VCMI Claims Code of Practice — The Definitive Reference
For a decade, “carbon neutral” meant whatever the company saying it wanted it to mean. A firm could buy the cheapest available credits, cover its full footprint on paper, and market the result as climate leadership — with no requirement to cut its own emissions first, disclose what it bought, or prove the credits represented anything real.
The VCMI Claims Code of Practice exists to make that sentence indefensible.
The VCMI Claims Code of Practice is the demand-side rulebook for how companies credibly use carbon credits. It defines Silver, Gold, and Platinum “Carbon Integrity Claims” — tiered by the share of remaining emissions a company offsets after cutting them first.
1. What the VCMI Claims Code Is
The Voluntary Carbon Markets Integrity Initiative (VCMI) is a multi-stakeholder body launched in July 2021, originally funded by the UK government and the Children’s Investment Fund Foundation, to drive integrity on the demand side of the voluntary carbon market. Its central output is the Claims Code of Practice: a set of requirements, recommendations, and supporting guidance for how a company can credibly buy and use carbon credits, and — critically — what it is permitted to say about having done so.
The distinction between demand and supply is the single most important thing to understand about VCMI’s place in the landscape. The voluntary carbon market has two integrity problems, and they require two different rulebooks:
Supply side — is the credit real?
Governed by the Integrity Council for the Voluntary Carbon Market (ICVCM) and its Core Carbon Principles. This is the question of whether a tonne of claimed mitigation actually happened: additionality, permanence, accurate baselines, no double counting. See the ICVCM Core Carbon Principles reference.
Demand side — is the buyer honest?
Governed by the VCMI Claims Code of Practice. This is the question of whether a company that buys high-quality credits is using them in addition to genuine decarbonisation — not as a substitute — and is describing that use truthfully. This is the subject of this page.
VCMI and ICVCM are deliberately complementary. A defensible carbon credit claim requires both: a high-quality credit (ICVCM’s domain) used inside a high-integrity corporate claim (VCMI’s domain). A VCMI Carbon Integrity Claim made with low-quality credits is not credible; high-quality credits used to mask the absence of real emission cuts are not credible either. The Claims Code is built to close the second gap.
Carbon credits must increase overall global mitigation, not substitute for a company’s own emission reductions. Under VCMI, a company qualifies to make a claim only after it has set science-aligned near-term targets and demonstrated progress toward them. Credits sit on top of decarbonisation; they never replace it.
2. Where It Sits in the Integrity Stack
VCMI does not operate in isolation. The Claims Code explicitly builds on and references a stack of adjacent standards. Understanding which body governs which decision prevents the common error of treating VCMI as a standalone net-zero programme — it is not. It is the claims-and-communications layer that sits on top of measurement, target-setting, and credit-quality standards owned by others.
The Claims Code draws directly on a recognised body of prior work, which it cites as its intellectual foundation: the Carbon Pricing Leadership Coalition’s Task Force report, the full suite of SBTi target-setting guidance, Gold Standard’s Scope 3 Value Chain Interventions guidance, the Oxford Principles for Net-Zero Aligned Carbon Offsetting, the UN Secretary-General’s High-Level Expert Group recommendations (“Integrity Matters”), and the GHG Protocol Corporate Value Chain (Scope 3) Standard. VCMI positions itself as the operational layer that turns those principles into a usable, claimable framework.
3. Version Lineage — Provisional to v3.1
The Claims Code has evolved substantially since its provisional release. Several widely circulated third-party explainers still describe the 2023 version; a methodology citation must specify the version in force at the time of the claim, because both the tier definitions and the Foundational Criteria have changed across releases.
| Date | Version | What changed |
|---|---|---|
| June 2022 | Provisional Claims Code | Public consultation draft. Road-tested with roughly 70 companies. Used a Bronze / Silver / Gold tier structure. |
| June 2023 | v1 (final) | First full release. Dropped the “Bronze” / “on-ramp” entry tier; renamed the tiers Silver / Gold / Platinum. Established the four-step claim process. |
| November 2023 | v2 | Added the Monitoring, Reporting and Assurance (MRA) Framework, the “Carbon Integrity” brand and mark, and a beta Scope 3 Flexibility Claim. Released ahead of COP28. |
| August 2024 | v2.1 | Consolidation and clarification release. |
| April 2025 | v3.0 | Major revision. Changed the Foundational Criteria (see §5.5). Published the standalone Scope 3 Action Code of Practice, superseding the beta Flexibility Claim. MRA Framework updated to v1.3. |
| August 2025 | v3.1 (current) | Current operative version. Accompanied by MRA Framework v1.4. The version this page documents. |
A claim made in 2024 was governed by v2.1 and its original Foundational Criteria, which required a public net-zero commitment. A claim made from mid-2025 onward is governed by v3.0/v3.1, under which the public commitment was downgraded to a recommendation. Stating “made under the VCMI Claims Code” without the version is insufficient for assurance — cite the version and release date.
4. The Carbon Integrity Claim Tiers
The headline feature of the Claims Code is its three-tier structure for Carbon Integrity Claims. Each tier is defined by the proportion of a company’s remaining emissions that it covers with high-quality carbon credits, after it has met or demonstrated progress toward its near-term science-aligned targets. The tiers are sequential levels of ambition, not categories of company.
| Tier | Credits retired (share of remaining emissions) | Signal |
|---|---|---|
| Silver | ≥ 20% and < 60% | Entry-level integrity claim. The company is offsetting a meaningful minority of what remains after cuts. |
| Gold | ≥ 60% and < 100% | Substantial coverage of remaining emissions on top of decarbonisation. |
| Platinum | ≥ 100% | The apex tier. Credits cover all remaining emissions and finance mitigation beyond them. |
Several third-party explainers quote the tiers as Silver 10–50% and Gold 50–100%. Those figures trace to early provisional-draft material and are not the operative thresholds. The current Claims Code uses Silver 20–60%, Gold 60–100%, and Platinum 100%-or-more of remaining emissions. When in doubt, the VCMI primary document governs.
4.1 What “Remaining Emissions” Means
The tier percentages are not applied to a company’s gross footprint. They apply to remaining emissions — the emissions left in the most recent reporting year after the company has acted on its near-term reduction targets. This is the mechanism that prevents a company from buying its way to a high tier without cutting anything: the denominator itself shrinks only through real decarbonisation, and a company that has not progressed on its targets does not qualify to make any tier of claim at all.
Emissions covered span Scope 1, Scope 2, and Scope 3 as reported under the GHG Protocol or an equivalent national inventory methodology. For the meaning of these boundaries see the Scope 3 emissions glossary entry and the CO2e definition.
4.2 Worked Threshold Example
Consider a company whose most recent reporting year, after acting on its near-term targets, leaves 500,000 tCO2e of remaining emissions across all scopes. The credit volume required for each tier is:
| Tier | Threshold | Credits to purchase and retire |
|---|---|---|
| Silver (minimum) | 20% of 500,000 | 100,000 tCO2e |
| Gold (minimum) | 60% of 500,000 | 300,000 tCO2e |
| Platinum (minimum) | 100% of 500,000 | 500,000 tCO2e |
This is a “ton-for-ton” approach: one credit, representing one tonne of CO2e of mitigation achieved outside the company’s value chain, is matched against one tonne of remaining emissions. The credits must represent emission reductions and/or removals from outside the value chain — credits cannot be drawn from the company’s own Scope 3 interventions, which belong to inventory accounting, not to a Carbon Integrity Claim.
4.3 The Annual Escalation Rule
A Carbon Integrity Claim is not a one-off purchase. The Claims Code requires that the proportion of remaining emissions covered by credits increase each year following a Silver or Gold claim. The intent is a ratchet: a company that enters at Silver is expected to climb toward Gold and Platinum over time, while its absolute remaining emissions fall through continued decarbonisation. A flat or declining coverage ratio year-on-year is inconsistent with the Code’s ambition principle.
5. The Four Foundational Criteria
Before a company can make any tier of Carbon Integrity Claim, it must satisfy a set of Foundational Criteria. These are the gate. They ensure that credit use sits on a base of genuine measurement, target-setting, and disclosure — not in place of it. The criteria were materially revised in the April 2025 (v3.0) release; the descriptions below reflect the current v3.1 position.
5.5 What Changed in the 2025 Revision
The April 2025 revision adjusted the Foundational Criteria to lower barriers to entry while preserving the science-aligned core. VCMI framed the changes as aligning with evolving best practice and providing routes for companies focused on immediate near-term action. The substantive shifts:
| Element | Before (v2.1 and earlier) | After (v3.0 / v3.1) |
|---|---|---|
| Inventory methodology (FC1) | GHG Protocol | GHG Protocol or national inventory methodologies adapted from it |
| Public net-zero commitment | Required | No longer required; downgraded to a recommendation |
| Long-term target setting | Expected | Becomes a recommendation, to prioritise near-term action |
| Target validation route | Effectively SBTi process | Broadened to any credible science-aligned framework, third-party validation recommended |
Dropping the mandatory public net-zero commitment is the most debated element of the 2025 revision. VCMI’s position is that it removes a barrier to entry without weakening the requirement that targets be net-zero-aligned. Critics argue a recommendation carries less accountability than a requirement. A company citing the Code should be explicit about which version’s criteria it met, since the bar differs materially between v2.1 and v3.1.
6. The Four-Step Claim-Making Process
For a company seeking an enterprise-wide Carbon Integrity Claim, the Code defines a four-step process. This structure has been stable since the first full release in 2023, even as the detail within each step has evolved.
Report enterprise-wide emissions, set near-term science-aligned targets, maintain a net-zero-aligned trajectory, and disclose transparently. This is the eligibility gate — without it, no claim of any tier can be made.
Choose the tier — Silver, Gold, or Platinum — based on the share of remaining emissions the company is prepared to cover, or elect the Scope 3 Action route (see §8). Tier selection sets the credit volume required at step 3.
Purchase and retire high-quality carbon credits — emission reductions and/or removals from outside the value chain — in the volume the selected tier requires, meeting the Code’s quality criteria (see §7).
Have the claim independently verified under the MRA Framework before it is communicated publicly. Verification confirms the underlying information is evaluated, evidenced, and assured (see §9).
The order is not arbitrary. Eligibility precedes selection; selection precedes purchase; purchase precedes verification; verification precedes communication. A company that buys credits first and asks whether it qualifies afterward has the process backwards — and under the Code, cannot make a compliant claim.
7. High-Quality Carbon Credits — Use and Quality Thresholds
A Carbon Integrity Claim is only as credible as the credits behind it. The Claims Code does not itself define what makes a credit high-quality at the project level — that is the supply-side question owned by the ICVCM Core Carbon Principles and operationalised through programmes such as the Verra Verified Carbon Standard and Gold Standard. VCMI instead specifies how those credits must be used.
| Requirement | What it means in practice |
|---|---|
| Outside the value chain | Credits must represent mitigation achieved beyond the company’s own value chain. Reductions inside the value chain belong to the Scope 1/2/3 inventory and cannot be double-counted as a credit. |
| Reductions and/or removals | Both avoided/reduced emissions and carbon removals are eligible. VCMI’s position is that removals are essential but must not undermine the financing of reduction and avoidance credits. |
| Retired, not just purchased | Credits must be retired on the company’s behalf in a registry. A purchased-but-unretired credit does not support a claim. |
| High-quality, third-party verified | Credits should meet recognised quality criteria — the ICVCM Core Carbon Principles are the reference benchmark for high quality on the supply side. |
The balance between avoidance/reduction credits and durable removals is one of the most actively discussed questions in the market. The Code permits both. Companies anticipating a future tilt toward removals — driven by net-zero standards that increasingly emphasise durable carbon storage — often weight their portfolios accordingly. For the removals accounting context see the GHG Protocol Land Sector and Removals Guidance.
8. The Scope 3 Action Code of Practice
In April 2025, VCMI published the Scope 3 Action Code of Practice as a standalone companion to the Claims Code. It is the finalised successor to the beta “Scope 3 Flexibility Claim” that VCMI had floated in November 2023. The Scope 3 Action Code addresses the single hardest problem in corporate decarbonisation: value-chain emissions a company does not directly control.
8.1 The Problem It Addresses
For most companies, Scope 3 is the largest and least tractable part of the footprint. The barriers are structural: limited control over indirect suppliers, high cost and limited availability of low-carbon alternatives, and persistent data gaps. A company can be acting in good faith and still fall behind its science-aligned Scope 3 trajectory because the levers sit outside its direct authority. The result is a widening “Scope 3 emissions gap” — the difference between where a company’s Scope 3 emissions are and where its target pathway says they should be.
8.2 How the Scope 3 Action Code Works
The Scope 3 Action Code lets a company use high-quality carbon credits, on a time-limited basis, to close the gap between its current Scope 3 emissions and its science-aligned Scope 3 target — while it works to remove the underlying barriers and get back onto its decarbonisation pathway. It is explicitly a bridge, not a destination: the intent is to keep momentum and channel finance into mitigation during the period a company is structurally unable to cut value-chain emissions fast enough.
8.3 The Guardrails
Because a flexibility mechanism is inherently open to misuse, the Code surrounds it with guardrails:
The company must demonstrate meaningful progress on its own Scope 1 and Scope 2 reductions. The Scope 3 route does not excuse inaction on directly controlled emissions.
Credit use is capped — in the beta design, not exceeding 50% of Scope 3 emissions — and the cap declines year on year, forcing a return to direct reductions over time.
The mechanism is designed to be temporary, with credit use phased out on a path consistent with reaching the science-aligned target through internal decarbonisation.
A Scope 3 Action claim does not bypass the gate. The company must still meet the Foundational Criteria and report transparently under the MRA Framework.
The Scope 3 mechanism attracts the sharpest criticism of anything VCMI publishes. Analysts at the NewClimate Institute argued the beta Flexibility Claim could let companies treat ambitious 2030 Scope 3 targets as effectively optional, substituting credits for value-chain cuts that would otherwise drive real-economy change. VCMI’s counter-position is that the guardrails — direct-emissions progress, a declining cap, and a phase-out — keep the mechanism a bridge rather than an exit. This is a genuine, unresolved disagreement among credible parties, and a company using the Scope 3 route should expect scrutiny and document its barriers carefully. For the underlying accounting boundary see the GHG Protocol Scope 3 Standard.
9. The MRA Framework — Monitoring, Reporting and Assurance
The Monitoring, Reporting and Assurance (MRA) Framework, currently at v1.4 (August 2025), is the verification engine behind every VCMI Claim. Without it, a Carbon Integrity Claim is just a marketing assertion. The MRA Framework specifies what a company must report and how that information must be independently checked before any claim is communicated.
9.1 What Must Be Reported
The MRA Framework requires transparent, regular public reporting of, at minimum:
- Emissions across Scope 1, Scope 2, and Scope 3
- The company’s near-term and (where set) long-term targets
- Progress against those targets relative to a base year, whether absolute or intensity-based
- The quantity and type of carbon credits purchased and retired, including project type and vintage
- Information on the third-party assurance obtained
9.2 The Assurance Requirement
The defining feature of the MRA Framework is that VCMI Claims are not self-certified. Each claim must undergo independent, third-party verification before publication, so that the underlying information is evaluated, evidenced, and assured. This separates a Carbon Integrity Claim from an unverified “carbon neutral” label — the latter can be asserted by anyone; the former requires an external party to stand behind the numbers. The verification step is what gives the Carbon Integrity mark its meaning.
10. The Carbon Integrity Brand and Claim Communications
VCMI provides a “Carbon Integrity” brand and associated mark that companies meeting the requirements may use to signal a verified Silver, Gold, or Platinum claim. The communications dimension is not an afterthought — the Code’s stated dual purpose is to govern both how companies use credits and how they communicate that use. The branding gives buyers, investors, and regulators a recognisable, verifiable signal in place of the unregulated “carbon neutral” claims the Code was designed to displace.
The first organisation to make a claim against the Code was the consultancy Bain & Company, which achieved Platinum status in February 2024. Support for the Code has been voiced by governments including the UK, France, Singapore, Peru, and Panama, positioning it as an emerging reference point for how regulators may eventually frame consumer-protection and anti-greenwashing expectations around carbon claims.
A VCMI Carbon Integrity Claim communicates that a company has cut emissions in line with science and financed additional high-quality mitigation on top. It is explicitly not a “carbon neutral” or “net zero” claim — those describe a state; a Carbon Integrity Claim describes verified action above and beyond a science-aligned pathway. Conflating the two is the precise confusion the Code was built to end.
11. VCMI vs Adjacent Neutrality Frameworks
Sustainability teams frequently ask how VCMI relates to the carbon-neutrality standards they may already use. The frameworks are not interchangeable: they answer different questions and can be used together. The comparison below positions VCMI against the two dominant neutrality standards and against SBTi’s beyond-value-chain mitigation concept.
| Dimension | VCMI Claims Code | PAS 2060 / ISO 14068-1 | SBTi (BVCM) |
|---|---|---|---|
| Core question | Is the company’s use of credits and its claim credible? | Has the company achieved carbon neutrality for a defined subject? | Are the company’s reduction targets science-based? |
| Claim produced | Silver / Gold / Platinum Carbon Integrity Claim | Carbon neutral declaration | Validated near-term and net-zero targets |
| Reductions required first? | Yes — science-aligned targets and demonstrated progress | Reduction plan required; rigour varies by standard | Yes — the standard is the reduction target itself |
| Tiered ambition? | Yes — three explicit tiers | No — neutrality is binary | No — pass/fail validation |
| Side of the market | Demand-side claims and communications | Neutrality accounting and declaration | Target-setting and decarbonisation |
In practice these stack rather than compete. A company can hold SBTi-validated targets, report under the GHG Protocol, source credits meeting ICVCM principles, and make a VCMI Platinum claim — each layer doing a distinct job. For the neutrality standards specifically, see the PAS 2060 reference and the ISO 14068-1 reference; both are increasingly read alongside VCMI rather than as substitutes for it.
12. Implementation Workflow for Sustainability Teams
For a team deciding whether and how to pursue a VCMI Claim, the practical sequence collapses the Code’s requirements into a working order of operations. Each gate must clear before the next is worth resourcing.
13. Compliance and Disclosure Interactions
VCMI is a voluntary framework, but it does not exist apart from the mandatory disclosure landscape. Its interactions with reporting regimes and anti-greenwashing law increasingly shape how a Carbon Integrity Claim should be positioned.
| Regime | Interaction with VCMI |
|---|---|
| GHG Protocol | Provides the inventory that Foundational Criterion 1 depends on. Credits sit outside the inventory and never net against reported Scope 1/2/3 totals. See the Corporate Standard reference. |
| CSRD / ESRS E1 | ESRS E1 requires disclosure of carbon credits purchased and reliance on them separately from gross emissions and reduction targets. A VCMI claim must be presented so it does not blur that separation. See the CSRD ESRS E1 reference. |
| CDP | The CDP questionnaire captures credit use and target progress, the same data the MRA Framework requires — a well-run VCMI process feeds CDP disclosure directly. See the CDP reference. |
| Anti-greenwashing rules | Consumer-protection and green-claims regimes scrutinise “carbon neutral” assertions. VCMI’s separation of claim-from-state and its verification requirement are designed to keep claims defensible under that scrutiny. |
14. Misconceptions and Criticisms
15. GreenCalculus Implementation Notes
GreenCalculus treats the VCMI Claims Code as a Layer 5 framework — a claims-and-communications layer that depends on outputs from the measurement and target-setting tools elsewhere on this platform. The Code defines no emission factors and no calculation engine of its own, so there is no VCMI factor set in the MasterBrain. What the platform supports is the data a VCMI process consumes:
- The GHG Protocol Corporate Standard and Scope 3 Standard references define the inventory that Foundational Criterion 1 requires.
- The SBTi net-zero target calculator models the science-aligned trajectory that Foundational Criterion 2 depends on.
- The PAS 2060 and ISO 14068-1 calculators serve the adjacent neutrality-claim use cases compared in §11.
The tier thresholds, version dates, and Foundational Criteria on this page are hardcoded against the VCMI primary documents and reviewed on the cadence shown in the header. Because VCMI publishes no machine-readable factor table, these values are maintained editorially rather than through the live data layer.
16. Frequently Asked Questions
It is the demand-side rulebook for the voluntary carbon market: a framework defining how companies can credibly buy and use carbon credits, and how they may communicate that use, through tiered Silver, Gold, and Platinum Carbon Integrity Claims. It is the counterpart to the supply-side ICVCM Core Carbon Principles, which govern whether a credit is high-quality in the first place.
The tiers are defined by the share of a company’s remaining emissions — those left after it has acted on its near-term science-aligned targets — that it covers with high-quality carbon credits. Silver is 20% to under 60%; Gold is 60% to under 100%; Platinum is 100% or more. The thresholds apply to remaining emissions, not the gross footprint, and a company must demonstrate progress on its targets to qualify for any tier.
The current operative version is Claims Code of Practice v3.1, published in August 2025, accompanied by MRA Framework v1.4. It follows v3.0 (April 2025), which introduced the standalone Scope 3 Action Code of Practice and revised the Foundational Criteria. The lineage runs from the provisional code of June 2022 and the first full release in June 2023. A claim should always cite the version in force at the time it was made, because the criteria have changed across releases.
They govern opposite sides of the same market. ICVCM, through its Core Carbon Principles, sets supply-side quality — whether a carbon credit represents real, additional, permanent mitigation. VCMI, through the Claims Code, sets demand-side integrity — whether a company buying those credits is using them on top of genuine decarbonisation and describing that use honestly. A credible claim needs both: a high-quality credit used inside a high-integrity claim.
No, and the distinction is deliberate. A Carbon Integrity Claim describes verified action above and beyond a science-aligned reduction pathway — what the company did. “Carbon neutral” and “net zero” describe a state. VCMI built the framework precisely to replace unqualified neutrality labels with verified, tiered statements of action. Presenting a VCMI claim as a carbon-neutral claim misrepresents it.
Published in April 2025, it is a standalone companion to the Claims Code — the finalised successor to the earlier beta Scope 3 Flexibility Claim. It lets a company use high-quality carbon credits, on a time-limited and capped basis, to close the gap between its current Scope 3 emissions and its science-aligned Scope 3 target while it works to remove the structural barriers to cutting value-chain emissions. Guardrails include demonstrated Scope 1 and 2 progress, a declining volume cap, and a phase-out. It is the most debated element of the framework.
No. VCMI is a voluntary framework and no jurisdiction currently requires compliance with it. Its influence is growing through endorsement by governments including the UK, France, Singapore, Peru, and Panama, and through its potential role as a reference point for future anti-greenwashing and consumer-protection policy. A claim against it is a voluntary act, not a regulatory filing — though it interacts closely with mandatory disclosure under regimes such as CSRD ESRS E1.
Credits must represent high-quality mitigation — emission reductions and/or removals — achieved outside the company’s value chain, and they must be retired in a registry, not merely purchased. The ICVCM Core Carbon Principles are the reference benchmark for high quality. Reductions inside the value chain belong to the GHG inventory and cannot be counted as credits. The required volume depends on the tier selected and the company’s remaining emissions.
VCMI claims sit on top of a science-aligned target. Model the trajectory before you select a tier.
Related GreenCalculus References
Carbon market integrity: ICVCM Core Carbon Principles · Verra VCS · Gold Standard · CORSIA
Targets and removals: SBTi Corporate Net-Zero · SBTi FLAG Guidance · GHG Protocol Land Sector & Removals
Neutrality standards: PAS 2060 · ISO 14068-1
Measurement and disclosure: GHG Protocol Corporate Standard · Scope 3 Standard · CSRD ESRS E1 · CDP
Apply the upstream targets: SBTi net-zero calculator · PAS 2060 calculator · ISO 14068-1 calculator
Glossary: Scope 3 emissions · CO2e