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Regulatory

Prepare for stricter disclosure and transition-plan requirements

Regulators are rapidly raising expectations around credible climate action and transparent reporting. In the EU, the Corporate Sustainability Reporting Directive (CSRD) requires companies to disclose clear net-zero targets (E1-4) and detailed information on CDR (E1-7).

Non-compliance with CSRD can carry significant consequences. Because each EU Member State sets its own enforcement regime, penalties vary, but they typically include substantial administrative fines, potential legal liability for company directors, and increased scrutiny from regulators and auditors. Beyond regulatory exposure, insufficient or inaccurate reporting can also create reputational risks, undermine investor confidence, and lead to challenges during assurance or stakeholder reviews.

Beyond regulation, disclosure frameworks such as CDP and SBTi increasingly expect companies to articulate how they will neutralize residual emissions—pushing organizations toward earlier, clearer integration of CDR into transition plans.

Align with rules governing climate claims and high-integrity use of carbon credits

The EU's Directive on Empowering Consumers for the Green Transition and the proposed Green Claims Directive introduce stricter conditions for environmental claims such as "carbon neutral" or "net zero". These frameworks, if and when adopted, could require companies to demonstrate that any claim involving carbon credits is transparent, science-based, and clearly separated from emissions within the value chain.

This regulatory direction reinforces the need for companies to work with removals that meet emerging quality standards and can stand up to scrutiny from regulators, investors, and ratings bodies.

Act now with confidence as CDR rules become clearer

The policy landscape for carbon removal is advancing quickly, and its direction is increasingly predictable. Frameworks such as the EU's Carbon Removals and Carbon Farming (CRCF) and emerging mechanisms under Article 6 of the Paris Agreement are establishing how removals will be verified, certified, and recognized across markets.

This growing clarity gives companies the confidence to start purchasing high-quality CDR today, knowing that the projects they support are likely to fall within future regulatory definitions of credible removals. Acting early allows organizations to build experience, secure supply, and shape procurement strategies ahead of the point when these rules become fully operational and widely enforced.

Case Study: Airbus commitment to CDR reporting: Airbus already includes a disclosure table aligned with CSRD requirements ESRS E1-7 (Greenhouse Gas Removals and Mitigation Projects) in its 2024 Annual Report. In this section, Airbus explains that it will begin providing detailed information on carbon removal credits once verified removals are delivered, starting from the 2025 reporting cycle.

As a side note, Airbus has already made a significant long-term commitment to CDR by contracting 400,000 tonnes of direct air capture (DAC) removals through its agreement with 1PointFive. These volumes will appear in ESRS-aligned reporting once the removals are generated and verified.