Verra, the registry behind the Verified Carbon Standard (VCS), recently conducted a public consultation on its Scope 3 Standard (S3S) Program. This program aims to enable companies to credibly account for and report Scope 3 greenhouse gas (GHG) reductions and removals resulting from intervention activities. The draft includes a set of documents comprising the standard, definitions, and integration guidance to support intervention owners in generating Scope 3 claims via Intervention Units while having the ability to change (with some safeguards and restrictions) to generate VCS credits out of the mitigation outcomes of their interventions.

As part of Value Change Initiative’s (VCI) ongoing engagement with standards developments, we submitted a detailed response to Verra’s open consultation, outlining our position on key concepts. Drawing on insights from our sector-specific working groups and cross-sector labs, our feedback reflects the practical challenges companies face with Scope 3 accounting and interventions. This blog summarizes key recommendations and technical perspectives we shared in response to Verra’s draft S3S Program.

Key recommendations to strengthen the S3S framework

VCI’s feedback was grounded in three high-level recommendations aimed at accelerating corporate action in the Scope 3 space:

– Enabling flexibility and inclusiveness to allow companies at various levels of maturity in their climate strategies to act.

– Incentivizing action and collaboration, allowing companies to make claims about emission reductions or removals based on their investments.

– Building on tested approaches. The VCI has developed and tested approaches to unitized impact, substitution, and other key concepts, which we recommend standard bodies refer to while developing their frameworks in the Scope 3 space.

Below we elaborate on our technical feedback across several key concepts in the S3S Program.

Permanence and durability

Permanence is one of the core principles of the S3S Program, requiring projects to demonstrate that the removed carbon stock is maintained, and report when that is not the case. VCI recognizes the importance of permanence for credible GHG reporting, particularly for removals, but encourages Verra to distinguish between the needs of Scope 3 inventory accounting which differ from carbon offsetting, where permanence is a strict requirement.

When considering the importance of credible and actionable mitigation linked to Scope 3, the VCI proposes incorporating concepts such as durability, as mentioned in the current draft of the Corporate Net Zero Standard 2.0 by the Science-Based Targets initiative (SBTi). The SBTi defines permanence and durability as the longevity of a carbon pool and the stability of its stocks, given the management and disturbance environment in which it occurs. The SBTi is currently assessing two approaches to durability: (1) “like for like”, based on the atmospheric lifetime of the GHG residual emissions addressed, and (2) a “gradual transition” approach, which increases the minimum durability threshold over time.

Functional equivalence

Functional equivalence is a foundational principle for the VCI. It refers to the requirement that the intervention product or outcome is sufficiently similar in function and purpose to the conventional product it replaces or modifies in GHG accounting. In simpler terms, if a default emission factor (EF) is being updated using the substitution method with a project-specific one, the product or process it represents must be essentially the same in function as the conventional one it’s replacing — along with other safeguards. You can learn more about our approach to substitution in our 2025 Food & Agriculture guidance.

Functional equivalence ensures that GHG outcomes from interventions can be meaningfully and credibly integrated into corporate Scope 3 inventories, especially when traceability is imperfect.

The Verra S3S Program leverages the UN Central Product Classification (CPC) system to establish consistency, traceability, and comparability when accounting for GHG outcomes across value chains. This could introduce an efficient and standardized approach to establish functional equivalence. The VCI looks forward to exploring the applications of this approach in co-product allocation in our upcoming workstreams.

Additionality

The Verra S3S Program treats additionality as a critical requirement for issuing Scope 3 Intervention Units (S3IUs)—GHG outcomes that companies can use to support credible Scope 3 reporting. This is a requirement in Verra’s approach because S3IUs should also be eligible to support VCS claims in the voluntary carbon market.

The VCI takes a pragmatic approach to additionality, particularly in the context of enabling credible Scope 3 emission reductions and removals from value chain interventions. Unlike carbon crediting frameworks that require strict additionality for offsetting, VCI focuses on accountability, transparency, and alignment with value chain realities, recognizing that additionality may not always be applicable to Scope 3 claims. Tests such as regulatory surplus — referring to the expectation that interventions required by law are excluded from participating in the S3S Program — might not always be applicable for Scope 3 interventions.

Allocation and attribution

In the S3S Program, attribution refers to the process of assigning a share of the mitigation outcome (e.g., a reduction or removal) from an intervention to a specific reporting company. This is based on a company’s role, sourcing relationship, or financial contribution. Verra proposes that mitigation outcomes be attributed as a whole to the intervention proponent.

The VCI proposes a harmonized way to use the terms allocation and attribution to enhance clarity across different frameworks. We propose that:

– Allocation be used to refer to the distribution of the mitigation outcomes across the impacted product (or co-products).

– Attribution be used to refer to the distribution of the mitigation outcome claims across companies in the value chain.

Additionally, VCI supports a flexible, context-specific approach to allocation that ensures transparency, environmental integrity, and traceability when assigning emissions reductions from interventions across value chains.

Unitized impact

Unitized impact refers to turning GHG outcomes (e.g., CO₂e reductions or removals) into discrete, tradable units — similar to carbon credits. VCI has developed the concept of Impact Units to enable these tradeable units. For more information, refer to VCI’s guidance on the role of Scope 3 systems in enabling collective action and co-investment.

Verra’s S3S Program uses Scope 3 Intervention Units (S3IUs) to represent verified GHG outcomes from specific interventions within defined boundaries. These units are designed to enable companies to integrate intervention-specific emissions data into their Scope 3 inventories and can only be leveraged within the Verra S3S Program. For VCI, having flexibility and interoperability, particularly with Scope 3 claims, is key to enabling a sustainable Scope 3 ecosystem for reporting companies and co-claimants.

Scope 3 claims and VCS claims

Under Verra’s S3S Program, Scope 3 claims allow companies to integrate verified GHG reductions into their inventories using Scope 3 Intervention Units (S3IUs). These claims support internal reporting and target-setting but are non-tradable and not used for offsetting. In contrast, VCS claims result in Verified Carbon Units (VCUs), which are tradable carbon credits used for external climate claims, including offsetting. The two systems are distinct but complementary, serving different purposes in climate action and corporate reporting. A company reporting under the S3S could leverage either S3IUs or VCUs across different reporting periods.

The VCI emphasizes the importance of maintaining clear boundaries between Scope 3 claims (used for internal GHG accounting and target-setting) and VCS claims (used for carbon crediting and offsetting). The VCI does not support automatic or interchangeable pivoting between these two claim types, as they serve distinct purposes and are governed by different integrity rules and safeguards.

However, the VCI acknowledges the potential to evolve claims over time—for example, shifting from a claim in the voluntary carbon market to a Scope 3 claim (or vice versa) — provided that there is no double claiming, and that the transition is transparently documented, clearly communicated, and based on credible data. The priority is to protect environmental integrity, ensure traceability, and maintain alignment with the GHG Protocol and SBTi guidance.

Integration into the Scope 3 inventory

Verra’s S3S Program enables companies to integrate verified emissions outcomes from value chain interventions directly into their Scope 3 inventories through S3IUs. This integration supports more accurate, intervention-specific reporting aligned with GHG accounting standards. It allows for flexible methods such as subtraction or substitution, depending on the company’s accounting framework. The approach enhances transparency and credibility in Scope 3 claims while ensuring no double counting.

The VCI supports integrating intervention outcomes into Scope 3 inventories using both inventory-based and project-based accounting approaches. Integration must be transparent, prevent double counting, and align with GHG Protocol principles. The VCI has explicitly explored these approaches in relation to compliance with current standards, as well as the implications beyond standards, in our 2025 Food & Agriculture guidance. The guidance also outlines the substitution approach in line with GHG Protocol requirements.

Conclusion

The VCI welcomes pragmatic approaches to incentivize Scope 3 action and enable claims, while ensuring environmental integrity and traceability. It is positive that companies are being offered options to choose the most appropriate approach to address their Scope 3 emissions. We expect that the next iteration (Version 2) of the S3S Program will incorporate increased flexibility and interoperability to help establish a resilient Scope 3 ecosystem. We are pleased that the draft S3S proposes approaches standardizing concepts such as functional equivalence and further considerations that support flexible and consistent Scope 3 accounting and reporting.

The S3S Program leverages the existing infrastructure of the voluntary carbon market and adapts it to the Scope 3 context. The VCI suggests that some of the concepts included may be less applicable to Scope 3 claims, and that alternatives should be explored. Furthermore, we maintain that due to the inherent differences in the purposes of VCS and Scope 3 claims, these should be kept separate — while acknowledging the potential for claims to evolve over time.

Finally, we encourage the continued harmonization of the Scope 3 landscape, ensuring that the final version of the S3S aligns with the concepts and requirements of other standards, such as the GHG Protocol and the SBTi.

Learn more about VCI’s Scope 3 guidance below.