Brussels, 4 May 2026 – The European Banking Federation(EBF)’s Key Messages on International Carbon Credits & 2040 EU Climate Law Targets

• We support developing an EU framework for limited  use of international emission credits to support global decarbonization and cost-efficiency, provided they remain strictly complementary, meet high integrity standards, and operate within a transparent, liquid market.
• These credits could also play a stabilizing role in the EU climate framework, including for ETS sectors, without undermining the ETS cap or price signal.
• Voluntary carbon credits must follow strict principles: emission reduction must always takes priority; reductions must be effective and permanent; credits must be based on high-integrity standards; and their use must be strictly limited to clearly defined residual emissions and not used as a speculation tool.
• An early and predictable regulatory framework is essential. Legal certainty and greenwashing prevention must be built in from the outset, covering not just environmental risks but also technology, regulatory, political, counterparty and permanence risks.
• Verifying the credibility, integrity and governance of carbon credits must not fall to financial institutions. All EU-eligible credits must be accepted by supervisors and auditors based on a rigorous, independent verification process, with validation bodies fully separate from project developers and issuers.
• The proposed 5% cap is appropriate, but a pragmatic approach allowing different high-integrity credit types , including nature-based solutions and engineered removals, is essential to avoid supply bottlenecks and ensure market liquidity.
• Any EU framework for international credits must align with Paris Agreement mechanisms and be accompanied by corresponding adjustments to prevent double counting and fragmentation.
• EBF also supports well-designed pilot mechanisms to test quality standards and governance before broader application, with a phased approach starting with partner countries ahead of potential use from 2036.
• A uniform European level playing field is  also essential to ensure consistency across Member States and prevent regulatory fragmentation.
• Purchase  of certificates (provided those are subject to robust standards as described above) from foreign ETS with strict framework closely aligned with the EU ETS should also be considered.

Denisa Avermaete, Head of Sustainable Finance,D.Avermaete@ebf.eu
Jānis Priekulis, Senior Policy Adviser – Sustainable Finance, j.priekulis@ebf.eu