Carbon Markets Advisory

Carbon credits are the most debated climate tool and the easiest one to misuse. Chosen well, they finance real climate impact beyond your value chain; chosen badly, they create reputational and legal risk. In 2026 the rules became much clearer: the SBTi Corporate Net-Zero Standard V2.0 redefined where credits fit, the EU adopted its first certification methodologies for permanent carbon removals, and in Türkiye the Climate Law and the TR ETS Regulation began to set a domestic framework for carbon credits.

Alalëa's carbon markets advisory helps companies use these instruments in the right place, in the right quantity and with the right claim. Our founder, Göker Avcı, also leads CDR Türkiye, an initiative working on carbon removal, so we follow the technical and market side of removal projects closely. This page is written for sustainability, procurement and legal teams at multinational companies, EU buyers considering credits or removals from Turkish projects, and companies in Türkiye building their first credit strategy.

Compliance and voluntary markets

Carbon markets split into two branches. Which branch you are in determines the instrument and the rules.

There are bridges between the two. Türkiye's Climate Law defines offsetting as the use of carbon credits under the ETS or in voluntary commitments. The TR ETS Regulation provides that credits from projects within Türkiye may be used for allowance surrender, up to a ratio to be set by the Carbon Market Board. As of October 2026 we had not found a decision setting that ratio. For TR ETS obligations, see our ETS readiness page.

To understand how the voluntary market works, it helps to separate the actors. The project developer runs the reduction or removal activity. The carbon-crediting programme (for example Verra VCS or Gold Standard) approves methodologies, sets rules and issues credits in its own registry. An independent validation and verification body validates the project design and verifies the reductions or removals achieved. The buyer purchases the credit and has it retired in its own name; a retired credit cannot be sold again. Brokers and platforms may sit in between. A credit is only as credible as the transparency and traceability of each link in this chain, so a purchase decision should look at every link, not just the project name.

CBAM certificates are a separate category: they are neither allowances nor credits, but non-transferable instruments an EU importer buys against the embedded emissions it declares. Details are on our CBAM readiness page.

Credit quality: what to look for

Every carbon credit claims to represent one tonne of CO₂ equivalent, but the robustness behind that claim varies widely between projects. Our core framework for carbon credit due diligence is the ten Core Carbon Principles (CCPs) of the Integrity Council for the Voluntary Carbon Market (ICVCM):

Programmes that pass assessment can apply the CCP label to credits from approved categories. The label is a good threshold, but not enough on its own. In practice we focus hardest on three principles:

• Additionality: would the project have happened without credit revenue? Credits from activities that are legally required, already profitable or common practice tend to fail this test.
• Permanence: how long will the stored carbon stay stored, and how is reversal risk managed? Natural stores such as forests and soils can be released by fire, drought or land-use change; geological storage and mineralisation last far longer. The contract should state who compensates a reversal, and how.
• No double counting: is the same tonne counted both in the host country's national target and in the buyer's claim? For international transfers under the Paris Agreement, this is prevented by a corresponding adjustment.

Beyond these, we look at whether the baseline is conservative, leakage risk, the quality of monitoring data, the vintage, the rights of and safeguards for local communities, and the project's public documentation.

Removals and avoidance: not the same tonne

Most credits in the voluntary market are avoidance or reduction credits: they represent emissions that would have occurred without the project but did not. A removal credit represents CO₂ actually drawn down from the atmosphere and stored.

This distinction drives what a company can claim. A tonne of avoidance does not take back a tonne the company itself emitted; it helps prevent a tonne being emitted somewhere else. A removal can physically balance an emitted tonne. The GHG Protocol's Land Sector and Removals Standard, published in January 2026, likewise allows removals into an inventory only with safeguards such as data quality, traceability and ongoing monitoring of storage. For a deeper look at removal pathways, see engineered versus nature-based carbon removal.

The EU removals certification framework: CRCF

With Regulation (EU) 2024/3012, the EU created the Carbon Removals and Carbon Farming Certification Framework (CRCF). The framework is voluntary and covers permanent carbon removals, carbon farming and carbon storage in products. On 3 February 2026 the Commission adopted the first certification methodologies, covering three permanent removal activities: direct air capture and storage, capture and storage of biogenic emissions, and carbon removal through biochar. According to the Commission, the methodologies define how a tonne of removal is counted, how permanence is ensured and how risks such as leakage and liability are managed. The Commission also announced an EU Buyers' Club for permanent removals and carbon farming.

The CRCF places no direct obligation on Turkish companies. But for anyone running carbon removal procurement, or considering biochar or biogenic CO₂ capture projects in Türkiye, it is a strong quality reference. We recommend adding one question to purchase criteria: has the certification scheme been recognised under the CRCF?

Türkiye's carbon crediting framework

In Türkiye, the legal basis for carbon credits is the Climate Law. It defines a carbon credit as a credit expressed in tonnes of CO₂ equivalent and leaves the details of a national carbon crediting and offsetting system to the Climate Change Presidency. Article 11 requires domestic project owners active in voluntary carbon markets to register their projects in the carbon credit registry within a period set by the Presidency. If project data proves inaccurate or untrue, the related offset amount cannot be used for ETS surrender.

On 1 August 2025 the Presidency opened the draft Türkiye Carbon Crediting and Offsetting Regulation for consultation. The draft names credits generated in the Türkiye Carbon Offsetting System Turkuaz Kredi, assigns issuance and tracking to the Turkish Standards Institution (TSE), provides for two separate registries and requires a corresponding adjustment for credits under the Paris Agreement. Under the draft, projects must not have generated credits under another international programme and must not have received a YEK-G certificate or similar energy certificate.

It is important to stress that this is a draft. As of October 2026 we had not found a text showing that the regulation has been published in the Official Gazette, and the final provisions may differ from the draft. For foreign buyers this means that any credit sourced from a Turkish project should be checked against both the Climate Law's registration requirement and the direction of the national rules at the time of purchase.

Credits in SBTi V2.0 and beyond value chain contribution

The SBTi Corporate Net-Zero Standard V2.0, published in June 2026, clarified the role of credits:

• They do not count toward targets. Carbon credits are not part of the hierarchy used to implement targets (activity level, activity pool, sector level). Progress is measured by change in the physical inventory.
• OER replaces BVCM. The V1.3.1 recommendation on beyond value chain mitigation (BVCM) becomes the ongoing emissions responsibility (OER) framework in V2.0. Until 2035 there is a three-tier voluntary recognition programme: Engaged (at least 1% of ongoing emissions), Advanced (100% of Scope 1 and 2 and at least 10% of the total) and Leadership (100%). Each company states at validation whether it will join the programme and, if not, explains why.
• From 2035. Category A companies are expected to support eligible carbon removals equal to at least 1% of their ongoing emissions, rising linearly to 100% by the net-zero year. SBTi notes that this provision will be revisited in the next major revision.
• In the net-zero year. All residual emissions are neutralised; residuals from long-lived gases should be matched with long-lived removals.

For a company with an SBTi target, this places credits in two roles: today, contribution beyond the value chain; later, steadily growing support for removals. For target setting itself, see our SBTi target setting service and our note on current points in the SBTi process.

Five rules for using credits responsibly

1. Reduce first. Credits do not replace a plan to cut your own emissions. Buying credits without a reduction roadmap is what leaves a "carbon neutral" claim most exposed.
2. Match the claim to the instrument. A "contribution" claim fits avoidance credits better; a "neutralisation" claim fits removals. Broad claims such as "carbon neutral product" must state which emissions were balanced, with which credits, for which period.
3. Be transparent. The credit's programme, project name, registry serial number, vintage and retirement record should be public. If you cannot show the credit was retired in your name, you cannot make the claim.
4. Keep the inventory separate. Credits are not deducted from your emissions inventory; they are reported separately. Inventory change supports reduction claims; credits support contribution or neutralisation claims.
5. Shift the portfolio toward removals over time. Given SBTi's OER timeline and net-zero rules, it makes sense to plan for an avoidance-heavy portfolio today to increase its share of permanent removals over the years.

The practical questions to ask in procurement follow from these rules. Which programme is the credit registered in, and in whose name will it be retired? Are the project documents and verification reports public? What is the compensation mechanism if a reversal occurs? If the credit comes from a project in Türkiye, has the national registration requirement been met? If an international transfer is involved, is there a corresponding adjustment? A credit for which you cannot get written answers to these questions cannot carry your claim.

It also matters not to confuse renewable energy certificates with carbon credits: YEK-G and similar certificates are used in Scope 2 accounting and are not credits. See how to use renewable energy certificates and market-based versus location-based Scope 2.

What we offer

Strategy

We look at your emissions profile, reduction roadmap, targets (including SBTi) and stakeholder expectations together to define where credits fit in your strategy: for what purpose, of what type, on what timeline. Where not using credits is the better answer, we say so plainly.

Due diligence

We review the projects you are considering against the ICVCM principles, the relevant programme rules and the project documentation: additionality case, baseline, quantification and monitoring, permanence and reversal management, double counting risk, safeguards and registration status. For projects in Türkiye we also check the Climate Law's registration requirement and the direction of national rules. The output is an assessment note for each project setting out risks and open questions.

Portfolio design and carbon removal procurement

We build a balanced portfolio across avoidance and removals, natural and technological storage, and shorter and longer permanence. We define purchase criteria, supplier selection and the safeguards a contract should include (delivery, reversal, retirement, document sharing), and plan how the portfolio should change over the years in line with the SBTi OER timeline and your net-zero year.

Claims and communication

We co-write the wording you will use in corporate reports, product labels and marketing so that it stays consistent with the instruments you hold. We prepare an evidence file showing which claim rests on which proof, and make sure credits are presented separately from the inventory in your reporting.

Project side

If you wonder whether your own operations or land could host a carbon project, we run a preliminary assessment of additionality, measurability, permanence and national registration requirements. If you are covered by the TR ETS, we include the possibility of using domestic credits for surrender in that assessment.

The main factors that determine how long this takes are the number of projects to assess, the accessibility of documentation, the complexity of your target and claim structure, and your procurement timeline. Market terms used on this page are explained in our carbon market terms glossary.

Why now?

Global quality thresholds for credits, EU removals certification and SBTi's new rules all became clear in the same period, while Türkiye's national registry and crediting regulation are on their way. A credit bought today will have to be defended against all of these rules within a few years. Asking the right questions before buying is far easier than withdrawing a claim later.

To review your credit strategy, the projects you are considering or your existing claims with Alalëa, reach us through our contact page. If you do not yet have a reduction plan, a decarbonization strategy gives your credit decisions a solid foundation.