This article was originally published by Carbon Herald on April 28, 2026.
By David LaGreca, managing director of Carbon Markets at EcoEngineers
By the time a carbon dioxide removal (CDR) credit reaches the voluntary carbon market (VCM), it has already passed through an increasingly rigorous set of reviews. Beyond questions of technology or permanence, today’s market puts growing emphasis on how assumptions are tested, data is scrutinized, and projects respond to sustained challenges.
This increased scrutiny is often described as a “quality problem.” In reality, it reflects a maturing market. As buyers, investors, registries, and verifiers apply deeper diligence to minimize risks as much as possible (knowing unknowable risks will always arise), the quality of carbon removal is no longer a static label. It becomes an outcome achieved through process.
The result is a VCM that demands more from projects while providing clearer signals about what credible, investable carbon removal looks like.
From Methodologies to Market Scrutiny
A few years ago, having a credible methodology was often enough to move a project forward. Developers focused on demonstrating that approaches such as bioenergy with carbon capture and storage (BECCS), direct air capture (DAC), or soil carbon mineralization could plausibly remove carbon. Registries validated methodologies, verifiers confirmed conformance, and buyers largely accepted those outcomes.
That era has ended.
Since roughly 2022, trust deficits in the VCM have shifted the center of gravity from registries to buyers. Today, a project may clear registry validation and third-party verification and still fail to secure offtake. Buyers now conduct their own diligence processes or contract with a third-party consultant for diligence, often lasting months, re-examining baseline assumptions, modeling choices, monitoring systems, land-use impacts, governance, and political or reputational risk.
The result is a layered diligence environment in which projects must satisfy multiple stakeholders, each with distinct expectations and incentives.
What Robust Diligence Looks Like in Practice
Despite this fragmentation, a clearer diligence pathway is beginning to emerge. While specifics vary by technology and buyer, high-quality CDR projects increasingly follow a common review sequence that extends beyond registry approval.
- Scientific and technical feasibility. This forms the foundation. Projects must demonstrate that their underlying science is credible at a relevant scale and supported by peer-reviewed research or pilot data. Early feasibility assessments help identify red flags before they become costly setbacks. This step is exceptionally important for projects deploying any first-of-its-kind technology, chemistry, or process.
- Methodology alignment. It’s important that project developers understand that standards and methodologies evolve over time, and that they should aim for the highest attainable bar rather than optimizing for the status quo.
- Baseline integrity. Whether adapting an existing registry methodology or working within a newer carbon removal standard, projects must show that baselines reflect a credible “no-project” scenario and that crediting assumptions are conservative. Inflated baselines remain one of the fastest ways to lose buyer confidence.
- Project design and documentation. This translates assumptions into formal plans. Clear, internally consistent documentation that covers system boundaries, monitoring plans, and data management supports validation and reduces friction during downstream reviews.
- Independent validation and verification. Conducted under International Organization for Standardization (ISO)-aligned requirements, these assessments confirm that projects conform to their chosen methodologies and that claimed removals are supported by evidence. At the same time, verification and credit issuance are no longer tightly coupled to immediate purchase in the voluntary carbon market. Recent market data illustrates the shift: Puro.earth reported that suppliers issued about 650,000 CO₂ Removal Certificates (CORCs) in 2025 while only 344,026 were retired, meaning issuance was roughly 1.9 times retirements for the year. This growing gap reflects a market increasingly driven by forward offtake agreements and future supply reservations rather than spot purchases. Verification therefore remains a critical independent checkpoint for credibility, even as issuance itself no longer guarantees immediate buyer activity.
- Buyer and investor diligence. Buyers frequently revisit earlier assumptions, interrogate monitoring and reporting systems in greater depth, and evaluate risks ranging from permitting to long-term storage integrity. Projects that have prepared for this scrutiny upstream tend to move through it more efficiently. In other words, project developers should seek out additional scrutiny at the design phase, prior to kicking off the formal registration process with registries.
- Ongoing monitoring and re-verification. Diligence does not end at first issuance; it must continue over time. Annual or periodic verification and responsiveness to evolving expectations have become defining features of durable projects.
The Stabilizing Role of Verification
One paradox of today’s market is that third-party verification, the only step governed by formal ISO accreditation and independence requirements, is often treated as secondary. Yet verifiers are uniquely positioned to identify structural weaknesses in project design, unrealistic timelines, or gaps in monitoring that can later derail buyer diligence.
When engaged early, verification can function as market preparation rather than a box-checking exercise, helping projects anticipate the questions that will ultimately determine commercial success. Often, issues that arise in verification are sure to arise in diligence. Major changes to the project during verification are going to spook buyers. The key is not to rush verification and to de-risk before engagement.
Common Failure Points
Across technologies, several patterns recur when projects struggle to advance. These include overly aggressive timelines that underestimate the duration and cost of diligence; underinvestment in monitoring, particularly digital systems that buyers increasingly expect; reliance on single-track monitoring approaches that fail to satisfy different reviewer preferences; and late engagement with verification experts, which can force redesigns at the worst possible moment.
These are rarely scientific failures. More often, they are process failures and/or misjudgments about how the market now evaluates credibility.
Toward a More Coherent Diligence Ecosystem
If the voluntary carbon market is to scale credibly, diligence must become more predictable without sacrificing rigor. That does not require lowering standards. It requires aligning expectations across registries, verifiers, buyers, and investors so that quality is not re-litigated from scratch at every stage.
For developers, this means treating diligence as a core development activity rather than a downstream compliance task. For buyers, it means recognizing how bespoke requirements shape market participation. For the market, it means acknowledging a simple truth: quality is not a label. It is a process.
About the Author
David LaGreca is the managing director of Carbon Markets Services, EcoEngineers, an LRQAcompany, with experience in all major greenhouse gas (GHG) programs across the Americas. Mr. LaGreca has brought projects through every phase, from conception through financing, methodology development, project registration, and verification. He has worked on hundreds of diverse projects, including reforestation, energy, methane abatement, blue carbon, and novel carbon removal technologies. He has developed and audited GHG inventories for communities, companies, and governments. Mr. LaGreca works to strategically align projects with markets to make decarbonization a viable business
