European Commission launches Roadmap towards Nature Credits

On 7 July 2025, the European Commission launched the Roadmap towards Nature Credits (the “Roadmap”) which sets out, at a high level, the Commission’s plans to establish a nature credit system to incentivise investment in Europe’s nature and biodiversity. 

It has also published Questions and Answers (“Q&As”) to accompany the Roadmap and has opened a call for feedback until 30 September 2025 to seek input on the plan. 

Background

At present, the EU’s nature restoration and protection projects mostly rely on public funding. According to the Commission, this funding is insufficient to meet its own commitments and Target 19 of the Global Biodiversity Framework (GBF), which seeks to increase financial resources available for nature actions to USD 200 billion per year by 2030 (for more information on GBF, see our previous blog post). 

Therefore, to meet its commitments, the Commission considers that it “must unlock private finance to complement public support” (see remarks by Commissioner Roswell). Nature credits are one tool to incentivise nature-related private investment. Other tools include green bonds and payments for ecosystem services. 

What is a nature credit?

According to the Roadmap, a “nature credit” is a unit that represents a nature-positive outcome, derived from a certified and independently verified action and quantified using a recognised biodiversity metric or indicator. These nature-positive outcomes can be valued and sold to investors. The actions supported by nature credits can take different forms. In the EU, examples include restoring wetlands or extending forest areas. 

The intention is that nature credits can generate additional income for farmers, foresters, fishers, landowners, and local communities while aiding ecosystem restoration. 

Potential buyers and investors include private companies, financial institutions, other investors, and public bodies seeking to benefit from or address nature-related risks and opportunities. 

Nature credits may also help Member States achieve EU Nature Restoration Regulation targets and support the Global Biodiversity Framework’s goals.

What is the Roadmap?

The Roadmap sets out the EU’s path to establishing the nature credit market, and in particular, the series of steps the Commission intends to take to help make nature credits effective and trustworthy.

It anticipates that the EU will establish a “two-step model” of certification followed by crediting, which incorporates strict criteria at both stages. Key to the plan is to set up an expert group to help design appropriate methodologies and governance frameworks for assessing projects and implementation methods. 

It is unclear at this stage whether Member States will develop their own nature market frameworks based on the EU’s roadmap, or whether it is expected that a single EU-wide or global nature credit market will be adopted. It is also unclear whether additional legislation will be needed in due course to help regulate the market.

The Roadmap has committed the Commission to timings for a number of key milestones. In particular: 

• 2025: The Commission will set up an expert group on nature credits to mobilise expertise, share best practices and provide inputs.
• 2025-2026: The Commission will engage in international fora and with international partners, including in preparation for the next Convention on Biological Diversity, COP 17.
• 2025-2026: The Commission will carry out an EU-wide evaluation of supply and demand for nature credits. Thereafter, on this basis, the Commission will invite the expert group to provide inputs on how to foster nature credit markets.
• 2025-2027: A pilot project on nature credits will be launched and supported by EU funds.
• 2026: The Commission will adopt the first carbon farming methodologies under the Carbon Removals and Carbon Farming Regulation, with mandatory co-benefits on biodiversity.
• Mid 2026: The Commission will invite the expert group to provide its expertise on criteria and methodologies for nature credit markets.
• 2027: The Commission will invite the expert group to provide its expertise on designing governance frameworks for nature credits, with particular considerations for smallholders and small and medium sized enterprises.
• 2027: The Commission will review progress made and consider next steps for the development and scaling up of nature credit markets.

How does this fit with national schemes?

The Roadmap acknowledges that several EU Member States and other countries are already piloting or using biodiversity finance models that blend public and private capital (e.g., the UK, France, Ireland and Finland) and in some countries, non-government bodies are similarly piloting such schemes (e.g., Belgium, Germany, Italy, the Netherlands, Portugal, Spain, Slovakia and Sweden). 

For example, the UK has implemented a biodiversity net gain scheme which requires in-scope developers to deliver at least 10% biodiversity net gain by creating biodiversity on-site, and if that is not possible, through a mixture of on-site and off-site measures or by purchasing statutory biodiversity credits from the government (for more information, see our previous blog post). 

The Commission's Q&As state that the EU’s nature credit market is intended to complement these existing regimes and to “raise investor interest and scale up nature credit markets”. 

Challenges

The Commission acknowledges that the carbon credit market has faced a number of significant challenges, such as greenwashing and concerns around the integrity of credits. Thus, in the Roadmap the Commission states that “strict criteria and principles need to be established to ensure transparency, avoid conflicts of interest and safeguard against greenwashing and double counting”. 

Further, given current lack of demand for nature credits and the lack of clear role for credits in emerging nature frameworks, it is unclear whether there will be sufficient business drivers to grow the market. 

However, a number of companies have made it clear that nature is material to their businesses, so a new, regulated, nature market could be a key tool for driving private finance into nature. 

The Roadmap and the Q&As state that the Commission plans to conduct a market potential assessment to better understand the realistic volumes and drivers in the EU context. 

Next steps

The Commission has launched a call for feedback which is open until 30 September 2025. 

Feedback received will be summarised by the Commission and presented to the European Parliament and Council with the aim of feeding into the legislative debate. 

For more information on Linklaters' nature and biodiversity materials, click here.