SECR reporting. Meeting VCMI credit due diligence requirements simultaneously satisfies DEFRA Good Quality criteria. For UK companies, the two frameworks are addressed together in the disclosure pack.
Science Based Targets initiative · Consultation draft Nov 2025
The SBTi near-term target is the first VCMI pre-requisite. The emerging SBTi CNZ v2.0 mitigation impact contribution framework is aligned with the VCMI contribution claim framing. An SBTi-committed company making a VCMI claim is operating within a consistent framework across both standards.
University of Oxford · Smith School
The Oxford Principles are referenced by the VCMI Claims Code as a framework for credit quality and portfolio composition. A VCMI claim built on an Oxford Principles-aligned portfolio carries the additional scientific credibility of the Oxford framework alongside the VCMI tier designation.
International Civil Aviation Organization
For aviation-sector clients making both a VCMI claim and satisfying CORSIA obligations, the Sovereign Portfolio provides CA-backed credits that satisfy both simultaneously. CORSIA eligibility is noted in the disclosure pack where relevant to the client’s sector.
Every transaction includes a VCMI-aligned claim statement, CCP-aligned credit sourcing, and a disclosure pack structured to support the Claims Register entry and satisfy parallel ISO 14068-1 requirements. The 30-minute discovery call is the starting point — we will confirm your pre-requisite status and advise on parallel workstreams where needed.