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VCMI’s New Scope 3 Code, Flexibility or Risk in Carbon Credit Use

The Voluntary Carbon Markets Integrity Initiative (VCMI) has introduced a new code to guide how companies can handle Scope 3 emissions—the indirect emissions from a company’s value chain. Called the Scope 3 Action Code of Practice, the proposal allows companies to use high-quality carbon credits to help address gaps in their Scope 3 targets. 

This new approach is attracting both strong support and sharp criticism. While some welcome the extra flexibility, others warn it could delay real climate action. This article explains what the new guidance means, why it matters, and how different stakeholders are responding.

Understanding Scope 3 Emissions

Scope 3 emissions are all the indirect emissions that happen in a company’s supply chain and product use—such as emissions from suppliers, product transportation, or even customer use of a product. For most companies, Scope 3 emissions make up the largest part of their total carbon footprint.

Yet, these emissions are the hardest to control because they come from sources outside the company’s direct operations.

According to the VCMI, the global Scope 3 emissions gap—the difference between actual emissions and what they should be to stay on track with climate targets—is already about 1.4 billion tons of carbon dioxide equivalent.

  • That is roughly equal to the combined 2023 emissions of Germany, the United Kingdom, and Italy. This gap could grow 5x by 2030.

What the VCMI’s Scope 3 Code Proposes

The VCMI’s new Scope 3 code sets clear rules for how companies can use carbon credits to address this emissions gap. Like other frameworks, such as the Science Based Targets initiative (SBTi), the VCMI insists companies must first set science-based targets and prioritize cutting their own emissions. But VCMI goes further by allowing companies to use carbon credits sooner and in larger amounts than SBTi currently allows.

VCMI Scope 3 code of practice
Source: VCMI

Under the code, companies must:

  • Disclose their Scope 3 emissions gap and the steps they are taking to close it.
  • Explain the barriers they face in reducing Scope 3 emissions, describe their strategies to overcome them, and set a clear timeline to close the gap by no later than 2040.
  • Retire (cancel) high-quality carbon credits in an amount equal to their entire emissions gap.
  • Limit their use of credits to no more than 25% of their total Scope 3 emissions in any given year.

The credits used must come from high-quality projects, such as select reforestation initiatives that meet strict standards. The following figure shows the steps companies must follow to comply with the new code. 

VCMI scope 3 code process

Why Some Support the Code

Groups like the Environmental Defense Fund, the We Mean Business Coalition, and the U.K. government have backed the VCMI’s approach. They argue that Scope 3 emissions are so hard to reduce that companies need more flexible tools to stay on track with climate goals.

For many businesses, making deep cuts in Scope 3 emissions requires cooperation across global supply chains, which can take time. Supporters say using carbon credits can help companies show progress while they continue working on direct reductions.

In March 2025, even the Science Based Targets initiative suggested it might recognize the use of carbon credits to address ongoing emissions—although it has not finalized this proposal yet. The VCMI code could give companies clarity and a consistent framework to follow.

Why Others Are Worried

Not everyone is convinced. Many environmental groups and experts warn that allowing carbon credits to cover Scope 3 gaps could weaken corporate climate ambition and slow real emissions cuts.

Lindsay Otis Nilles, a global carbon markets expert at Carbon Market Watch, says:

“VCMI risks undermining its own credibility by allowing companies to present themselves as climate leaders while, in reality, falling behind on their commitments.”

Critics argue that allowing companies to rely on credits until 2040—a date without a clear scientific basis—could disadvantage firms that are already making tough changes to lower their emissions. If both leaders and laggards can make similar claims, it becomes harder for investors, consumers, and regulators to tell which companies are truly reducing emissions.

Thomas Day from the NewClimate Institute agrees:

“The Scope 3 Claim could mislead investors and regulators, allowing companies with ambitious-sounding targets to continue increasing their emissions in the short term.”

Others point out that carbon credits do not remove the need for direct cuts. According to Thea Lyngseth from the Environmental Coalition on Standards (ECOS),

“Investing in carbon credits for Scope 3 instead of reducing emissions at their source only delays real climate action.”

Balancing Flexibility and Integrity

The VCMI says its goal is not to undermine existing standards but to offer a practical tool that reflects real-world challenges. In response to concerns, the initiative stated:

“The intention is not to create divergence, but to offer a pragmatic, high-integrity solution to the difficulty many companies face in reducing Scope 3 emissions at the required pace.”

The VCMI also recommends that target-setting groups like the SBTi adopt a similar approach. However, with no unified global standard yet, companies could face confusion about which rules to follow.

What Comes Next?

The debate over VCMI’s Scope 3 code highlights a bigger question in corporate climate action: How can companies balance the need for fast, deep emissions cuts with the challenges of managing complex global value chains?

For now, companies interested in using the VCMI framework will need to:

  • Carefully document their Scope 3 emissions and reduction plans.
  • Make sure any credits used meet the highest quality standards.
  • Be transparent about how credits are used and how they plan to phase them out over time.

The VCMI’s new Scope 3 guidance adds an important option for companies grappling with indirect emissions. Whether it speeds up or slows down real climate action will depend on how it is used—and how closely its users are held accountable.

The post VCMI’s New Scope 3 Code: Flexibility or Risk in Carbon Credit Use? appeared first on Carbon Credits.

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Carbon Footprint

Insetting vs Offsetting: Which Actually Counts Toward Your Scope 3 Targets

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The accounting differences that decide whether your nature investment shows up in inventory, in BVCM, or nowhere at all.

The question reaches a procurement team about three weeks before the next sustainability committee meeting. Someone has read about insetting. Someone else has just signed off on an offset purchase. The CSO wants to know if the two are interchangeable. The answer is no, and the GHG Protocol Land Sector and Removals Standard is the reason why.

This article walks through what each term means at audit-grade specificity, what the standards actually say about how each gets counted, and how to decide which tool fits which target. The insetting vs offsetting question is one of the most-searched in corporate climate strategy, and one of the most poorly answered. By the end of this piece, you should be able to brief a committee on the difference without notes.

The two definitions, in plain English

Offsetting means buying carbon credits generated outside your value chain and retiring them against your residual emissions. The reduction happens somewhere else, financed by you, and the credit is the receipt.

Insetting means investing in emission reductions or removals inside your own value chain, typically with suppliers, where the reduction is directly linked to the products and services you buy. The reduction happens inside the boundary of your Scope 3 inventory, and the accounting treatment is fundamentally different.

The shorthand from the University of Oxford’s Nature-based Insetting Initiative is useful: insetting is what you do with the supply chain you have; offsetting is what you do with the supply chain you do not have.

What the GHG Protocol Land Sector Standard actually says

The GHG Protocol Land Sector and Removals Standard, finalised in 2024 after a multi-year pilot, sets the rules for how land-based emission reductions and removals enter corporate inventories. The Standard distinguishes between inventory accounting (Scope 1, 2, and 3) and project or intervention accounting (a separate methodology for crediting).

For insetting, the practical implication is that supplier-level interventions, when properly measured and attributed, can reduce your Scope 3 category 1 (purchased goods and services) emissions in your inventory. The reduction is not a credit retired against the inventory; it is a lower inventory number, period.

For offsetting, the credit is retired separately. It can be reported as a contribution toward a net-zero claim under the SBTi Beyond Value Chain Mitigation framework or as part of a VCMI Carbon Integrity claim, but it does not lower the inventory number.

A practical consequence: if your Science Based Target requires a 50% absolute reduction in Scope 3 emissions by 2030, insetting moves you toward the target. Offsetting does not. This single point of difference reshapes the procurement decision.

When insetting counts toward Scope 3 (and when it does not)

Insetting counts toward Scope 3 only when several conditions are met:

  • The intervention must occur with an entity in your value chain.
  • The emissions reduction or removal must be measured against a defensible baseline.
  • The reduction must be attributed to your share of that supplier’s output, not double-counted with other buyers.
  • It must follow the inventory accounting rules in the GHG Protocol Land Sector Standard, not the project accounting rules used to generate credits.

The most common failure mode is double counting. If your supplier sells the same reduction as a credit on the voluntary market and also reports it to you as a Scope 3 reduction, the math breaks. The Standard requires you to address this risk, typically by purchasing and retiring the supplier-issued credit as part of your inventory or by contractual provisions that prevent the supplier from selling the reduction twice.

When insetting does not count toward Scope 3: when the intervention sits with a supplier you do not buy from, when the baseline is not defensible, when the attribution is unclear, or when the documentation does not survive audit. Those cases default to Beyond Value Chain Mitigation, which is still useful but operates on a different ledger.

The procurement and supplier engagement question

Insetting is harder than offsetting. That is the unfashionable truth most buyers eventually confront. Offsetting is a transaction; insetting is a relationship.

To run an insetting program, you need supplier mapping precise enough to know which farms or facilities sit at which Scope 3 boundary. You need an engagement model that gets suppliers to participate, which usually requires multi-year commitments and shared economics. You need an MRV architecture that measures the right things and produces audit-ready documentation. And you need a contractual structure that prevents double counting and protects both sides.

The trade-off you receive in return is significant. Reductions count against your inventory rather than your residual. Supplier relationships deepen, which protects sourcing continuity. Yield and quality improvements often follow regenerative interventions, which reduces your input cost over time. And the regulatory file, under CSRD, CSDDD, EUDR, and the SBTi FLAG Guidance, is materially stronger.

Choosing the right tool for the right target

A practical decision rule. If your target is a science-based Scope 3 reduction and you operate in a FLAG sector or source FLAG commodities, insetting is the structurally correct tool. If your target is a net-zero claim that includes neutralising hard-to-abate residual emissions outside your value chain, BVCM via high-integrity offsets is the structurally correct tool. Most companies with material Scope 3 exposure need both, in different proportions, sequenced over time.

The sequencing matters. Insetting takes longer to stand up but produces a permanent reduction in the inventory. Offsetting can be transacted faster but does not change the inventory and now sits under tighter claim restrictions. Treat them as complementary tools with different jobs, not as substitutes. The Accountability Framework Initiative and the IUCN Global Standard for Nature-based Solutions both provide useful guardrails for the insetting side, with biodiversity, human rights, and benefit-sharing requirements that go beyond carbon math.

If you are mapping a Scope 3 reduction roadmap and need to scope which interventions count toward your inventory versus which sit in Beyond Value Chain Mitigation, the carbon and sustainability experts at Carbon Credit Capital can help you structure a nature-based supply chain investment program that fits your FLAG exposure, your target architecture, and your audit horizon. Schedule a consultation.

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Carbon Footprint

Net zero needs nature: a carbon credit guide

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Net zero is often described as a balancing act: cut what you can, account for the rest, and reach zero on the ledger. That framing is useful, but it leaves something out. It treats every tonne of carbon as interchangeable and every route to zero as equally sound, while the science tells a more specific story.

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Carbon Footprint

Deforestation in Malawi: causes and solutions

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Malawi has lost a striking share of its forests over the past three decades. Woodlands that once covered well over a third of the country now cover less than a quarter, and the pressure on what remains is increasing. Behind those figures sit two practical questions: what is driving the loss, and what reverses it?

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