Voluntary carbon credits: verification, value, and prospects for Ukraine

What are voluntary carbon credits and how do they differ from regulated ones?

Voluntary carbon credits are a special tool for reducing greenhouse gas emissions, which companies and individuals use on a voluntary basis. Each such credit corresponds to one tonne of CO₂ equivalent, the emission of which has been avoided or removed from the atmosphere as a result of the implementation of a specific environmental project. Unlike official (compliant) carbon credits, which arise within the framework of mandatory programs defined by law (e.g., EU ETS quotas or Kyoto Protocol credits), voluntary credits are traded on the private market without direct government regulation. Government schemes set mandatory emission limits and issue permits (credits) within those limits, while the voluntary market has emerged in parallel as an initiative of businesses and the public seeking to reduce their carbon footprint beyond the requirements of the law.

Why did the voluntary market emerge? The fact is that many companies set their own climate goals — for example, to achieve net zero by a certain year — even if they are not required to do so by law. Voluntary carbon credits make it possible to offset emissions that cannot yet be avoided by financing external projects to reduce or absorb CO₂. In other words, if a company cannot completely reduce emissions within its production, it can invest in climate conservation projects and credit the emissions reductions achieved by those projects to its own assets. This is the concept of carbon neutrality: for example, an airline calculates its own emissions from flights and purchases an equivalent amount of credits in a forest restoration or renewable energy project to “zero out” its emissions balance.

The advantage of voluntary credits is that they provide flexibility and incentives where laws do not apply. They help channel funding into projects that would not otherwise happen, as it is often the sale of credits that makes such projects economically viable. In this way, the voluntary market acts as an additional climate finance mechanism, mobilizing private funds to combat climate change outside of mandatory quotas. It coexists with official schemes and does not replace them, but complements them: companies continue to comply with regulatory requirements (where they exist), but voluntarily take extra steps for the sake of corporate social responsibility, a “green” image, or preparation for future stricter rules.

It should be emphasized that purchasing voluntary credits does not exempt companies from the need to reduce their own emissions. It is only a compensation tool. Leading principles, particularly those of the British government, require that credits be used only in addition to ambitious measures to decarbonize the business itself. That is, first — energy efficiency, clean technologies, and only after maximum reduction — compensation for the remaining emissions through high-quality credits.

How are voluntary carbon credits generated and verified?

The source of voluntary credits is special projects that either avoid emissions or remove CO₂ from the atmosphere. Examples include forest restoration projects (tree planting absorbs CO₂), the introduction of renewable energy (to replace fossil fuels and avoid new emissions), the introduction of energy-efficient technologies, wetland restoration, direct CO₂ capture from the air, protection against deforestation (REDD+), and so on. The key requirement for all these projects is additionality: the project must generate emissions reductions beyond “business as usual,” i.e., reductions that would not have occurred without the financial incentive from the sale of carbon credits. If, for example, a wind farm is already profitable on its own thanks to a “green” tariff, then selling credits to it is simply additional income that does not lead to new climate benefits. Such a project would not be considered additional, and issuing credits to it would not make sense. On the other hand, if a project is not feasible without income from credits (for example, a farmer implements regenerative farming practices that do not pay off without monetizing carbon sequestered in the soil), then this project is additional, and each ton of reduced emissions can be registered as a separate credit for sale. The principle of additionality is the foundation of the environmental value of credits; in effect, it ensures that when a company purchases a credit, it is financing a real new reduction/removal of CO₂, rather than paying for something that would have happened anyway.

The process of creating credits usually involves several stages. First, the project developer selects a verification standard — an independent organization that sets requirements and methodologies for evaluating carbon projects. The most common global standards are, for example, Verified Carbon Standard (Verra), Gold Standard, American Carbon Registry (ACR), Climate Action Reserve, and others. New platforms are also emerging, such as the International Carbon Registry (ICR) and others. The developer prepares a detailed project document, which outlines the baseline scenario (what would happen without the project) and the projected emissions reductions achieved by the project.

The project then goes through a validation and verification stage: an independent audit (known as VVB — Validation and Verification Body) checks whether the project complies with the standard methodology and whether the claimed emission reductions are realistic. Auditors are accredited by the standards themselves and act as a “third party” quality control. At this stage, everything is checked — calculations of baseline emissions, the monitoring plan, environmental and social risks (e.g., leakage — will the project lead to increased emissions elsewhere; permanence — how long will CO₂ remain sequestered, especially relevant for forests that may burn; impact on communities and biodiversity, etc.). After successful verification, the standard registers the project and issues the corresponding number of credits to its electronic registry. Each credit has a unique serial number and is stored in the owner’s account in the registry until it is sold or redeemed.

The voluntary market infrastructure includes several key players: 

• standards and certification bodies — they manage methodologies and credit issuance (e.g., Verra, Gold Standard);
• independent auditors (verifiers) — they validate/verify projects for compliance with the standard;
• credit registries — electronic platforms where credits are issued, stored, and transferred. Often, the standard itself maintains a registry (Verra Registry, Gold Standard Impact Registry), but there may also be separate registries such as ICR or APX. The registry tracks the “life cycle” of each credit – from issuance to retirement, when the credit is permanently written off to credit the emission reduction to a specific end buyer.

Only then do the credits enter the market, where they can be purchased by anyone interested (a corporation, organization, or even an individual). Typically, sales take place either directly (from the developer to the buyer under a bilateral agreement) or through intermediaries and trading platforms. More details on trading mechanisms are provided below.

Quality assurance: how to prove that a credit is “real” and valuable?

Since voluntary credits are not strictly regulated by the state, it is critical for businesses to verify their environmental quality. Unfortunately, not all credits are equally valuable from a climate perspective — some projects deliver real, additional reductions, while others may suffer from questionable methodology or double counting. Reputational risks are also high: by purchasing a “low-quality” credit, a company risks being accused of greenwashing (declaring non-existent climate achievements). Therefore, third-party verification and compliance with recognized standards are key to trust. A large investor, such as the Norwegian sovereign wealth fund (Norges Bank IM), explicitly requires companies to ensure that “any credits purchased must be additional and verified.” In other words, the focus is on “high integrity”: real, non-double-counted, verified reductions, preferably with a long-term effect.

There are several criteria for the quality of voluntary credits that are worth paying attention to: 

• additionality (mentioned above) — the project would not have taken place without carbon finance;
• no double counting — the same ton of CO₂ cannot be sold to two different parties or counted towards both a country’s national target and the purchasing company’s target. This raises the issue of so-called corresponding adjustments under the Paris Agreement: to avoid a situation where the credit-producing country includes this reduction in its national achievements, and a foreign company also uses it for its own purposes. So far, this issue has been regulated voluntarily in the voluntary market, but for compliance programs (CORSIA for aviation, the future Article 6 of the Paris Agreement), this requirement is already relevant. The purchase and sale contract should clearly specify whether such a letter of adjustment from the government of the generating country is required;
• permanence — guarantees that the absorbed CO₂ will not be released back into the atmosphere. For biological projects (forests, soils), there is always a risk of fire, deforestation, or degradation, so standards introduce buffer reserves of credits in case of such reversals. For example, part of the forest credits are reserved and not sold — this is insurance that is canceled if the forest burns down. The buyer should be interested in whether these risks are taken into account and how potential losses are compensated;
• methodological restraint — credits should be calculated based on conservative estimates. In other words, it is better to underestimate slightly than to overestimate. For example, for a project to avoid deforestation (REDD+), it is critical to correctly determine the baseline level of deforestation: an overestimated baseline scenario will lead to crediting “phantom” reductions. In recent years, independent analyses have found that some early methodologies produced inflated baseline figures for forests, resulting in credits being issued that exceeded the real climate benefits. Current standards and initiatives introduce stricter ratings and checks for such situations;
• liquidity and transparency — credits must be sold through transparent platforms and registries so that everyone can track their path (issued → sold → retired). This prevents the same credit from being resold. Blockchain technologies are now beginning to be used to track the paths of credits, increasing confidence in the market.

The market’s response to quality issues has been the introduction of new global initiatives and “high quality” standards. For example, in 2021, the Integrity Council for the Voluntary Carbon Market (IC-VCM) was established, which developed the Core Carbon Principles (CCP) — a core set of principles for quality credits. The IC-VCM recently approved the first methodologies that comply with these principles, including projects for landfill gas collection and the destruction of ozone-depleting substances, while some older methodologies for renewable energy did not pass this “filter” as they were not sufficiently additional. This is a signal to the market: loans from projects that do not meet the new criteria will lose demand. Companies are advised to choose only high-quality credits. For example, Norges Bank IM (which manages the Norwegian pension fund) clearly states in its expectations for businesses: first, reduce your own emissions, and if you buy credits, then only additional, verified, and preferably long-term CO₂ removal credits. In November 2024, the British government issued principles for the use of voluntary credits, which specifically emphasize: use only high-integrity credits that have undergone independent validation/verification, do not double count, take into account the risk of leakage and reversal, respect the rights of local communities, and bring additional environmental or social co-benefits. These principles, as well as the work of organizations such as IC-VCM and the Voluntary Carbon Market Integrity Initiative (VCMI), are setting a new quality benchmark in the market, and responsible companies are increasingly adhering to them.

Finally, an important practical aspect is credit portfolio diversification. Since each project has its own risks and uncertainties, experts advise businesses not to rely on a single type of credit. The so-called portfolio approach means acquiring a set of credits from different projects and categories: for example, some from forestry projects, some from technology projects (DAC, biochar, etc.), from different geographies and with different delivery times. First, this reduces risks (if, for example, one project does not generate the expected amount of credits due to force majeure, other projects will compensate for this). Second, it has a combined effect: some credits may be cheaper and more readily available (e.g., from emission avoidance projects), while others may be more expensive but have a greater long-term impact (from CO₂ removal projects). This balance allows us to stay within budget while supporting innovative solutions. The Oxford Principles for Carbon Offsetting (2020), considered the “gold standard” for climate strategies, recommend precisely this evolution: invest now in a mix of projects, gradually increasing the share of those that remove CO₂ permanently (long-term storage), and eventually transitioning entirely to removal, abandoning short-term offsets. Many companies are listening to this advice, forming credit portfolios in the same way as financial portfolios — weighing risks, impact, and cost.

Global trends and leading voluntary credit markets

The voluntary carbon market has experienced a real boom in recent years. According to Fastmarkets, demand for such credits grew explosively between 2016 and 2021, in parallel with the wave of corporate commitments to net zero and climate goals. The volume of credits used (i.e., redeemed for compensation claims) worldwide increased from ~31 million tons of CO₂ in 2016 to over 160 million tons in 2021. After some stagnation in 2022 due to criticism of the quality of some projects, the market resumed its growth: in 2023, 163 million tCO₂ had already been redeemed – a new record. In monetary terms, the global voluntary market was valued at approximately $2 billion in 2022, and forecasts (e.g., McKinsey, Taskforce on Scaling Voluntary Carbon Markets) suggest growth to tens of billions of dollars per year by 2030, provided that confidence in the quality of credits is ensured.

The leaders in terms of market size are primarily the United States and Europe. In the US, although there is no single national emissions trading system (except for sectoral schemes such as California’s), there is a large corporate movement for voluntary carbon neutrality. Many American corporations (Big Tech, airlines, banks) regularly purchase offsets to partially neutralize their emissions. The US market is well developed, with many project developers and brokers operating, as well as startups emerging from marketplaces and fintech solutions in this area. The US government is beginning to pay attention to this segment: the role of the Commodity Futures Trading Commission (CFTC) in supervising voluntary carbon markets as a commodity is being discussed in order to prevent fraud and ensure transparency, although there are no direct regulations yet.

The European Union has historically focused on the mandatory market (EU ETS for large enterprises), but voluntary offsets are also gaining momentum here, especially for sectors not covered by the ETS (flights within the EU are partially offset through CORSIA, private businesses offset their uncovered emissions, consumers can purchase “green” services with compensation, etc.). European companies are increasingly shifting their focus to the quality of offsets. After a series of critical studies that revealed problems with some forest credits, there was some skepticism in Europe, but work is now underway to restore confidence: The European Commission is developing a regulation on carbon sequestration certification, which aims to set standards for voluntary sequestration projects (e.g., soil carbon, CO₂ capture technologies) and ensure their scientifically sound measurement and no double counting in countries’ targets. The EU is also introducing the Carbon Border Adjustment Mechanism (CBAM), which, although not directly related to voluntary credits, encourages Ukrainian and other exporting companies to reduce their carbon footprint, potentially through the purchase of offsets. Some European governments (the UK, Sweden, the Netherlands) have already issued guidelines for businesses on the use of high-quality offsets and proper disclosure of information.

After leaving the EU, the UK is taking steps to develop a transparent voluntary market within the country. In 2024, the government published the principles of high integrity (mentioned above) and launched consultations on the creation of an accreditation system for nature-based projects and reporting standards. As a financial center, London is seeking to become a hub for carbon credit trading. With this in mind, Mark Carney’s initiative (Taskforce on Scaling Voluntary Carbon Markets) has received strong support from the British financial sector. This means that in the future, we can expect to see even more structured platforms and, possibly, derivatives on voluntary offsets under English law.

Other regions are also active. Singapore is positioning itself as the Asian hub for carbon credit trading: it is home to the large digital exchange AirCarbon Exchange, launched in 2019 for global transactions. The Middle East: Saudi Arabia and the UAE have held large-scale voluntary credit auctions, declaring their intention to become major players (for example, the Saudi sovereign wealth fund organized auctions in 2022–2023, where millions of tons of offsets were sold to stimulate the regional market). Australia has its own certificates (ACCU) for the domestic market, but Australian projects also sell credits internationally — which, incidentally, is where a significant portion of the supply on the ACX exchange comes from. So, the market is truly global and fragmented: there is no single global exchange yet, but there are many regional and private platforms that interact with each other.

Trading infrastructure. Today, voluntary credits can be traded in various ways. For large transactions, direct bilateral agreements (offtake contracts) between the buyer and the project developer are popular. For example, Microsoft has entered into several long-term agreements to purchase future CO₂ removals: in 2021–2023, the company contracted more than 10 million tons of forest credits (AFFORESTATION) for a 30-year period, thereby investing in the development of these projects. Another approach is to turn to specialized offset providers (South Pole, Climate Impact Partners, mini-platforms such as Patch or Shopify), which select a portfolio of credits to suit the client’s needs. For those who want to trade independently, digital exchanges and markets have emerged. The most well-known are: 

• Xpansiv CBL (formerly known as Carbon Base Load) — the largest global spot trading exchange for voluntary credits, headquartered in the US; 
• AirCarbon Exchange (ACX) — a Singapore-based exchange offering instant deals, tokenized credits, and a large customer base in Asia; 
• Carbon Trade Exchange (CTX) — one of the first online exchanges (since 2009) where participants can list their credits from various standards (Verra, Gold Standard, CDM, etc.) and trade directly through the platform; 
• Climate Impact X (CIX) — a Singapore-based international platform for large batches of nature-based credits, supported by major banks; 
• CarbonMark — a newer marketplace that integrates with blockchain. For example, CarbonMark works with the International Carbon Registry to place projects and credits directly on its marketplace, enabling fast transactions and full transparency regarding credit status. Recently, ICR-registered projects were listed there, including the Ukrainian project “Ovid Wind Farm” in Odesa region — a wind farm that sells its credits for green electricity generated.

In addition to exchanges, experimentation with loan tokenization (converting them into crypto tokens for trading on blockchain platforms) is ongoing. The idea is that each token represents 1 ton of CO₂, and all credit attributes (standard, project, year, etc.) are embedded in a smart contract. Such tokens can be traded on decentralized exchanges, theoretically increasing liquidity and transparency. Some projects (e.g., Toucan, KlimaDAO in 2021) have attempted to tokenize Verra credits en masse, but have faced difficulties and criticism (Verra even temporarily suspended this due to the risk of double counting). Developers are now working with standards to formally integrate blockchain — the ICR example shows how the registry itself uses a public blockchain to ensure the integrity of records. In any case, it is important for the end business user that the platform guarantees that the purchased credit will be redeemed on their behalf or transferred to their account and then redeemed so that no one else can use it.

Overall, the trend is that demand is shifting towards high-quality, transparent credits. Better less, but better — many companies openly declare the priority of quality over quantity. For example, the Ecosystem Marketplace 2023 study notes that demand is concentrated on more expensive but proven credits, while cheap mass offsets (such as old renewable energy projects with questionable additionality) are losing buyers. This “shift towards quality” is already noticeable in prices: nature-based solutions with proven additionality (reforestation, peatland protection, etc.) are selling at higher prices and remain stable despite the general decline in prices, while prices for some avoidance credits (especially old wind farms and hydroelectric power plants) have fallen by 50-80% due to skepticism about their usefulness. Companies are willing to pay more for a guarantee of real climate impact.

Carbon credit purchase and sale agreements: features and risks

The legal formalization of transactions on the voluntary market is no less important than the technical quality of credits. Since the legal framework for regulating these assets is unclear, the agreement between the parties becomes the main instrument for protecting interests and distributing risks.

The simplest case is the purchase of already issued credits on the spot market (ex-post credits). Here, the purchase and sale agreement usually confirms that the seller transfers a certain number of clearly identified loans (specifying the standard, register, project, serial numbers, or reference to the register block) to the buyer at an agreed price. It is important that the agreement includes the seller’s guarantee of clear legal title to these credits: that they have the right to dispose of them and that they are not encumbered by any third-party rights (e.g., not previously sold to another party). It should also be specified how the transfer will take place: either by transfer to the buyer’s account within the same registry, or by redemption in favor of the buyer (in which case the seller redeems the credits and indicates the name/purpose of the buyer in the registry). The second method is often used when the ultimate goal is to claim compensation: a redeemed credit can no longer be resold to anyone.

More nuances arise with so-called forward contracts or ERPA (Emission Reduction Purchase Agreement), where a company agrees to purchase credits that will be issued in the future when the project generates reductions. Such agreements are similar to deferred delivery contracts. For example, a business invests in a forestry project, agreeing to supply N credits each year for 10 years at an agreed price. The IETA (International Emissions Trading Association) model contracts for 2023 include several important points: 

• precedent conditions are included — for example, the project must be registered under a certain standard by a certain date, and the seller must provide a legal opinion that they own the project’s emission rights and can sell credits;
• the schedule for the delivery of credits (which years, what volumes) and the price are specified, as well as provisions for possible losses. In particular, if the project is unable to issue the agreed volume of credits (e.g., due to crop failure, fire, etc.), the seller undertakes to make efforts to compensate for the shortfall — for example, to provide equivalent credits from other projects or, at a minimum, to return part of the funds. The IETA model contract stipulates that if the shortage is the seller’s fault (fraud, gross negligence), the buyer has the right to demand either replacement of the volumes or reimbursement of the costs of purchasing equivalent credits on the market;
• the issue of credit buffers is being discussed: for forestry projects, it may be stipulated that the amount supplied is already net of the necessary reserve for reversals (so that the buyer does not pay for credits that will go into the buffer pool anyway);
• monitoring and verification: as a rule, the contract refers to the rules of the selected standard. It is important for the buyer to ensure the reliability of the standard according to which the credits are issued, since the contract usually does not re-evaluate quality — it assumes that the standard guarantees it. Therefore, choosing the right partner and standard is a big part of success: legally, the buyer can demand the delivery of specific loans, but if the loans themselves turn out to be “unsuitable” (for example, the market does not recognize them due to a scandal), the contract may not protect against reputational damage;
• force majeure and early termination: as in other commercial contracts, cases are specified when the parties may fail to fulfill their obligations without penalties (war, changes in laws, natural disasters, etc.), as well as lists of default events (failure to deliver/pay, breach of representations and warranties, failure to fulfill conditions, etc.). Upon default, the counterparty has the right to terminate the agreement and claim damages.

Another point is jurisdiction and regulation. The absence of a special law means that such agreements are governed by general rules of contract law. Parties often choose the law of England or New York and arbitration to resolve disputes, as these jurisdictions are well known in the field of commerce. In 2023, as mentioned, the IETA proposed standardized contract forms, which should simplify negotiations and reduce the variability of terms. The emergence of standardized contracts is a sign of market maturity and increased confidence, as participants receive a clear framework for cooperation.

Buyers and sellers should also consider tax and accounting aspects. In particular, different countries interpret offset costs differently: in some places, they can be included in the cost of production as part of a climate strategy, while in others they cannot. Before signing a large contract, it is worth analyzing whether the supply of credits is subject to, for example, VAT or customs duties (in the EU, trading in quotas is subject to VAT, but international offsets may be a gray area). This is another reason why legal support for such agreements is necessary: specialists will help draft the contract in such a way as to maximally protect the client’s interests, ensure compliance with best market practices (the same IETA standard), and provide for exit, replacement, or compensation mechanisms in case of unforeseen situations.

Prospects for Ukraine: creation and sale of voluntary credits

For Ukraine, the topic of voluntary carbon credits is relatively new but has significant potential. Our country is actively integrating into European climate policy: back in 2018, Ukraine approved a low-carbon development strategy until 2050, and in 2023–24, it adopted a legislative framework for launching its own emissions trading system (ETS). In particular, in October 2024, the Law “On the Fundamentals of Climate Policy” was adopted, which provides for the launch of pilot trading in quotas from 2026. This will be a regulated market for large enterprises. But at the same time, opportunities are opening up in the voluntary market, where the rules are more flexible and action can be taken now.

Ukraine has significant potential for projects that can generate voluntary credits: 

• the agricultural sector and soil carbon. Ukrainian black soil can serve as a huge CO₂ sink if regenerative practices are implemented (no-till, cover , organic farming). There are already case studies: for example, after 2022, the Ivan Franko Agricultural Enterprise was able to diversify its income by earning money from the sale of carbon credits for soil carbon restoration. Project developers and consultants have appeared in Ukraine to help farmers obtain certification according to international methods (Verra VM0042 for soils, Gold Standard methods, etc.). Large agricultural holdings are showing interest, although it is still difficult for small farmers due to the cost of monitoring and uncertainty (state support or grants are needed here to attract SMEs). Nevertheless, soil projects are one of the most promising areas, especially in the context of post-war land restoration; 
• forest projects. Ukraine is one of the leaders in Europe in terms of forest area, with primeval forests of global importance preserved in the Carpathians. Unfortunately, the war has caused enormous damage to the forest fund: in 2022–24, hundreds of thousands of hectares of forest were burned or destroyed by hostilities. This is a tragedy, but also a challenge: large-scale forest restoration programs in de-occupied territories could become the basis for generating millions of carbon credits (AF/RF projects). In the western regions, projects to preserve old-growth forests (REDD+) are relevant, such as the creation of new nature reserves, which can be financed by the sale of credits for avoiding deforestation. Experts have calculated that the total carbon stock of Ukrainian forests is of enormous value: even at a price of $7 per ton, it is estimated at ~$41 billion, and in a high scenario (€75/t) — up to $480 billion per year! Of course, this potential is contingent on the preservation/expansion of forests and the monetization of the entire carbon volume, but the sheer magnitude of the figures is impressive. This can only be achieved through the gradual attraction of investment, project development, and strict control. It is critical to ensure transparency and sustainable management here: otherwise, we risk either not getting buyers (if the quality is questionable) or harming ecosystems. Fortunately, there are international initiatives (e.g., IKI in the Carpathians, World Bank projects) that help lay the groundwork for such schemes. Plans are already being made for post-war forest restoration, taking into account financing through carbon credits;
• energy and industry. We have significant potential for biogas projects, waste management, and renewable energy outside of green tariff schemes. For example, Odessa’s Ovid Wind Park is registered in the International Carbon Registry (ICR) and sells credits for the clean electricity it generates. This is a pioneering case for Ukraine. There are opportunities to implement projects involving methane combustion at solid waste landfills, mine methane utilization, and energy efficiency improvements at factories — all of which can be done through voluntary credits if properly formalized. Previously, under the Kyoto Protocol, there were more than 100 joint implementation (JI) projects in Ukraine — this experience can be reactivated in the voluntary market. Moreover, in the context of the upcoming CBAM, it is beneficial for our industry to demonstrate emissions reductions, and voluntary offsets can be a temporary solution (again, if they are of high quality).

How to create a project and sell credits? The absence of internal rules does not prevent Ukrainian entities from using international standards. The algorithm is as follows: 

1. find a project idea (there are emissions that can be reduced or an area where CO₂ can be absorbed);

2. choose a standard and methodology. If it is a forestry project, pay attention to the REDD+ or ARR methodologies from Verra or Gold Standard; if it is agriculture, VM0042 (Verra) is currently popular for improving land use; if it is waste, methane methodologies, etc;

3. engage an accredited partner. As mentioned, companies have emerged in Ukraine that provide turnkey assistance: they will conduct basic measurements, prepare documentation, and organize verification. One such company is the Agreena project, which cooperates with Ukrainian farmers and has successfully verified a number of soil projects under the VCS (Verra) standard;

4. after registering the project and issuing credits, the question of sales arises. Here, Ukrainian beneficiaries should focus on the international market, as there is no domestic market yet. The easiest way is to list credits on one of the global marketplaces. For example, after registering a project with Verra, you can either search for buyers yourself through brokers or use a platform such as Carbon Trade Exchange, where you simply need to link your registry account and list the credits for sale. Another way is to cooperate with funds or aggregators: there are funds that specialize in buying credits from certain regions or technologies for resale to large customers. For example, the Ovid Wind Farm project found its way onto the CarbonMark marketplace through integration with ICR, making its credits available to global buyers online;

5. legal aspects must also be taken into account: Ukrainian legislation does not yet regulate the status of voluntary carbon credits. Theoretically, this can be considered as an emission reduction service or as an intangible asset. It is important to ensure that the agreement with the buyer is properly formalized (if, for example, they are a non-resident): determine the law, place of dispute resolution, etc., as described above. In the future, when Article 6 of the Paris Agreement comes into force, it may be necessary to obtain letters of authorization from the state for the international transfer of reductions in order to avoid double counting. At present, Ukrainian projects on the voluntary market operate independently of national targets, but government policy in this area should be monitored.

Why is this interesting for Ukrainian business and the state? First, it is an additional source of funding for environmental projects. For example, a farmer who has reduced tillage and improved soil fertility not only receives agronomic benefits but also sells credits — a real cash bonus for environmental services. Second, it is about image: Ukrainian companies that are part of international supply chains can demonstrate to their partners that they are environmentally responsible and voluntarily offset their emissions. This is a plus in the eyes of investors, banks, and consumers, especially in the demanding markets of the EU and the US. Thirdly, for the state, the development of this market is an opportunity to attract green investments in post-war reconstruction. If the right steps are taken, Ukraine could become a case study in how carbon projects can restore ecosystems, generate income for communities and businesses, and contribute to the global fight against the climate crisis. The “Carbon for Peace” concept promoted by some experts is precisely about this: financing carbon sequestration can go hand in hand with peacebuilding and social goals — restoring nature in war-torn areas, creating jobs in green projects, integrating veterans into eco-projects, and so on.

Of course, success will depend on institutional capacity. It is necessary to train local specialists in carbon measurement and verification, involve scientific institutions, and educate communities. Controls are needed to prevent abuse under the guise of carbon projects (for example, deliberately setting fire to forests in order to receive money for their restoration — such risks cannot be ruled out). But with proper transparency and civil society participation, it is possible to build a sustainable domestic market in the future that will integrate with the global market.

I believe that it already makes sense for Ukrainian companies to experiment with pilot projects: choose one area or direction and try to certify the reduction. This will provide invaluable experience and position them as pioneers in this field. As the head of energy law practice and as a person who has been working on the development of green energy in Ukraine for six years, I am convinced that voluntary carbon credits are an opportunity for our business to demonstrate innovation and responsibility at the same time. And for legal advisors, a new niche is opening up — helping clients safely and effectively realize their potential in this new market.

For Ukraine, entering this market is not just a tribute to fashion, but also a strategic necessity and opportunity. Without waiting for the launch of the mandatory ETS, our projects can already attract “green” capital through voluntary credits — and thus accelerate environmental modernization. This is in line with the European integration course and global trends. With proper support, the state can achieve a win-win situation: nature is restored, businesses and communities receive additional income, and the country’s image as an environmentally responsible player grows.