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New Zealand’s Ministry for the Environment has released updated Guidance for Voluntary Climate Change Mitigation, replacing the Interim Guidance published in 2022. The document provides a clearer and more comprehensive framework for organisations using carbon credits to support voluntary climate action.
The updated guidance arrives at a critical time for voluntary carbon markets, as governments, standard setters, and corporations continue to grapple with questions around credibility, double counting, and the role of carbon credits in net zero strategies.
For organisations operating in the New Zealand market, the guidance provides several important clarifications — particularly around corresponding adjustments, contribution claims, and the cancellation of New Zealand Units (NZUs).
A stronger emphasis on integrity
At the core of the guidance are six principles that carbon credits should meet when used for voluntary mitigation:
Additional.
Durable and permanent.
Real, measurable, verifiable outcomes and risk mitigation.
Transparent.
Respectful of rights.
Not double counted and supports accurate claims.
While many of these principles align with international best practice, the updated guidance introduces more detailed interpretation and practical expectations than the 2022 interim version.
Notably, the guidance strengthens expectations around transparency and claims-making, while reinforcing that voluntary mitigation should complement — not replace — direct emissions reductions.
Introducing a mitigation hierarchy
One of the most significant additions is the introduction of a mitigation hierarchy. The guidance makes clear that purchasing carbon credits should only occur for emissions that cannot yet be eliminated.
This includes situations where:
emissions reductions are still being implemented within the value chain,
decarbonisation technologies are not yet commercially available, or
emissions are currently impractical to eliminate.
This approach aligns New Zealand’s guidance more closely with evolving international expectations from initiatives such as the Science Based Targets initiative (SBTi) and the Integrity Council for the Voluntary Carbon Market (ICVCM).
A clear position on corresponding adjustments
Perhaps the most consequential aspect of the updated guidance is New Zealand’s explicit position on corresponding adjustments (CAs).
The Government states clearly that it will not issue corresponding adjustments for voluntary carbon market activity at this stage, although this position may change in the future.
As a result, organisations using credits that also contribute toward a host country’s Nationally Determined Contribution (NDC) must make transparent “contribution claims” rather than “exclusive use claims”.
The guidance distinguishes between:
Contribution claims — where credits contribute to a country’s NDC and support broader climate action.
Exclusive use claims — where emissions reductions are not counted toward another entity’s targets and may support claims such as “carbon neutral” or “net zero”.
This is a significant policy position because international guidance on organisational claims and NDC interactions remains unsettled. The ICVCM itself has acknowledged that debate is ongoing regarding whether corresponding adjustments should be required for voluntary corporate claims.
By taking a clear — and relatively conservative — stance, the New Zealand Government has prioritised market transparency and consumer confidence, even while international frameworks continue to evolve.
What does this mean for NZUs?
The updated guidance also addresses the controversial issue of cancelling NZUs for voluntary mitigation claims.
Importantly, the guidance states that:
surrendering NZUs for compliance obligations under the NZ ETS is not voluntary mitigation,
organisations should not make voluntary mitigation claims for compliance-related surrender activities, and
NZUs must be cancelled — not surrendered — before being used for voluntary claims.
However, the Government stops short of fully endorsing NZUs as a preferred voluntary mitigation instrument.
Instead, the guidance recommends that organisations participate in reputable voluntary carbon markets rather than rely on NZ ETS units; a position EAS has long communicated to our clients.
The rationale is that cancelling NZUs may not necessarily produce economy-wide additional climate benefits, because market settings could indirectly increase the future supply of NZUs available through auctions.
The guidance, therefore, recommends that only certain forestry-derived NZUs be considered appropriate for voluntary mitigation purposes:
Permanent Forest Sink Initiative units (NZU_PFSI), and
Permanent Post-1989 forestry units (NZU_PP89).
Standard post-1989 forestry NZUs (NZU_P89) are considered to require additional due diligence and safeguards.
Remaining uncertainties
While the updated guidance provides greater clarity in many areas, several practical questions remain unresolved.
One notable area of ambiguity relates to demonstrating that cancelled NZUs meet all six integrity principles of the ICVCM. The guidance suggests that organisations should demonstrate alignment with these principles, but does not clearly explain:
what evidence is required,
who is responsible for demonstrating compliance, or
whether participation in the NZ ETS itself is sufficient evidence of integrity.
Questions also remain around:
how “exclusive use” claims should interact with global corporate frameworks such as SBTi,
what level of public disclosure is required under the transparency principle, and
how organisations should assess and document safeguards and stakeholder rights.
These gaps are not unique to New Zealand. Many of the same issues remain unresolved internationally as policymakers and standard setters continue refining approaches to Article 6, double counting, and voluntary market integrity.
A signal of where the market is heading
Despite these uncertainties, the updated guidance sends a strong signal about the future direction of voluntary climate mitigation in New Zealand.
The emphasis is clearly shifting toward:
high-integrity credits,
transparent claims,
contribution-based climate action, and
alignment with broader decarbonisation pathways rather than offset-heavy approaches.
For organisations operating in carbon markets, the guidance reinforces the importance of:
robust due diligence,
credible project selection,
transparent communications, and
careful consideration of how climate claims are framed.
As international rules and expectations continue to evolve, New Zealand has positioned itself as an early mover in establishing a more conservative and integrity-focused approach to voluntary mitigation claims.
Cover photo by Long Ling on Unsplash