A framework still in the making 

As a member of the European Commission’s Nature Credits Expert Group, Bellona joined the second meeting that took place on 18-19^th of March 2026, marking an early step in the EU’s exploration of market-based instruments for nature positive actions. While discussions highlighted strong interest from stakeholders, the overall process remains at a formative stage, with key design choices still unresolved. 

A “blank canvas” approach from the Commission 

On day 1, the Commission made clear that it is currently in a listening phase, adopting an open approach to stakeholder input without committing to specific policy directions. Notably, no clear definition of Nature Credits, their use cases, or the claims associated with them has been established at this stage. Instead, the Commission is prioritising the development of methodologies, with use cases to be determined at a later stage. 

This sequencing raises concerns. A similar “methodology-first” approach was followed in the Carbon Removals and Carbon Farming (CRCF) framework, where use cases have still not been defined after the adoption of the methodologies from the delegated act, contributing to ongoing debates about environmental integrity and policy coherence. Replicating this approach risks embedding structural weaknesses into the Nature Credits framework. 

Sustainability gaps and a carbon-centric legacy 

While the Nature Credits Expert Group has not yet addressed sustainability requirements in detail, experience from the CRCF framework raises important concerns. 

Bellona has highlighted the shortcomings of the CRCF carbon farming methodologies notably for their sustainability provisions, often limited to existing legal requirements (Nature Restoration Law, Do No Significant Harm) rather than introducing robust, measurable biodiversity mandatory requirements. When this point was raised in the CRCF Expert Group, the Commission indicated that Nature Credits would “bring new light” on biodiversity quantification, effectively deferring these issues to a separate framework. 

This approach is problematic. It risks leaving gaps in current carbon methodologies (written with a carbon lens rather than the whole ecosystem benefits) unresolved, while placing sustainability expectations on a Nature Credits system that is itself still undefined. 

More broadly, there is a risk that Nature Credits could repeat the same challenges seen in carbon markets, particularly around baselines, additionality, and permanence, with greater complexity.  

Developing a common metric: the ecosystem condition index 

One of the central ideas presented was the development of an EU-wide baseline system using an “ecosystem condition index” (ECI) which would assess how “healthy” or “functional” an ecosystem is on a scale from zero to one across Member States. This approach could provide a common reference point for comparing ecological conditions and tracking improvements. 

While promising in theory, questions remain about how such baselines would be defined, standardised, and updated. The complexity of ecosystems, regional variation, and data limitations make this a challenging task. Without clear rules, there is a risk that baseline flexibility could undermine the credibility of any resulting credits. 

Market readiness: demand remains the key challenge 

Day 2 discussions focused on financial and market readiness, with financial institutions emphasising that voluntary demand alone is unlikely to mobilise investment. Without clearer incentives or compliance-driven demand, private capital remains limited. 

At the same time, stakeholders warned of risks associated with premature market creation. If credits are generated without stable demand or price signals, project developers (particularly farmers and landowners) could face stranded assets and financial losses. Proposals such as public price guarantees, blended finance models, and readiness funds were discussed. 

Linking climate and biodiversity: synergies and trade-offs 

The interaction between climate and biodiversity objectives was another key theme. While some ecosystem types may not be suitable for carbon crediting and could instead be targeted through standalone Nature Credits, the overall message from research and modelling is that climate and biodiversity goals are largely synergistic. 

In most cases, actions that benefit biodiversity also support climate mitigation and adaptation. However, trade-offs can occur, and these need to be carefully managed within any certification framework. Participants generally favoured a simple, integrated system that captures both carbon and biodiversity outcomes, rather than creating fragmented or parallel markets. 

The Commission is currently exploring a spectrum of possible credit types, ranging from carbon credits with biodiversity co-benefits to fully standalone Nature Credits. This flexibility reflects the early stage of the process but also underscores the lack of clarity about the final direction. 

Equity, access, and governance 

Several important governance and equity considerations were raised. Ensuring fair benefit-sharing will be essential to the legitimacy of any Nature Credit system, particularly in avoiding disproportionate gains for large actors at the expense of smaller landowners. 

Accessibility remains a concern, as most restoration projects are relatively small and may struggle to meet the scale required by institutional investors. Aggregation models and targeted financial support mechanisms will be necessary to ensure broad participation. 

Participants also highlighted risks related to social impacts and global equity, including the potential for “neo-colonial” dynamics if socioeconomic considerations are not adequately integrated. Citizen engagement and transparency were identified as key elements for building trust and ensuring accountability. 

Looking ahead 

The Expert Group discussions made one thing clear: there is no clear direction yet on what Nature Credits are meant to achieve or how they will be used. While the Commission’s open, consultative approach creates space for input, it also means key questions around use cases, governance, and environmental integrity, remain unresolved. 

This lack of clarity is not just procedural; it risks repeating the same uncertainties seen under the CRCF. Developing methodologies without first defining how credits will be used or what claims they enable raises fundamental concerns about the purpose and credibility of the system. 

For Bellona, the priority remains clear: Nature Credits must deliver real, measurable ecological improvements and cannot become a substitute for emissions reductions or stronger biodiversity regulation. If framed as offsetting tools or flexible claims mechanisms, they risk weakening environmental ambition rather than strengthening it. 

Without clear guardrails and a well-defined role, Nature Credits risk creating the appearance of progress while delaying the structural changes needed to halt biodiversity loss.