Retiring a carbon credit takes minutes. Defending the retirement can take weeks, because the questions arrive later: from the auditor reviewing the sustainability statement, from the team drafting the annual report, and increasingly from regulators enforcing rules on environmental claims. This guide sets out what those reviewers ask, the record errors that most often fail a review, and how a Retirement Evidence Pack answers every question row by row, with a source and a date for each figure.
- A certificate proves a transaction, not a claim. Auditors also ask whether the vintage existed, whether the tonnage fits, whether the project still stands and what the company says about it.
- The EU rules on environmental claims apply from 27 September 2026. Product claims of neutral or reduced impact based on offsetting are prohibited; contribution claims remain possible.
- Five record errors cause most failed reviews: a vintage the project never issued, tonnes above what the vintage issued, a mistyped or padded identifier, a date before the project issued anything, and a beneficiary that does not match.
- The Retirement Evidence Pack in CRBN.credit matches every retirement to its registry record, adds the project's ICVCM, CORSIA, Article 6 and hazard position, and exports a dated, sourced file as PDF and CSV.
- Why a certificate is not enough
- The rules behind the questions
- The eight questions an auditor asks
- The five record errors that fail a review
- What a Retirement Evidence Pack contains
- Reading the pack: matched, check, not matched
- Describing the retirements
- Building one, step by step
- Frequently asked questions
Why a certificate is not enough
A retirement certificate records that a registry cancelled a quantity of credits, from a project, of a vintage, for a beneficiary, on a date. It is the right starting point and it is where most companies stop. The problem is that the certificate answers the registry's question, which is whether the transaction happened. It does not answer the reviewer's question, which is whether the company's figures and statements about that transaction hold up.
Those are different questions. A company can hold a genuine certificate and still report a vintage that does not match it, add up tonnes from two certificates twice, describe the retirement in words the law no longer allows, or keep citing a project that has since been placed on hold. None of that shows on the certificate. All of it shows in a review.
The rules behind the questions
Three sets of rules drive what reviewers ask in 2026.
Sustainability reporting. Under the European Sustainability Reporting Standards, disclosure requirement E1-7 asks companies to report the carbon credits cancelled in the reporting period outside their value chain, the share that comes from removals and from reductions, and the recognised quality standards the credits were verified against. IFRS S2 asks companies that use carbon credits toward a climate target to explain that planned use. Both need a clean, project-level record to compile.
Consumer claims. Directive (EU) 2024/825 applies from 27 September 2026. It prohibits claims to consumers that a product has a neutral, reduced or positive environmental impact because of greenhouse gas offsetting. The practical effect is that the wording used about retirements moves from "neutral" to "contribution", and a company needs to know which of its statements fall on which side.
Target standards. The SBTi Corporate Net-Zero Standard Version 2.0 takes effect on 1 February 2027 and introduces a removal requirement for Category A companies from 2035. Credits retired now are increasingly read against where a company will need to be later.
The eight questions an auditor asks
Across reviews, the same questions come up. A good evidence file answers each of them before it is asked.
- Does each retirement correspond to a real project on a named registry?
- Did the project issue credits of the vintage recorded?
- Does the tonnage recorded fit within what that vintage issued?
- Is the retirement date consistent with the project's history?
- Does the registry record name your organisation as the beneficiary?
- What is the project's current status, and has anything changed since the retirement?
- What standard and methodology were the credits verified against, and what have the ICVCM and ICAO concluded about them?
- How does the company describe the retirements, and is that wording supported?
The five record errors that fail a review
When retirement records are checked against registry data at scale, the same five errors account for most of the problems.
| Error | How it happens | How it shows in a pack |
|---|---|---|
| A vintage the project never issued | The year of purchase or retirement is recorded instead of the vintage | Check: this vintage was never issued by the project |
| Tonnes above what the vintage issued | Two certificates added together, or a typing error | Check: tonnes exceed what the vintage issued |
| An identifier that matches nothing | Zero padding, a Gold Standard GS number against a GLD record, or a mistyped ID | Resolved automatically where the intent is clear; otherwise Not matched, with the reason |
| A date before the project issued anything | Contract date recorded instead of retirement date | Check: dated before the project first issued credits |
| A beneficiary that does not match | Credits retired under a subsidiary or a trading name | Beneficiary check: different beneficiary recorded |
Each of these is easy to fix when it is found early and expensive when it is found by a reviewer. The point of the pack is to find them first.
What a Retirement Evidence Pack contains
The Retirement Evidence Pack in CRBN.credit is built from your Retirement Ledger or from a CSV of retirements. Its first page carries one sentence that frames everything after it: Prepared from registry records and published criteria on the date shown. Not an assurance opinion. Then:
- At a glance: rows given, rows matched, rows to check, rows not matched, rows that could not be read, tonnes given and tonnes on matched rows. Nothing is dropped, so the totals reconcile with the file you provided.
- Summary tables by project type, by registry, by vintage band and by ICVCM status. Vintage bands split at 2016, the line CORSIA draws.
- Every retirement, with its status and the named reason for any issue.
- Row detail for every matched retirement: the project record and the date it was read, the vintage check, the ICVCM decision, the CORSIA screen, the host country's Article 6 position, hazard exposure and the beneficiary check, each dated.
- Describing these retirements: wording for the largest retirements that the Green Claims Checker rates lower risk.
- Sources, each with the date it was read.
It exports as a PDF for the audit file and as a CSV with one row per retirement and every fact in its own column, ready for the team compiling the ESRS or IFRS figures.
Build your evidence pack.
The Retirement Evidence Pack sits in the Retirement Ledger, inside the terminal, and building one does not use your monthly allowance.
Reading the pack: matched, check, not matched
Every row carries one of three statuses.
Matched means the retirement resolved to a project in registry records and no check found a problem: the vintage was issued, the tonnage fits, the date is consistent.
Check means the project was found but something in the record needs attention, and the reason is named: a vintage never issued, tonnes above the vintage, a future date or a date before the project issued anything. These are the rows to correct before a review.
Not matched means no project with that identifier or name exists in registry records. Most of these are typing errors. A few are projects recorded under a trading name, which the reason makes clear.
Lines that could not be read at all, such as a row with no project identifier or no tonnage, are listed separately with their data row number, so they can be found and fixed in the source file.
Describing the retirements
Once the record is clean, the remaining question is what to say. The rules now distinguish sharply between two kinds of statement.
- Neutralisation claims say or imply that emissions are cancelled out: "carbon neutral product", "climate neutral shipping". For products marketed to consumers in the EU, these are prohibited from 27 September 2026 where they rest on offsetting.
- Contribution claims describe what the company did without implying its footprint is gone: "In 2025 we retired 5,000 tonnes of carbon credits from a named project, registered with a named registry, as a contribution to climate action beyond our own value chain."
The pack offers contribution wording for the largest retirements that the Green Claims Checker rates lower risk, and leaves out any row still marked Check. Each suggested sentence can be opened straight in the checker to test variations.
Wording is where good records most often become bad claims. A company can retire high quality credits, record them perfectly, and still breach the rules with one sentence in a product description. Testing the sentence is as important as testing the record.
Building one, step by step
- Choose the source. From my ledger, if you record retirements in the Retirement Ledger, or from a CSV file.
- If you use a CSV, include a header row with a project identifier, vintage, tonnes and retirement date. Serial numbers and beneficiary are read if present. Registry exports are recognised in their usual layouts.
- Build the pack and read the At a glance figures first. If rows are marked Check or Not matched, correct them at source and build again.
- Open the row detail for any project you want to understand better, or open it in the Project Dossier.
- Export the PDF for the audit file and the CSV for the reporting team.
A CSV used to build a pack is read for that pack only and is never stored. The Retirement Ledger, by contrast, keeps your retirements and re-reads the projects behind them every time you open it, so a change of status after you retired reaches you through the ledger.
| Project ID | Vintage | Quantity | Retirement date | Serial |
|---|---|---|---|---|
| VCS1748 | 2021 | 300 | 2025-02-01 | optional |
| GS1247 | 2019 | 200 | 2023-06-01 | optional |
The layout above is the minimum. Gold Standard identifiers are recognised whether they are written as GS or GLD numbers, and zero-padded identifiers are matched to their registry form.
Related reading. The evidence pack starts from a clean purchase: see carbon credit due diligence in one terminal for the checks to run before buying, and carbon market monitoring in 2026 for keeping retired positions under watch. Every project in a pack also has its own page in the project database.
Frequently Asked Questions
Is a retirement certificate enough evidence for an audit?
Usually not on its own. A certificate shows that a registry cancelled a number of credits for a beneficiary. An auditor will also want to know that the vintage was actually issued by the project, that the tonnage fits within it, that the project's status still supports the claim, and what the company says publicly about the retirement.
What does ESRS E1-7 ask about carbon credits?
Companies reporting under the European Sustainability Reporting Standards disclose the carbon credits cancelled in the reporting period outside their value chain, the share from removals and from reductions, and the recognised quality standards the credits were verified against. A retirement record that is matched to each project and methodology makes those figures straightforward to compile.
What changes on 27 September 2026?
The EU rules on environmental claims to consumers in Directive (EU) 2024/825 apply from that date. Claims that a product has a neutral, reduced or positive impact on the environment because of greenhouse gas offsetting are prohibited in consumer communication. Contribution claims that describe support for climate action, without implying the product's footprint is cancelled, remain possible.
What wording is safer for retired carbon credits?
Wording that describes a contribution rather than a neutralisation: for example, that the company retired a stated number of credits from a named project, registered with a named registry, in a stated year, as a contribution to climate action beyond its own value chain. The Green Claims Checker tests a sentence against the rules and explains the risk.
Can I build an evidence pack from a registry export?
Yes. The Retirement Evidence Pack accepts a CSV with a project identifier, vintage, tonnes and retirement date, and reads common registry export layouts. The file is used to build the pack and is not stored. It can also be built from the Retirement Ledger if you record retirements there.
Is the evidence pack an assurance opinion?
No. It reports what registry records and published criteria show, with the source and date for every figure, and says so on its first page. Assurance is the auditor's role; the pack gives the auditor a complete, traceable file to work from.
A note on this article. Descriptions of ESRS E1-7, IFRS S2, Directive (EU) 2024/825 and the SBTi Corporate Net-Zero Standard summarise the position at the time of writing and are not legal advice. The Retirement Evidence Pack reports what registry records and published criteria show and is not an assurance opinion.