Is the CRCF Carbon Farming Delegated Act fit for purpose? Analysis of requirements and comparison with the PACM

In April 2026, the European Commission made available a revised draft delegated regulation and Annex setting out a certification methodology for carbon farming activities under the Carbon Removal and Carbon Farming Regulation (CRCF). The CRCF is meant to generate high-quality carbon removals and soil emission reductions in the EU. Whether it will be able to do so depends, to a large extent, on the quality of the methodologies that determine which activities are eligible, how mitigation outcomes are quantified, and how integrity risks such as non-additionality, leakage and reversals are addressed. In this study, we evaluate the robustness of the proposed rules. We examined whether the proposal adheres to key integrity principles in the voluntary carbon market and compared it to the overarching methodological standards of the PACM. Our assessment finds that the draft does not adhere to key integrity principles in the voluntary carbon market and sets a lower standard than the Article 6.4 Paris Agreement Crediting Mechanism (PACM). Unless it is significantly revised, many CRCF units from carbon farming are unlikely to be backed by actual emission reductions or removals. If such units were used for compliance with EU climate targets, the CRCF could pose significant risks, potentially undermining the ability of the EU to achieve these targets.