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ARTICLE · 04 NOVEMBER 2026

Voluntary Nature And Carbon Markets: Key Risks And Practical Considerations For Organisations

Gowling WLG
Gowling WLG
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Gowling WLG

Gowling WLG

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As voluntary nature and carbon markets mature, businesses face mounting legal and reputational risks when purchasing environmental credits. This analysis examines the contractual mechanisms, regulatory frameworks, and governance structures that determine whether credit purchases strengthen or undermine corporate climate strategies, exploring how organisations can navigate evolving disclosure requirements, greenwashing allegations, and project delivery risks.

United KingdomEnvironment

Few large companies can meet their public climate commitments on emissions reductions alone.

With most emissions sitting in Scope 3, beyond a company's direct control, credits and increasingly removals have become a fixture of corporate climate strategy. Businesses are increasingly exploring nature-based credits as part of their sustainability strategies. But the legal environment around voluntary credits is likely to become more demanding: evolving disclosure frameworks, greenwashing risks, stakeholder expectations and performance concerns all point to an ever-greater focus on the quality of a credit portfolio.

For in-house legal teams, the question is no longer whether to buy credits, but how to buy them in a way that will survive scrutiny from a regulator, an auditor, a shareholder, a customer, or an employee five or ten years from now; long after the procurement team has moved on and the project has faced its first drought.

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