From the Environmental Markets Fairness Foundation (EMFF), we welcome the publication of the European Union’s document “Roadmap towards Nature Credits.” This roadmap marks a decisive moment in the development of a strategically designed, ecosystem-focused, and methodologically sound nature credit market.
The text rightly recognizes that nature is not merely a heritage to be preserved, but a vital infrastructure that sustains life and the economy. EMFF has clearly upheld this principle since its inception:
All human activity—productive, economic, social, and cultural—is directly or indirectly based on natural resources.
This is not just a fraction of GDP; it is the very fabric that supports any form of development.
Why is this document important?
The European Commission’s roadmap lays the groundwork for a nature credit market built upon four core pillars:
1. Multisectoral cooperation: bringing together public institutions, private actors, and civil society to align criteria and promote a shared vision.
2. High-integrity methodologies: simple, robust, adaptable frameworks with social and environmental safeguards.
3. Market development: encourage genuine supply and demand, with traceability and verifiable value.
4. Catalytic financing: reducing risks and unlocking private investment through initial public funding and blended finance mechanisms.
A key aspect of the European approach is its attention to scale. The proposed framework aims to fairly and effectively include those on the front lines of nature conservation—farmers, fishers, local communities, and ecosystem managers. Their role is strategic, and their recognition is essential.
A turning point in environmental markets
Since 2023, confidence in environmental markets has been under pressure. Investigative journalism revealed serious structural flaws in forest carbon credits issued by one of the world’s leading certifiers. This triggered a domino effect: investment retreat, growing scepticism, and concerns about greenwashing.
Although biodiversity credits are a distinct tool, they face similar challenges:
- Lack of comparable and standardized data
- Methodologies not easily adaptable to different ecosystems
- Difficulties in demonstrating additionality, permanence, and traceability
There is a risk of adopting standardized solutions that fail to reflect the true diversity of ecosystems.
Insights from Latin America
At EMFF, we have conducted in-depth analyses of biodiversity methodologies, focusing on concrete experiences in Latin America. This experience allows us to clearly identify the strengths and weaknesses that must be addressed to avoid design flaws and achieve real, lasting impact.
We know that many existing methodologies can serve as a starting point, but they often fall short in capturing the ecological, legal, and social complexity of each territory. Biodiversity does not accept one-size-fits-all solutions. We need rigorous, adaptive, and locally relevant approaches.
Building bridges for fair markets
Thanks to our track record in environmental markets and our broad network of technical, territorial, and financial actors, EMFF is well-positioned to understand the real needs of both ends of the market—supply and demand—and translate them into effective solutions together with methodology developers.
For environmental markets to fulfill their promise, we must build bridges—not barriers. The design must be collaborative, evidence-based, and action-oriented.
A new framework of trust
Global initiatives such as the ICVCM, TNFD, and SBTN are already establishing integrity standards—additionality, permanence, transparency, and safeguards—as fundamental criteria. The European roadmap aligns with this momentum, proposing a market architecture centred on trust.
At EMFF, we believe this is the right path.
The EU’s proposed roadmap is a clear signal that the future of environmental markets cannot rely on opacity or the easy promise of offsetting. Instead, it must be built on carefully designed instruments that generate trust, drive structural change, and respect the diversity of territories and the people who inhabit them.
We will continue contributing our experience to the development of environmental markets that are fair, transparent, and aligned with the challenge of regenerating our ecosystems—without losing sight of equity and integrity.
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