Brussels, 21 May 2026 – A landmark session convened by the European Commission marked a pivotal moment for the EU soil carbon market: the formal opening of the public debate on the demand framework for CRCF-certified carbon farming units.
Carbon Farming Day – the dedicated second day of the European Commission's CRCF Days – brought together policymakers, project developers, standard bodies, financial institutions, and corporate buyers in Brussels to confront a question that will define the trajectory of the EU soil carbon market: how do we build genuine, durable demand for CRCF-certified carbon farming units that fairly rewards farmers and drives real climate outcomes?
ISCIA attended and actively participated in the day's proceedings. Our team contributed to the demand framework discussion and presented ISCIA's position – including our Demand Activation Framework, submitted ahead of the event – which sets out a practical pathway for scaling the market through supply chain co-claiming, registry infrastructure, and aligned financial incentives.
The State of the Market: Further Along Than Many Assume
One of the clearest messages of the day was that the supply side of the EU carbon farming market is more mature than the policy debate often reflects. Estimates presented suggest the pipeline could reach 420 million tCO₂ by 2040, with approximately 20 million tonnes potentially available at the point of methodology launch.
ISCIA's own membership data reinforces this. As board member Robin Saluoks shared in the final plenary session moderated by Deloitte:
"We did a survey among ISCIA members: how many units are going to be produced by 2028? And we are on track to produce more than 10 million units – that's probably around 20,000 farmers. And those farmers are quite excited about changing their practices and storing more carbon into the soil. But they are also expecting there to be clear demand."
The Demand Problem Is Not Just About Volume — It's About Getting It Right
The stakes are high: a poorly designed framework does not just fail to scale the market – it actively undermines it, creating perverse incentives and opening the door to greenwashing at scale.
If accounting and claims guidance remains vague, corporate buyers will exploit the ambiguity – purchasing CRCF units as a low-cost Scope 3 insetting shortcut without meaningful supply chain transformation. This is precisely the kind of outcome that erodes market integrity and farmer trust simultaneously.
ISCIA's position is clear: demand and value must be aligned. The price paid for CRCF units must reflect the genuine cost of carbon sequestration – covering measurement, reporting, and verification (MRV), farmer transition costs, and long-term monitoring. A race to the bottom on price is not a market; it is a liability.
The Free-Rider Problem
A recurring concern raised by Commission representatives and participants alike was the free-rider problem: food companies and other supply chain actors benefiting from the sustainability credentials of carbon farming without contributing financially to the cost of producing verified soil carbon units.
The registry infrastructure becomes critical here. A well-designed EU CRCF registry centralising data on practice change, soil carbon outcomes, and buyer-side allocation rules and accounting reconciliation – can create transparency across the rotation and supply chain, making it possible to identify who is purchasing units, who is claiming value, and who is getting a free ride. Without this data backbone, the free-rider problem is structurally unsolvable.
Co-Claiming: The Viable Path for Supply Chain Engagement
The session on demand frameworks made clear that the traditional offset model – one buyer, one tonne, one claim – is insufficient for the complexity of agricultural supply chains. Co-claiming is not just a policy option; for many supply chain actors, it is the only financially viable pathway to participation.
In a typical crop rotation, multiple actors – input suppliers, grain traders, processors, food manufacturers, retailers – each touch the same commodity. Each has a Scope 3 footprint partially attributable to the same field. A co-claiming structure that allows both vertical co-claiming (across the supply chain) and horizontal co-claiming (across actors within the same rotation) is essential to distribute MRV costs fairly and make buyer participation economically rational.
The MRV Cost Challenge: Lessons from the Field
The economics of MRV remain a significant barrier, particularly for smaller buyers. When a single company bears the full cost of measurement and verification across a project, the per-tonne economics often do not pencil out.
Supply chain MRV cost sharing: A few CPGs in the value chain have been food industry pioneers in exploring how MRV costs can be amortized across multiple supply chain actors purchasing from the same project or rotation. The key insight is that if five buyers share the cost of a third-party verification audit across a single farming landscape, the per-buyer cost drops dramatically – from a potential barrier to a manageable line item.
The registry as cost-sharing infrastructure: A centralised EU CRCF registry – interoperable with existing registries compliant with EU CRCF Delegated Act, such as Verra, and built to accommodate API connectivity – could dramatically reduce the overhead of MRV by enabling data to be submitted once and accessed by multiple buyers.
From Pilots to Policy: The Urgency of Regulation
Perhaps the most direct message from the day was one that ISCIA has been articulating consistently: we cannot stay in pilot mode. The soil carbon sector has spent years demonstrating that the science works, that farmers will participate, and that verified outcomes are achievable. The supply pipeline is building. What is missing is the regulatory certainty that converts pilots into a functioning market.
Participants noted that the current landscape – characterised by small-scale, fragmented pilot projects, absence of long-term offtake agreements, and price volatility – is not a market failure. It is a policy gap.
What is needed
Projects serving both inset and offset markets, with information centralised in the registry to prevent double counting.
Scope 3 alignment guidance from the Commission that gives buyers the accounting clarity they need to make purchasing decisions with confidence.
Standardised, bankable offtake contracts that allow project developers to access project finance.
A CRCF registry that goes live promptly, with interoperability built in from the start.
Public financial de-risking mechanisms – first-loss guarantees, price subsidies, pooled replacement guarantees – that make buyer participation rational in the short term.
ISCIA's Demand Activation Framework
Ahead of CRCF Days, ISCIA developed and shared our Demand Activation Framework – a practical document setting out how the EU soil carbon market can be structured to create durable, fair, and scalable demand for CRCF-certified units.
The framework addresses the core questions raised throughout the day: how to structure co-claiming across supply chains, how to design registry infrastructure that enables rather than burdens market participation, how to price units fairly relative to MRV and farmer transition costs, and how to sequence policy and voluntary mechanisms to create momentum without locking in the wrong architecture.
We welcome engagement with stakeholders: policymakers, buyers, project developers, associations and standard bodies. If you would like to discuss the framework or explore collaboration, please reach out to us at [email protected].
View the Demand Activation FrameworkWhat Comes Next
CRCF Days was the opening of a conversation, not its conclusion. The Commission has signalled that autumn and winter will bring further structured sessions on the demand framework, registry design, and data-sharing infrastructure. Deloitte's use-case work on CRCF units is expected by October. EFRAG implementation guidance will take longer.
ISCIA will continue to be an active voice in these processes – bringing the practitioner perspective of our member companies, grounding the policy debate in market reality, and pushing for a framework that works for farmers, buyers, and the climate.
The soil is ready. The farmers are ready. It is time for the policy framework to catch up.
In addition to being represented in a session, this event had strong representation from ISCIA's membership organisations, including: Agreena, Armosys, BASF, eAgronom, Green Alchemy, InSoil, Oath Biome, ReGeneration, Regrow, Seqana, and many others joining online.