Claim integrity gate
We will not confirm a claim. We will show you what published sources say should sit behind one, and which of those things you have told us you hold.
What this does
Carbon positive
- The term has no settled definition. Different organisations use it to mean different things, and the differences matter.
- One reading is that more carbon is removed from the atmosphere than the organisation emits, inside a stated boundary. That is a measurable claim, and it needs both figures published.
- A second reading is that the organisation has gone past a carbon-neutral position by buying additional units. That is a purchasing decision rather than an emissions outcome, and it should be described as one.
- A third reading is a general claim of net benefit with no quantity attached. That reading cannot be checked and is the one most likely to mislead.
- Removals are not the same as avoided emissions, and neither is the same as reducing what you emit in the first place. The order matters: avoid, reduce, substitute, then remove, and only then compensate for what is left.
Evidence these gates ask for
- Blocking
No documented inventory was named for the subject of the claim. Without one there is no quantity for the claim to be about.
Scopes 1, 2 and 3. Defines direct emissions, purchased energy emissions and other value chain emissions, and the operational boundary decisions that separate them.
Revised edition · Source last read 2026-09-11
VCMI Claims Code of PracticeVoluntaryFoundational criteria. Sets prerequisites before any carbon credit claim may be made, including public disclosure of an emissions inventory, a near-term science-aligned target, and demonstrated progress on the value chain.
Current published code · Source last read 2026-09-11
- Blocking
The boundary is not published alongside the claim. A qualification a reader has to go looking for is not a qualification.
Explain any conditions or qualifications. Important qualifications must be clear and prominent rather than buried, including the boundary a claim applies to.
Current published guidance · Source last read 2026-09-11
Carbon neutrality claim and disclosure. Sets what must be publicly available to support a carbon neutrality claim, including the subject boundary and the offsetting used.
2023 edition · Source last read 2026-09-11
- Blocking
Substantiation was not held at the time the claim was made. Reasonable grounds must exist when the representation is made, and a file built later does not cure that.
Have evidence to back up claims. Businesses should hold reasonable grounds and supporting evidence before making an environmental claim.
Current published guidance · Source last read 2026-09-11
Australian Consumer Law, section 18 — misleading or deceptive conductLegal obligation for some entitiesSection 4 — representations as to future matters. A representation about a future matter is taken to be misleading unless the maker had reasonable grounds for it, and the maker bears the evidential burden.
As amended, current compilation · Source last read 2026-09-11
- Blocking
Material scope 3 categories are outside the claim boundary. For a resources or fuels producer, downstream use is typically the largest part of the footprint, and a claim that excludes it without saying so invites a reader to assume otherwise.
Categories 10 and 11 — processing and use of sold products. Covers emissions from processing intermediate products and from the use of sold products, which for resources and fuels producers are typically the largest categories.
2011 edition · Source last read 2026-09-11
Explain any conditions or qualifications. Important qualifications must be clear and prominent rather than buried, including the boundary a claim applies to.
Current published guidance · Source last read 2026-09-11
- Material
The claim uses terms that are not defined where it appears. Broad environmental language is treated as a risk in itself, because a reader cannot tell what has been claimed.
Use clear and easy to understand language. Vague or undefined terms such as broad sustainability language risk misleading consumers unless explained.
Current published guidance · Source last read 2026-09-11
- Blocking
The mitigation hierarchy has not been demonstrated. Compensation addresses what is left after abatement. A claim resting on purchased units without demonstrated reduction is the specific pattern that ISO 14068-1, the VCMI Claims Code and the regulator's guidance all address.
Priority of reduction over offsetting. Requires that emissions reduction and removal within the subject take priority, with offsetting applied to residual emissions rather than in place of abatement.
2023 edition · Source last read 2026-09-11
VCMI Claims Code of PracticeVoluntaryCredits do not substitute for abatement. Carbon credit use is positioned as additional to, not in place of, an entity's own emissions reduction pathway.
Current published code · Source last read 2026-09-11
- Blocking
Abatement and credit use are not reported separately. A single net figure hides the question a reader most needs answered, which is how much of the position the organisation actually delivered.
AASB S2 Climate-related DisclosuresLegal obligation for some entitiesUse of carbon credits. Where carbon credits are relied on to meet a target, requires disclosure of the extent of reliance, the credit type and scheme, and whether removals or reductions are involved.
Issued 2024 · Source last read 2026-09-11
VCMI Claims Code of PracticeVoluntaryCredits do not substitute for abatement. Carbon credit use is positioned as additional to, not in place of, an entity's own emissions reduction pathway.
Current published code · Source last read 2026-09-11
- Material
Removals are not separated from avoidance credits. They are different things: a removal takes carbon out of the atmosphere, whilst an avoidance credit represents emissions that a project says did not occur.
AASB S2 Climate-related DisclosuresLegal obligation for some entitiesUse of carbon credits. Where carbon credits are relied on to meet a target, requires disclosure of the extent of reliance, the credit type and scheme, and whether removals or reductions are involved.
Issued 2024 · Source last read 2026-09-11
Carbon neutrality management plan. Requires a documented plan with a defined subject, quantified inventory, targets, timeline and the treatment of residual emissions.
2023 edition · Source last read 2026-09-11
- Blocking
No credit register was named. A reader cannot assess a claim that rests on units whose scheme, type, vintage and retirement status are not disclosed.
Additionality requirements. A project must satisfy the scheme's additionality tests before it can be credited, addressing whether the abatement would have occurred anyway.
As amended, current compilation · Source last read 2026-09-11
AASB S2 Climate-related DisclosuresLegal obligation for some entitiesUse of carbon credits. Where carbon credits are relied on to meet a target, requires disclosure of the extent of reliance, the credit type and scheme, and whether removals or reductions are involved.
Issued 2024 · Source last read 2026-09-11
- Material
Permanence arrangements are not stated. A removal that reverses has not offset anything, so the period and the reversal treatment are part of the claim.
Permanence obligations. Sequestration projects carry permanence periods and risk-of-reversal arrangements attached to the crediting.
As amended, current compilation · Source last read 2026-09-11
- Material
No interim targets were named. A distant end-state commitment with no near-term steps is difficult to describe as resting on reasonable grounds.
Be careful about future claims. Forward-looking environmental claims should rest on reasonable grounds, including a clear plan and interim steps.
Current published guidance · Source last read 2026-09-11
Australian Consumer Law, section 18 — misleading or deceptive conductLegal obligation for some entitiesSection 4 — representations as to future matters. A representation about a future matter is taken to be misleading unless the maker had reasonable grounds for it, and the maker bears the evidential burden.
As amended, current compilation · Source last read 2026-09-11
- Blocking
No funded plan was named. An intention without allocated capital is an aspiration, and describing it as a commitment is where forward-looking claims most often go wrong.
Be careful about future claims. Forward-looking environmental claims should rest on reasonable grounds, including a clear plan and interim steps.
Current published guidance · Source last read 2026-09-11
AASB S2 Climate-related DisclosuresLegal obligation for some entitiesStrategy. Requires disclosure of climate-related risks and opportunities, their effects on business model, strategy and financial position, and the entity's transition plan where one exists.
Issued 2024 · Source last read 2026-09-11
- Disclosure
Progress is not reported annually. A claim that is only ever restated, never measured, gives a reader no way to test it.
AASB S2 Climate-related DisclosuresLegal obligation for some entitiesMetrics and targets — targets. Requires disclosure of climate targets, how they were set and revised, whether third-party validation applies, and the role of carbon credits in meeting them.
Issued 2024 · Source last read 2026-09-11
- Blocking
The intended meaning is not published. The term is used to mean at least three different things, and a reader will supply the most favourable one unless you say which you mean.
Use clear and easy to understand language. Vague or undefined terms such as broad sustainability language risk misleading consumers unless explained.
Current published guidance · Source last read 2026-09-11
Australian Consumer Law, section 18 — misleading or deceptive conductLegal obligation for some entitiesSection 29 — false or misleading representations. Prohibits false or misleading representations about goods and services, including as to standard, quality, composition or approval.
As amended, current compilation · Source last read 2026-09-11
- Blocking
The two figures the claim compares are not both published. Without them the claim cannot be checked by anyone, including you.
Carbon neutrality management plan. Requires a documented plan with a defined subject, quantified inventory, targets, timeline and the treatment of residual emissions.
2023 edition · Source last read 2026-09-11
Make accurate and truthful claims. Claims must be accurate and capable of being substantiated when made.
Current published guidance · Source last read 2026-09-11
- Blocking
No evidence was named that the units are used once. A unit surrendered against a regulatory obligation has already done its work and cannot also support a voluntary claim.
Methods. Credits are issued only for abatement carried out under a determination made for that activity type, each with its own measurement and permanence rules.
As amended, current compilation · Source last read 2026-09-11
Safeguard MechanismLegal obligation for some entitiesSafeguard Mechanism Credits. A facility emitting below its baseline may be issued credits; a facility above its baseline must surrender credits or eligible units to manage the excess.
As reformed from 1 July 2023 · Source last read 2026-09-11
- Material
The scope and status of the referenced certification are not stated. A site-level certification described in company-level terms overstates what was assessed.
Australian Consumer Law, section 18 — misleading or deceptive conductLegal obligation for some entitiesSection 29 — false or misleading representations. Prohibits false or misleading representations about goods and services, including as to standard, quality, composition or approval.
As amended, current compilation · Source last read 2026-09-11
Validation and assurance. Members are expected to have performance against the expectations validated at asset level on a defined cycle.
Current published edition · Source last read 2026-09-11
Where this leaves you
11 pieces of evidence that this kind of claim rests on were not named
- State the boundary of the claim, including what it excludes, wherever the claim appears.
- State the period the claim covers and the date the underlying figures were prepared.
- Report your own abatement separately from your use of carbon credits, rather than as a single net figure.
- State the proportion of the position that rests on purchased units.
- Publish which meaning of the term you intend, and the two figures a reader would need to check it.
- Report removals separately from avoidance credits, and state permanence arrangements for sequestration units.
- Resolve the blocking evidence gaps below, or do not publish the claim in its current form, before seeking legal sign-off.
Claim wording review
Reads the wording you pasted and points at phrases a reader might take further than the evidence goes. It reviews your text rather than writing a claim, and it will not tell you whether anything is lawful.
Paste at least a sentence of your own wording above before running the review.