On the 18th of May 2026, after an opportunity for feedback from Expert Group members in March, the European Commission held the third Nature Credits Expert Group meeting, to assess the comments and discuss the views of the different stakeholders for each of the workstreams (WS), for which Bellona Europa gave feedback. Workstreams are as follows: WS1 Methodologies and Metrics, WS2 Governance and Integrity, WS3 Market Readiness, WS4 Policy coherence and finally WS5 International Cooperation. 

Ahead of the Expert Group, the Commission shared draft concepts and definitions for discussion, drawing on published academic studies and existing certification schemes. The effort reflects a genuine need: without agreed terminology there are risks of incoherence across workstreams in the design of said Nature Credits. For this initiative, defining use-cases, offsetting but also risks of reversals, leakages, and the liability architecture will determine the integrity of the scheme. Bellona does not support any type of offsetting for biodiversity credits. An example is Australia’s Nature Repair Market, a government regulated framework for investments in nature restoration. However, significant questions and criticism remain around fungibility, additionality, permanence, and the risk that biodiversity certificates evolve, specially with climate resilience and impact on climate change. Biodiversity certificates should not be a mean for compensating for biodiversity loss elsewhere. 

In relation to the market, the concept of bundling and stacking of nature and carbon credits and associated governance models were also presented and may be relevant in the broader context of international credits, Article 6 of the Paris Agreement and the EU CRCF. Agreement on definitions does not resolve the harder questions of what claims nature credits can support, how they interact with existing legal obligations, or who bears liability when ecological outcomes fail, which are still to be defined within the Nature Credits framework. 

Methodologies 

DG ENV collected feedback on whether the Ecosystem Condition Index (ECI), aligned with the UN System of Environmental-Economic Accounting (SEEA-EA), could be a potential framework for structuring biodiversity measurement. Expert feedback broadly supported using the ECI as a conceptual framework, while flagging important caveats: aggregating diverse variables into a single index risk masking trade-offs between ecosystem components. Reaching consensus on baselines will be challenging, particularly given regional variation across Member States. Satellite data, while improving comparability and reducing administrative costs, cannot capture all ecologically relevant variables. 

There is no one-size-fits-all approach. Each ecosystem type will require its own testing phase to determine which combination of remote sensing and in-situ data is appropriate. Several metrics for each ecosystem type could also be aggregated into an EU biodiversity indicator / index. If scientifically sound, it would also be good to align indicators and metrics with the EU Taxonomy, CSRD and other relevant policy instruments. 

Governance 

WS2 generated substantive input on the governance architecture. Feedback called for a clearer mapping of market participants between standard developers, certification bodies, project developers, intermediaries, and end buyers with explicit rules separating their roles to avoid conflicts of interest (similarly to the Renewable Energy Directive and CRCF). 

Bellona echoed concerns raised on how to handle liability when ecological outcomes underperform; how to prevent double counting, what the credits will be used for, corporate reporting and Paris Agreement accounting, particularly if Nature Credits can be bundled / stacked with removal credits (i.e. CRCF). 

The Commission also presented progress on a digital registry and digital MRV (monitoring, reporting, and verification) architecture, developed in cooperation with DG DIGIT. The proposed system would assign each credit a “digital passport” as an entry point to a full digital audit trail, operating in a federated configuration that allows existing registries to interconnect. The Commission invited expert input on state-of-the-art solutions in this area. 

Policy coherence 

Bellona identified several important coherence risks, especially regarding the boundary between legal compliance and voluntary actions having learned from the Expert Group on Carbon removals: the Nature Restoration Law, the relationship with CAP payments, State Aid rules, the role of CRCF carbon farming, the Bioeconomy Strategy and corporate sustainability reporting under the CSRD to avoid double accounting, double funding (additionality) and green claims. 

Next steps should include developing a policy coherence matrix with key EU frameworks with a set of use cases and pilots (already on track in some Member States such as France, which is launching their own ‘Crédits Biodiversité’ initiative). 

DG CLIMA provided an update on the CRCF, which is moving into implementation with published certification methodologies for permanent removals, while carbon farming methodologies are to be adopted this year (including rewetting of peatlands and afforestation) and a call for certification schemes opened in May 2026. DG CLIMA is also working on the formal review of the primary CRCF legislation as well as an upcoming methodology for Forest Management, which would be the most relevant for the Nature Credits workstreams. However, it is still very early stage and establishing baselines and alignment with international carbon credits will be difficult. 

International cooperation and market readiness  

The Commission outlined plans to organise a high-level side-event at CBD COP17 and is considering launching a “Group of Friends of Nature Credits” to bring interested governments and partners together around high-integrity approaches.  

Expert feedback pointed to the need to better qualify and quantify use cases and their market potential, clarify the role of financial institutions at each stage of project development, and address the fundamental question of whether credits will be used in compliance contexts or remain purely voluntary.  

Three studies were presented. The Commission’s scoping study is developing summary factsheets for existing credit schemes, alongside an EU-wide survey of potential buyers to estimate demand potential, expected to launch in September 2026. A Technical Support Instrument project (implemented by IUCN in Croatia, the Netherlands, and Poland) is assessing indicators, financing mechanisms, and governance options for nature credits, with delivery by October 2027. The JRC presented a behavioural study, including a published scoping literature review, examining what drives and blocks engagement by supply-side and demand-side actors. A large-scale survey experiment targeting agrifood firms across twelve EU Member States is planned for early 2027. 

Next steps 

The 4th Expert Group meeting is tentatively scheduled for September 2026. Between now and then, experts have been invited to submit written feedback by 21 August, including on the draft concepts and definitions paper and on the JRC survey design. 

The Commission is also advancing on several parallel tracks: a digital registry pilot with DG DIGIT; Green Assist advisory projects in French wetlands and on EU-wide scaling; LIFE funding calls open until September 2026; and relevant EU representation at CBD COP17 and UNFCCC COP31. 

• Bellona Feedback: Methodologies and Metrics (pdf)
• Bellona Feedback: Policy Coherence (pdf)