Beyond compliance: Is your market instrument ready?

From accounting to implementation 

One of the most important implications of Version 2.0 is a shift in focus. Historically, the debate was often about whether environmental attributes could be reflected in a company’s emissions inventory. The focus now moves towards implementation: whether an intervention helps decarbonise the relevant activity pool or sector, and whether that contribution can be evidenced in a credible way. 

For organisations using SAF certificates, renewable fuel certificates, book-and-claim programmes, and other market-based mechanisms, that changes the test. The issue is no longer only whether an environmental attribute exists, but whether the programme governing its creation, allocation, transfer, and use stands up to scrutiny. 

Integrity is what sets credible programmes apart 

In practice, this means governance becomes central. Companies should be asking whether their market instruments would hold up under scrutiny. 

Can the environmental attribute be followed from creation to retirement? Are allocation rules clear and applied consistently? Is the basis for the sustainability claim documented? Are activity and volume matching demonstrated? Are there controls to prevent double counting? 

These are becoming core questions for any organisation that wants to show that a market instrument supports a credible decarbonisation claim. 

None of this is being invented from scratch. The governance principles already exist — scattered across frameworks most companies have never had to read end to end: 

• ISO 14083 / GLEC Framework — consistent methodology for transport emissions accounting 
• ICAO / IMO guidance — the rules for using sustainable fuels in aviation and maritime 
• RED II/III — sustainability and lifecycle emissions requirements for renewable fuels 
• ISO 22095 — the international standard for chain-of-custody models, including book-and-claim 
• Smart Freight Centre MBM Framework — how freight carriers, shippers, and logistics providers allocate the benefits of low-emission freight through book-and-claim 

Together, they are the governance foundation credible market instruments are built on. Few companies are using all five correctly at once. 

Could you defend the claim? 

As market instruments become more common, companies need to look beyond whether a claim can be made and ask whether it can be defended. 

That requires more than sound emissions calculations. It requires a documented methodology, a clear chain-of-custody model, defined allocation rules, supporting evidence for the environmental claim, and controls to reduce the risk of double counting. Independent validation and verification can provide added confidence that these elements are in place and applied consistently under the relevant framework. 

The role of independent assurance 

As corporate target frameworks and sector-specific implementation frameworks move closer together, more attention is being placed on programme integrity. For companies, the question is whether the claim is supported by the methodology used, the allocation rules applied, and the evidence available. 

As a Smart Freight Centre recognised VVB, Normec Verifavia supports programme owners and participants by independently validating and verifying market instruments and associated claims against recognised sector-specific frameworks, including the Smart Freight Centre’s Market Based Measures (MBM) Framework, ISO 14083, and other relevant standards. Independent assurance may not be mandatory in every case, but it can provide confidence that programme governance, allocation methodology, environmental claims, and supporting evidence have been reviewed in a consistent and credible way.