Policy doesn't repeat itself, but it rhymes. One of the questions which recurs in public policy is: where should policymakers draw the line between the state and the market?
The question in the context of carbon removal isn't whether the government should oversee carbon removal quality—it clearly should. Instead, it's how value judgments at the heart of policy are translated to operational delivery—and when and where, the government should step back and let market structures do what they do best.
Many policy discussions treat registries as performing two simple functions—providing a rulebook for quantifying carbon removal, and acting as digital filing cabinets for carbon credits. This can lead to an assumption that these services can be easily outsourced to separate government bodies. This fundamentally misunderstands the role of modern registries in carbon removal, where the two functions are deeply interconnected.
Modern registries perform three functions in carbon removal:
- Rule-setting: They draft detailed protocols (also known as “methodologies”) that translate high-level principles into operational guidance. These rules respond to the latest scientific developments, specifying exactly how to measure carbon removal across different technologies and approaches. This requires deep scientific expertise, as well as the speed and flexibility to keep up-to-date with the latest scientific developments.
- Oversight of validation and verification: They appoint and monitor the independent bodies that verify whether projects deliver promised removals. Crucially, registries help validation and verification bodies (VVBs) interpret the complex rules that the registries themselves wrote, which often requires interpretation in the context of the specific project being assessed.
- Credit tracking: They operate the technical infrastructure that issues, tracks, and retires credits—this provides transparency and accountability, essential to building trust in the market. Again, this links directly back to the science: transparent publication of calculations and supporting tools requires understanding of the underlying methodology.
These functions have evolved together in the voluntary carbon market for good reason. Because registries write the protocols, their scientific teams are uniquely positioned to support VVBs when interpreting complex methodological questions.
Understanding these interconnected functions reveals why it would be a mistake to try to split these functions apart, as some jurisdictions are considering. This risks creating a fundamental disconnect: how will a government agency support auditors to interpret a standard the agency didn't write? Is the agency able to build a well-functioning IT system to integrate project data from scratch?
Splitting these functions apart impacts speed, quality, and efficiency. We need both rigorous standards and rapid deployment at scale. Starting from zero when functional systems and rules already exist is not a recipe for either.
A better path forward
Instead of building everything from scratch, governments should focus on setting the quality bar that existing registries must meet to benefit from government support. The UK Government, for instance, has already done excellent work setting out a high-level set of principles for the DAC and BECCS pathways. But moving from this to drafting a full methodology would be a mistake.
If the government replicates functions that already exist effectively in the voluntary carbon market, it risks not just crowding out these success stories, but forcing UK suppliers to rely on government-operated systems that are unlikely to keep pace with rapid scientific and technological developments.
Instead, they could develop a set of criteria of registry quality, drawing on the excellent precedent which already exists internationally:
- Require registries to meet established international quality frameworks (like The Integrity Council for the Voluntary Carbon Market's Core Carbon Principles)
- Develop an authorization process for registries and their methodologies to be recognized by the UK Government
- Use existing British Standards Institution's frameworks as minimum quality thresholds for methodologies
The EU's Carbon Removal and Carbon Farming Framework (CRCF) offers a useful model. Rather than building parallel systems, it establishes quality criteria that existing registries must meet to operate within the EU framework. This leverages market-tested infrastructure while maintaining appropriate political oversight. This type of approval scheme could undergird any state support for UK schemes.
The UK Government has launched an Independent Review of Greenhouse Gas Removals. One of the questions is: what are the barriers to deployment at scale?
Providing a clear and robust regulatory framework, which uses the infrastructure the market has already established, must be part of the answer.
The fundamental choice
The fundamental insight here is about comparative advantage. The government has unique capabilities that only it can exercise: setting strategic direction, making policy judgments about acceptable pathways, ensuring democratic accountability over public resources. These are inherently—and rightly—governmental functions.
But detailed methodology development, the operation of complex systems, and day-to-day market oversight? These are areas where the private sector has already invested heavily and developed proven capabilities.
Sometimes, in government, less is more.
