CSRD Article 19a & ESRS E1-7: What buyers must disclose about carbon credits

Why this matters

From financial year 2025, large EU companies (and UK companies with significant EU operations) must publish a sustainability statement under the Corporate Sustainability Reporting Directive (CSRD). Article 19a requires this statement to be assured by an independent auditor. The European Sustainability Reporting Standards (ESRS) define exactly what must be disclosed. Carbon credit purchases sit squarely inside ESRS E1-7.

If you buy a carbon credit and intend to count it towards your climate-related disclosures, your auditor will ask three questions: where did this credit come from, what evidence do you have that it represents a real tonne of CO2 reduction or removal, and have the credits been retired (taken out of circulation) so they cannot be double-counted?

What ESRS E1-7 actually requires

ESRS E1-7 covers GHG removals and storage financed through carbon credits. The disclosure must include the total volume of credits, the project type (avoidance vs removal), the registry, the vintage, whether the credit is from inside or outside the company's value chain, and the underlying methodology.

Critically, ESRS E1-7 distinguishes between credits used to make claims (such as carbon neutrality statements) and credits used to support a company's transition plan. The evidentiary bar is higher for the former. Auditors will look for project-level evidence, not registry summaries.

The five pieces of evidence your auditor will ask for

• Project identifier on the public registry (Verra VCS-XXXX, Puro Project ID, etc) — must be independently verifiable
• Methodology citation (VM0047, Puro Biochar, VM0033 etc) with the specific version applied to this project
• Vintage year of the credit and date of issuance
• Retirement serial number — proof the credit has been retired in your company's name on the registry
• Source of any quality scoring or independent assurance applied beyond the registry's own verification

Where most buyers get caught out

Auditors increasingly reject 'registry summary' documents because they are produced by the registry itself rather than an independent party. The 2023 Verra rainforest controversy made it harder to rely solely on registry-issued evidence for forest carbon credits. Independent project scoring (such as those produced by ClimSen, Sylvera, BeZero, Calyx Global) is now expected for any material disclosure.

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After the 2023 Verra controversy, registry-issued documents alone don't meet the evidentiary bar most auditors now apply.

What ClimSen ships in every disclosure pack

When a transaction closes on the ClimSen marketplace and the credit is retired, the buyer automatically receives a CSRD-ready disclosure PDF containing all five required evidence elements plus the ClimSen Premium Score breakdown, satellite verification status (where applicable), and a sequential disclosure number for audit traceability.

1. 1

   Buyer purchases credit on the marketplace

   Project has already been scored 70+ on the seven-factor Premium Score. The score, methodology and registry record are public.

2. 2

   Quote → KYC → registry transfer coordination

   ClimSen handles seller communication, account setup and registry transfer milestones inside a tracked workflow.

3. 3

   Retirement serial is entered into the system

   The credit is retired on the registry. Serial number, retirement date and proof URL are recorded against the transaction.

4. 4

   Disclosure PDF is auto-generated and emailed

   Single-page, sequentially numbered (CSRD-YYYY-NNNN), with all five required evidence elements plus the Premium Score breakdown.

5. 5

   Buyer drops the PDF into their CSRD pack

   Standalone evidence document. The buyer's auditor can independently verify every claim against the public registry record cited.