📋10 min read

CSRD, BVCM & climate reporting

Documenting your contribution for ESG reporting

The CSRD (Corporate Sustainability Reporting Directive) imposes new transparency requirements on European companies' climate strategies. The SBTi's BVCM framework complements this approach by defining how to communicate about financing climate projects beyond the value chain.

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CSRD requires increased transparency on climate strategies and credits used

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BVCM defines 4 steps to structure your carbon contribution

Communicating about your contribution (not your neutrality) is defensible and transparent

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Greenwashing is a growing legal and reputational risk

What you can sayWhat you cannot say
'We contribute to financing carbon sequestration projects''We are carbon neutral'
'We support the regenerative transition of X farms in France''Our emissions are 100% offset'
'X tCO₂e financed through certified Gold Standard credits''Our activity has no climate impact'
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SBTi's 4 BVCM steps

1. Set an SBTi trajectory, 2. Reduce emissions (scope 1-2-3), 3. Contribute beyond value chain, 4. Communicate with transparency

The SBTi's BVCM framework, published in February 2024, defines four steps for companies committed to an ambitious climate strategy. Carbon contribution comes at the third step, after defining a science-based trajectory and implementing a reduction plan. The fourth step (communication) is regulated to avoid any unfounded neutrality claims.

For CSRD reporting, companies must precisely document the credits they use: certification standard, project type, location, volume, vintage, and proof of retirement on the registry. Arka credits come with all this documentation, ready to be integrated into your ESRS report.

The CSRD application schedule rolls out in successive waves. First wave (reports published in 2025 on fiscal year 2024): large companies already subject to the NFRD, around 11,000 entities in Europe. Second wave (2026 reports on 2025): other large companies meeting at least two of three criteria: more than 250 employees, revenue above 50 M€, balance sheet above 25 M€. Third wave (2027 reports): SMEs listed on European regulated markets. Fourth wave (2029 reports): third-country companies with European revenue above 150 M€. On carbon credits, CSRD does not require their purchase but requires full transparency: volume used, type, standard, vintage, registry and purpose (internal reduction, BVCM contribution, associated claims). Note: the European Omnibus package in 2025 redefined the second-wave perimeter, which is no longer exactly as initially announced; companies should check this with their advisors.

ESRS E1 (Climate change) is the most structuring sector standard for carbon credits. It requires several specific disclosures. E1-1: 1.5°C-aligned transition plan, with decarbonisation scenarios and associated CapEx. E1-4: emission reduction targets, baselines and trajectory. E1-6: gross GHG emissions scope 1, 2 and 3 by category, methodologies used and uncertainties. E1-7: GHG removal and reduction projects and financing outside the value chain, which corresponds precisely to carbon contribution and BVCM. For this point, the company must document credit volume, typology (removal vs avoidance), geography, standard, vintage, status (purchased, retired), and articulation with the reduction trajectory. Any neutrality claim must be substantiated: without robust evidence, the CSRD auditor can issue a reservation.

Arka structures its buyer deliverable around ESRS E1 requirements to streamline its clients' CSRD reporting. For each transaction, the file provided includes: (1) the registry retirement certificate (Gold Standard, Verra, Label Bas-Carbone) with its publicly verifiable unique identifier; (2) the project PDD and annual monitoring/verification reports; (3) a contextualised project sheet (location, operator, methodology, vintage, co-benefits) in French and English; (4) an Arka attestation letter specifying volume, standard, intended use (BVCM contribution) and absence of double counting; (5) a methodological memo for the ESRS E1-7 report explaining how to integrate these credits into the company's trajectory and communication. This packaged documentation saves CSR teams time and lets auditors validate without follow-up requests. It is this packaging work that turns a carbon credit into a documentary asset usable in a CSRD report.

Key takeaway

Document your carbon contribution as a strategic investment, not a compliance expense. CSRD requires transparency, and well-done transparency is a competitive advantage.

In practice

Integrate carbon contribution into your climate strategy from the CSRD planning phase, not at the end of the process. Auditors value consistency between trajectory, reduction and contribution.

Frequently asked questions

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