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Opinion of the European Economic and Social Committee – Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Roadmap towards Nature Credits (COM(2025) 374 – final)

EESC 2025/03041

OJ C, C/2026/2548, 22.5.2026, ELI: http://data.europa.eu/eli/C/2026/2548/oj (BG, ES, CS, DA, DE, ET, EL, EN, FR, GA, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)

ELI: http://data.europa.eu/eli/C/2026/2548/oj

Date of document:: 19/02/2026; Date of vote
Date of vote:: 19/02/2026
Date lodged:: 29/08/2025

Author:: European Economic and Social Committee
Responsible body:: Section for Agriculture, Rural Development and the Environment, EESC_NAT
Rapporteur:: Arnaud SCHWARTZ
Co-rapporteur:: Teppo SÄKKINEN
Form:: Opinion
Internal reference:: NAT/961, AVIS-SECTION 2025/3041 FIN
Session:: 603

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Treaty on the Functioning of the European Union

Legal basis:

12016E304

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52025DC0374 ESC Opinion

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Subject matter:

Environment

Directory code:

15.10.00.00 Environment, consumers and health protection / Environment

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C/2026/2548

22.5.2026

Opinion of the European Economic and Social Committee

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Roadmap towards Nature Credits

(COM(2025) 374 – final)

(C/2026/2548)

Rapporteur:

Arnaud SCHWARTZ

Co-rapporteur:

Teppo SÄKKINEN

Advisor	Athénaïs GEORGES (to the rapporteur) Juha TURKKI (to the co-rapporteur)
Legislative procedure	EU Law Tracker
Referral	European Commission, 29.8.2025
Legal basis	Article 304 of the Treaty on the Functioning of the European Union
European Commission documents	COM(2025) 374 – final Summary of COM(2025) 374 – final
Relevant Sustainable Development Goals (SDGs)	SDG 1 – No poverty SDG 2 – Zero hunger SDG 8 – Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all SDG 10 – Reduce inequality within and among countries SDG 11 – Sustainable cities and communities SDG 12 – Ensure sustainable consumption and production patterns SDG 13 – Climate action SDG 14 – Life below water SDG 15 – Life on land
Section responsible	Agriculture, Rural Development and the Environment
Adopted in section	28.1.2026
Adopted at plenary session	19.2.2026
Plenary session No	603
Outcome of vote (for/against/abstentions)	219/3/2

1. RECOMMENDATIONS

The European Economic and Social Committee (EESC) calls on the European Commission to:

1.1.

Ensure that the biodiversity funding goals established by the Kunming Montreal Global Biodiversity Framework are met. This requires sufficient, stable and timely public funding, including from the EU budget, and the phasing-out of environmentally harmful subsidies, such as fossil fuel subsidies. Nature credits can be a tool to help close the funding gap and mobilise private finance, complementing but not replacing public funds.

1.2.

Uphold and enforce environmental legislation and fundamental principles, as an efficient tool to ensure the protection of nature and the achievement of the biodiversity targets, and to close the funding gap, and as the basis for a trustworthy nature credits framework.

1.3.

Ensure that the framework for nature credits and markets is based on strict high-integrity principles along with the mitigation hierarchy and other environmental, climate and social safeguards, and systematically assesses projects’ compliance with those. The methodologies used should be holistic and scientific, and they should be based on an ecologically integrated, outcome-based approach.

1.4.

Ensure that the governance framework for the nature credits market is science-based, inclusive, transparent and participatory, with a strong focus on involving farmers, foresters, landowners, conservationists, workers at large and other actors with the potential to restore, conserve and enhance nature, as well as vulnerable and marginalised groups such as youth, women, rural communities and indigenous peoples. The framework should address transparent and fair data management and ownership.

1.5.

Approach with caution the need for a Directive or a Regulation, as the establishment of nature credits and markets should remain voluntary while complying with strict rules and criteria. The framework should focus chiefly on positive contributions, while the use of offsetting should be left to the decision of the Member States, so as to not undermine existing ambitious initiatives at national level.

1.6.

Clarify the alignment of nature credits and markets with other policies, such as agri-environmental measures in the Common Agricultural Policy (CAP) with regard to agriculture. Nature credits and markets must be built in a way that allows the bioeconomy, circular economy, sustainable food production and forestry to thrive in the EU. The framework should avoid adding unnecessary administrative burden on practitioners, particularly small ones, while ensuring the high integrity and science-based approach of the credits.

1.7.

Ensure that the possible tradability of credits does not lead to the commodification or financialisation of natural elements. Land grabbing and speculation should be prevented at all costs. The European Commission must assess and learn from examples worldwide. The economic design of nature credits and markets should always prioritise integrity over short-term profitability, as well as the fair distribution of benefits, and address governance issues and market manipulation mechanisms. In this regard, while financing biodiversity action, nature credits markets should by design also help to reduce inequalities and promote quality jobs by providing additional revenue opportunities.

1.8.

Engage cautiously with projects outside the EU, bearing in mind that methodologies and governance frameworks developed in Europe might not fit social, cultural, legal, political and ecological contexts abroad, while providing continuous guidance for EU economic actors on using high-integrity credits to generate nature-positive impacts in their value chains outside the EU.

2. EXPLANATORY NOTES

Background

2.1.

The Kunming-Montreal Global Biodiversity Framework (GBF) sets the target of reversing biodiversity loss by 2030. In order to do so, the GBF aims to mobilise at least USD 200 billion annually, including through innovative schemes such as biodiversity offsets and credits with environmental and social safeguards. At the EU level, the financing gap to implement biodiversity objectives is estimated at around EUR 200 billion by 2030. As highlighted by the influential Dasgupta Review (1), the importance of biodiversity can be understood also in economic terms to capture its inherent necessity for our economies without downgrading the intrinsic worth of nature.

2.2.

The International Advisory Panel on Biodiversity Credits (IAPB) Framework for high integrity biodiversity credit markets (2024) (2), launched at COP16, defines a biodiversity credit as ‘a certificate that represents a measured and evidence-based unit of positive biodiversity outcome that is durable and additional to what would have otherwise occurred’.

2.3.

However, the Roadmap towards Nature Credits published by the European Commission mentions ‘nature credits and markets’. A clear definition of ‘nature credits’ should be the starting point, including identifying the specific nature-related areas, such as biodiversity and/or ecosystem services, that are suited to a credits-based approach and the specific conditions that would apply. The EU Water Resilience Strategy mentions the Roadmap as a potential tool for water financing. Water is not only a common good, it is vital to all organisms; it is a fundamental human right, an ecosystem, part of our cultural heritage, a climate regulator and the basis for any functioning economy. It is crucial that the framework address the very specific essence of each of the natural elements that will be included.

Prerequisites

2.4.

Nature credits can be a tool for mobilising funds for nature-positive action. However, they should not substitute other means of financing and protecting biodiversity. As a priority, the EU needs to ensure that sufficient and timely public funding is earmarked for nature restoration and protection in the EU budget with stable instruments; that environmentally harmful subsidies, particularly fossil fuel subsidies amounting to EUR 112 billion per year in Europe (EEA, 2023), are phased out swiftly; and that nature legislation is implemented and enforced, with due respect for the rule of law. Nature credits should align with the different EU environmental policies and contribute towards achieving the objectives of those policies; they should also contribute to achieving the sustainable development frameworks such as the Sustainable Development Goals (SDGs).

2.5.

The EESC has already stressed the importance of mobilising private sector investments. However, it also warned that the integrity of financial instruments incentivising private investments must be strictly assured and that, in particular, care should be taken when making proposals for ‘biodiversity markets’ (3). The Roadmap towards Nature Credits provides a starting point for the debate on how to develop high integrity credits and markets in order to support biodiversity goals. Sufficient time, not restricted to the two-year timeline of the roadmap, should be taken to lay the foundations for nature credits and markets with care.

2.6.

Market-based approaches can provide solutions for financing biodiversity and the conservation and restoration of nature. If done correctly, credits can highlight the value of biodiversity and ecosystem services, and establish both incentives for nature-positive action and costs for harmful impacts. However, markets alone cannot solve the nature financing gap, and loose market rules can lead to risks, such as greenwashing or speculation, and harm local communities. While carbon markets can provide lessons on the dos and don’ts of nature credits, the inherent locality and complexity of natural elements and their interactions must be considered.

2.7.

The Roadmap towards Nature Credits points to the EU Carbon Removals and Carbon Farming Regulation (CRCF), under which methodologies for the certification of carbon sequestration are being developed. These methodologies, while not final, illustrate the challenges linked to the integrity of credits, such as baselines and additionality, the potential misuse of the resulting credits and failure to incorporate meaningful safeguards, metrics and indicators to ensure environmental integrity and biodiversity benefits. These pitfalls must be taken into account when exploring the development of nature credits.

2.8.

Additionally, a thorough and cautious reflection on the legislative nature of the nature credits framework must take place, to avoid undermining ambitious and effective nature protection and restoration initiatives at national level. While nature credits must comply with strict rules and criteria, their establishment must remain voluntary. Therefore, the need for a Directive or a Regulation should be approached with caution.

Baseline principles

2.9.

National laws and EU regulatory frameworks already benefit from very powerful and efficient fundamental environmental principles, such as the ‘precautionary’, the ‘rectification at source’ and the ‘polluter pays’ principles (4), along with the ‘do no significant harm’ principle. The rule of law must be guaranteed by respecting those. Provided they are not watered down, national and EU environmental laws support the high integrity of potential nature credits by guaranteeing the permanence over time of nature protection and restoration. From a social point of view, nature markets should avoid fostering negative social impacts and promote quality and sustainable jobs.

2.10.

While credits can provide additional sources of finance, the ‘3Ts’ (taxes, tariffs, transfers) approach developed by former IMF Director Michel Camdessus, offers various robust instruments to implement the ‘polluter pays’ principle, while also financing biodiversity protection and restoration. Instruments like taxes and transfers are of particular relevance in addressing challenges linked to the monetisation and framing of ecosystem services and environmental damage.

2.11.

The mitigation hierarchy – avoid, minimise, compensate – provides sufficient flexibility in the event of ‘unavoidable’ environmental damage. From a scientific point of view, achieving absolute ecological equivalence is impossible, which is why compensation should always be a mechanism of last resort. Credits should not be used to offset impacts that should have been avoided or minimised, and should not allow double counting.

2.12.

According to the IAPB Framework, the use of credits can be roughly divided into: 1) evidence-based contributions to biodiversity; 2) offsets that are used to compensate damage at least at the same level; and 3) value chain insets. In Finland, the use of offsets takes place in the framework of the mitigation hierarchy and with the application of the ‘polluter pays’ principle, and has strong scientific backing. In some Member States (e.g. France) though, using nature credits to offset degradation could backfire by letting polluters profit from mandatory compensation under the mitigation hierarchy with the issuance of a credit, potentially encouraging further damage. Therefore, any EU framework should focus chiefly on using nature credits for only positive contributions, but could consider guidance for high integrity principles for offsets to discourage their loose use.

2.13.

Nature credits must abide by minimal high integrity principles. These include: additionality; no double counting; the permanence of restoration; a causality between metrics and the desired outcomes; the prevention of leakage effects; independent, third-party and public verification of outcomes, with the costs being borne by private entities seeking to acquire the credits; systematic detection and penalisation of non-compliance; and full and timely transparency and open access to methodologies, projects, results and any information linked to nature credits. Each of these terms must be thoroughly defined, along with methodologies to assess and monitor projects’ compliance with them.

2.14.

The application of high integrity principles must be a prerequisite for any nature credits. This includes additional environmental and social safeguards, such as:

—	environmental safeguards against greenwashing, genetic manipulation/bioengineering, wildlife trade, etc.; and

—

governance and social safeguards against: land grabbing, speculation and excessive land and real estate price increases (especially for agriculture), and privatisation of natural areas; unfair distribution of benefits, in order to prevent big landowners or powerful entities from capturing disproportionate gains, pushing farmers out of business or resulting in impoverishment and spoliation of vulnerable groups; and to ensure the geographical scope of projects is limited to ecosystems’ areas and jurisdictions of relevance, with consistent governance and regulatory processes involving, on a permanent basis, stakeholders, scientists and civil society at large.

Governance

2.15.

There is no market without supply, and there is no supply without people who have the means to restore, conserve and enhance nature, such as farmers and forest owners. The development of a nature value market and nature credits should closely involve practitioners at all stages of the process, including piloting and testing. Agriculture already works with different sustainability concepts, including organic farming and agri-environmental measures in the second pillar of the current CAP. It is important that nature credits do not crowd out other existing payments such as CAP payments. The EESC stresses the need for clarity about how credits would fit together with these other policy frameworks. Nature credits and markets must be built in a way that allows the bioeconomy, circular economy, food production and forestry to thrive in the EU.

2.16.

In order for nature credits to provide a way to create tangible benefits for local communities, farmers, fishers, foresters, landowners and Indigenous People, ensuring the capacity to restore, protect, enhance and conserve ecosystems and biodiversity, as well as incentivising regenerative practices, robust, transparent and participatory governance frameworks must be established, involving the systematic participation of frontline communities. Special attention should be given to vulnerable and marginalised groups such as youth, women, rural communities and Indigenous People. For the indigenous people, the UN Declaration on the Rights of Indigenous People, recognising their right to self-determination through Free, Prior and Informed Consent (FPIC), and the inclusion of traditional knowledge is crucial. Dedicated capacity-building and participation bodies for those groups should be established. Civil society should systematically be part of global negotiations.

2.17.

Market conditions, land-ownership structures, environmental regulations, agricultural and forestry practices, and nature itself vary between the EU Member States. Thus, all EU policy preparation must consider the unique characteristics of each country, respect established and ongoing development of high integrity nature credits and markets, and ensure that possible common frameworks for nature credits can be adapted in the different Member States without compromising integrity principles.

2.18.

Governance frameworks must be science-based, democratic, transparent and inclusive, while addressing transparent and fair data management and ownership. They require constant and meaningful public oversight and participation. Governance at large must be the responsibility of public authorities, which should invest in capacity-building and jobs (e.g. in universities, etc.), supported by trusted third parties. Access to information, justice and public participation are embedded in the Aarhus Convention, to which the European Union and its Member States are signatories.

2.19.

When establishing nature credits markets by allowing the transfer/trade of credits, it is important to ensure strong safeguards against market manipulation such as speculation, hoarding or wash trading that decouples financial incentives from ecological outcomes, potentially leading to the financialisation of nature. Initiatives transforming water into financial assets, such as the establishment of water markets and credits in California and Australia, have led to numerous impacts, such as rendering scarcity profitable and undermining sustainable use, small farmers and communities, by letting speculation in. Opaque pricing, weak oversight, and prioritisation of financial returns over social and ecological needs have further undermined transparency, equity, and the management of water as a common good.

2.20.

Nature credits must be kept within a local scope, tied to specific ecosystems and communities, and not traded across national jurisdictions. This is consistent with scientific methodologies in the field.

2.21.

EU institutions should be particularly careful with nature credit projects elsewhere in the world as the cultural, legal and ecological aspects vary greatly from one country to another, and because it risks creating governance issues that could result in another example of neocolonialism and hinder the very objective of those credits from both a social and an environmental point of view, thus also driving market instability through lack of trust. For example, the well-documented and historic illegal capture and spoliation of land from indigenous and rural communities in Latin America, Africa and Asia has led to their monopolisation by some powerful groups. The EU cannot take the risk of supporting the development of projects on stolen land. Methodologies developed in the EU might not be fit for purpose in other parts of the world.

2.22.

Nature credits could be an instrument for EU economic actors, especially businesses, with parts of their value chain outside the EU, that are willing to reduce their impacts on-site but lack dedicated mechanisms. Abiding by high integrity principles, including transparent, inclusive and participatory governance and decision-making frameworks tailored to the local socio-cultural, legal, political and economic contexts, is even more important in that regard. At EU level, this must align with the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD).

Scientific methodologies

2.23.

Establishing ecosystem references with robust indicators and criteria, as well as framing and monetising ecosystem services both pose great scientific and epistemological challenges. Proxy metrics should be used with caution, while striving toward higher causality variables. Any sound methodology must integrate ecological complexity; the multidimensional nature of functions, uses and users of ecosystems and their potential cross-border character; and the social context and uncertainty especially related to climate risks. Scientists, including natural and social scientists, are at the core of devising methodologies and should be able to provide honest feedback on their feasibility. Stakeholders from both public and private sectors have raised concerns on increased bureaucracy while stressing the need for strict, high-quality criteria to ensure integrity, trust and performance. Proxy metrics are not sufficient for robust methodologies.

2.24.

An outcome-based approach that issues credits only for verified ecological gains, such as species recovery, habitat integrity or ecosystem functionality, remains the most robust and valid approach. Credits should recognise a wide range of activities, including conservation, restoration, active maintenance such as clearing meadows, and multi-use of areas. For projects where the outcomes take a long time to materialise, goalposts/milestones, such as the return or increase of indicator species, could be established. Farmers, forest owners or conservationists whose contribution to biodiversity gains would require continuous actions may need to be rewarded on a regular basis, as they cannot wait for the entire lifespan of a complete ecosystem restoration project to be achieved.

2.25.

If developed, nature credits must comply with at least all the aforementioned principles and should not result in commodification or financialisation.

2.26.

In order to avoid: 1) increasing the cost of operating and managing nature certificates and the credit value chain; and 2) creating governance issues, intermediaries should be avoided as much as possible, when not necessary for the development of the market.

Economic considerations

2.27.

The economic design of a nature credit system must prioritise integrity and long-term sustainability over short-term profitability. Volatility is inherent in financial markets, but biodiversity protection requires stability and predictability. Voluntary markets can only provide the latter if they are tied to transparent, sound and strict rules and regulations.

2.28.

In the event that a secondary market is built, the Commission must explore different scenarios for a fair distribution of the benefits, including among the practitioners, local communities, authorities and other restoration projects, and devise measures to prevent speculation and profiteering on credit prices by resellers.

2.29.

Biodiversity and ecosystem restoration efforts have different life spans. While in some cases the restoration of some elements can be very quick (as in the case of river restoration and the swift return of migratory fish), the comprehensive restoration of functional ecosystems spans decades (for example, the restoration of the full connectivity of a river catchment). The fact that ecological outcomes are not likely to materialise within short-term investment cycles should be taken into account when designing nature credits.

Brussels, 19 February 2026.

The President

of the European Economic and Social Committee

Séamus BOLAND

(1) The Economics of Biodiversity: The Dasgupta Review, Partha Dasgupta, 2021.

(2) Framework for high integrity biodiversity credit markets, IAPB.

(3) Opinion of the European Economic and Social Committee – A comprehensive strategy for biodiversity at COP16: bringing all sectors together for a common goal (own-initiative opinion) (OJ C, C/2024/6880, 28.11.2024, ELI: http://data.europa.eu/eli/C/2024/6880/oj).

(4) Art. 191 TFEU.

ELI: http://data.europa.eu/eli/C/2026/2548/oj

ISSN 1977-091X (electronic edition)

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