Although blue carbon credits are not explicitly mentioned in the roadmap accompanying this public consultation, the text does explicitly reference the Ocean Pact released in June, which reflects the European Commissions intention to develop European blue carbon reserves and new business models for coastal communities.
EU consultation
Roadmap towards Nature Credits
198 submissions from 195 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 225 submissions on this file. Shown here: the 198 from organizations. Not shown: 22 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 5 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
Who showed up
91 submissions from industry — companies and their trade associations — against 74 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice. An identical text filed by several organizations counts once: 1 submission here repeats one text word for word and is folded into it.
What the room declares
- 100 of 195
- in the EU Register
- 664
- full-time lobbying staff
- €55.6M+
- declared costs a year
- 353
- EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 30 Sept 2025 — it ran from 7 Jul 2025.
- Policy area
- Sustainability (DG ENV)
- Where it stands
- Awaiting adoption
- Commission reference
- COM(2025)374
How it got here
- Communication30 Sept 2025
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 198 submissions.
In view of the plan presented by the Commission, the objectives of the Regulation, its importance as set out in the European Green Deal and the social impact that the implementation of the national nature restoration plans will have in each Member State, we note the following: Nature credits must not escape public funds at EU level for the implementation of Community environmental policy, including actions related…
Filed in Polish · English published by the European Commission
VÖWG - Verband der öffentlichen Wirtschaft und Gemeinwirtschaft
· · filed 30 Sept 2025 · source
Against this background, the VÖWG welcomes the initiative as it responds to one of the key challenges of environmental policy: the continued underfunding of nature conservation and ecosystem restoration. However, successful implementation requires a clear guarantee of long-term counter-financing, transparency of the interaction between public and private funds and concrete incentives for companies to purchase nature…
Filed in German · English published by the European Commission
Wiener Stadtwerke Feedback regarding the Roadmap towards Nature Credits 30 September 2025 The Wiener Stadtwerke Group expressly welcomes the European Commission's initiative to introduce nature credits. As the most important infrastructure service provider in the greater Vienna area, as Austria's largest regional energy supplier and as one of Austria‘s largest employers and investors, we bear responsibility for a…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Zero Waste Alliance Ireland (ZWAI) welcomes the European Commissions initiative to explore innovative finance mechanisms for biodiversity through the Roadmap towards Nature Credits. The ambition to mobilise private investment for nature restoration and conservation is timely, reflecting the urgent need to address biodiversity loss across the EU.
Copa and Cogeca acknowledge the European Commissions release of the Roadmap towards Nature Credits, which presents a potential framework for rewarding the environmental contributions of farmers, forest owners, and land managers through privately financed mechanisms. This proposal represents a pivotal opportunity to recognize and support biodiversity protection and ecological restoration within the European Union.
Brussels, the 30th of September 2025 IPIFF Position Paper Unlocking Nature-Positive Investment The Case for Including the Insect Sector in the EU Nature Credit Framework Submitted in response to: The European Commission's Feedback Consultation on the Roadmap on Nature Credits Submitted by: The International Platform of Insects for Food and Feed - IPIFF Date: 30/09/2025 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Environmental Policy Innovation Center, on behalf of the Nature Credit Working Group
· · filed 30 Sept 2025 · source
30 September, 2025 Joint commentary from the Nature Credit Working Group In response to the: COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Roadmap towards Nature Credits About the Nature Credit Working Group The organizations participating in this Working Group are committed to principles of additionality and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Cefic is supporting the European Commissions initiative for a roadmap towards voluntary nature credits and is willing to further exchange experiences and insights based on the sectors best practices. See a first set of elaborated recommendations in the attached paper.
Union of European Foresters European Forestry House Rue du Luxembourg 66b 1000 Brussels Belgium European Commission Brussels, 30th of September 2025 Object : UEF statement on the European Commission’s Communication: Roadmap Towards Nature Credits Dear Madam, Dear Sir, The Union of European Foresters (UEF) welcomes the EU Commission's initiative to promote ecological objectives in forests.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Conservation International welcomes the opportunity to contribute to the European Unions ongoing discussions on nature credits. We commend the European Commissions Roadmap towards Nature Credits and support its objective to establish high-integrity, transparent, and science-based instruments for quantifying biodiversity and ecosystem services.
The Forum on Forests and Climate Change values the European Commission’s initiative to establish a nature credit framework as a positive step to mobilise private investment in ecosystem restoration and conservation. We agree on the need to complement public funding with voluntary market-based instruments that bring transparency, trust and effectiveness.
Filed in Spanish · English published by the European Commission
The Chemical Industry Federation of Finland in general terms believes that it is good that integration of nature and biodiversity action into business is promoted. It is important that the objectives and the intended effect of the Nature Credits Roadmap are clearly outlined. Please find our full feedback in the attached document.
The European Biostimulants Industry Council (EBIC) welcomes the European Commissions Roadmap towards Nature Credits and submits this response to support the development of a high-integrity, outcome-based framework.
IFA welcomes the opportunity to input into the Roadmap to Nature Credits consultation to ensure that farmers perspectives inform the development of the market. The importance of the nature credit market to support nature restoration and climate resilience cannot be overemphasised.
The European Biostimulants Industry Council (EBIC) welcomes the European Commissions Roadmap towards Nature Credits and submits this response to support the development of a high-integrity, outcome-based framework.
Suomen yhteismetsät ry
· · filed 30 Sept 2025 · source
Opinion of the Finnish Common Forests Association thank you for the possibility of saying and representing the Finnish Co-forestry Group, which has around 800 thousand hectares of forest. Please note that the presentation has identified landowners as relevant for the implementation of nature credits.
Filed in Finnish · English published by the European Commission
PIC - Pravni center za varstvo človekovih pravic in okolja
· · filed 30 Sept 2025 · source
PIC is not inclined towards the financial valuation of nature and its services. Humans are part of nature, which cannot be fully quantified or comprehended. It is a condition of life and life itself. It is our common good, which we must take better care of (like stewardship) for the benefit of all, including future generations. As a common good, it cannot be subordinated to market mechanisms.
Swedish Forest Industries Federation
· · filed 30 Sept 2025 · source
Recommendations from Swedish Forest Industries: 1. Involvement of forest sector actors: The Commissions inclusion of stakeholders, e.g. through a dedicated expert group, is crucial for a scientifically sound and practically viable nature credit framework.
CLC welcomes the Commissions Roadmap as a step towards mobilising private finance for biodiversity. CLC remains fully committed to working with the Commission and other stakeholders to ensure that nature credit markets become a trusted and transformative tool in halting biodiversity lossstarting here in the Nordics.
Equinor’s feedback on a roadmap towards Nature Credits Equinor welcomes the European Commission’s initiative to develop a Roadmap towards Nature Credits, to create a high-integrity and transparent national and international market and to address the nature finance gap.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
American Forest Foundation
· · filed 30 Sept 2025 · source
The American Forest Foundation welcomes this opportunity from the European Commission (EC) to provide open feedback on its Roadmap Towards Nature Credits initiative. As an eighty-five-year-old conservation non-profit with a history of working with small holders of family-owned forests across the United States, we have understood first-hand how a nature-positive strategy for forests returns a multiplicity of values…
Preferred by Nature
· · filed 30 Sept 2025 · source
Preferred by Nature feedback to the Roadmap towards Nature Credits 30th Sept 2025 Preferred by Nature would like to thank the European Commission for the opportunity to provide feedback to the Communication from the Commission to the European Parliament, Council, The European Economic And Social Committee and the Committee Of The Regions Roadmap towards Nature Credits.
ICLEI Europe welcomes the European Commissions initiative to develop a Roadmap towards Nature Credits and to strengthen the governance of emerging nature markets. As the largest global network of local and regional governments committed to sustainable development, ICLEI Europe represents the interests of cities and regions across the continent, and we see a strong and proactive EU role as critical for ensuring that…
AFEP welcomes the Commission's initiative to present such a roadmap and to launch this consultation. The association supports the Commission's assertion that nature credits can be a key tool to reward nature-positive action through private investment to the benefit of nature and businesses by highlighting them, and is convinced that the European Union can play a catalytic role in the development of this form of…
Greenish, the national federation representing horticultural and nursery growers in France, wishes to contribute to the consultation on the introduction of natural credits. As a first step, we would like to welcome the Commission’s initiative to encourage financial instruments that support biodiversity and the development of ecosystem services.
Filed in French · English published by the European Commission
Please find attached Veolia's contribution to the European Commission's consultation on the Roadmap towards Nature Credits. Our key recommendations are: 1° Establish a high-integrity, science-based EU system compatible with existing legislation, with clear eligibility criteria, ecosystem-specific methodologies, and safeguards against reversals and double counting.
Umanotera, Slovenska fundacija za trajnostni razvoj
· · filed 30 Sept 2025 · source
In the Network of NGOs on Sustainable Development Plan B for Slovenia, coordinated by Umanotera, the Slovenian Foundation for Sustainable Development supports efforts to seek funding opportunities for nature restoration at EU level, as this represents a major obstacle to the effective implementation of Regulation (EU) 2024/1991 on nature restoration.
Filed in Slovenian · English published by the European Commission
We positively welcome the European Commissions decision to address nature credits and to draft this roadmap. By providing a clear and harmonized framework at the EU level, this initiative could bring confidence to this emerging market, reassure buyers and support local communities, while driving meaningful nature restoration across the EU. That said, several aspects of the framework could be improved or clarified.
The path outlined in the roadmap to Nature Credits recognizes the central role of nature for economic and environmental resilience, with a focus on water ecosystems. Addressing the challenges that the protection of biodiversity and natural ecosystems pose today requires a collective effort and an ambitious roadmap.
The Caisse des Dépôts Group, dedicated to the public interest for over two centuries, has embedded in its core mission the acceleration of ecological transformation and the pursuit of a better life for all. In line with this commitment and building upon the Group's biodiversity policy, we are determined to place biodiversity at the heart of our ecological transformation strategy.
BCA Feedback on the European Commission’s Roadmap towards Nature Credits 1. Introduction The Biodiversity Credit Alliance (BCA) welcomes the European Commission’s Roadmap towards Nature Credits (July 2025) as a timely and ambitious step toward addressing the biodiversity finance gap.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
This response is submitted by WCS EU, a Belgian NGO. Our response is also submitted on behalf of the Wildlife Conservation Society (WCS), the worlds largest field-based conservation organization, with which we are affiliated.
French Banking Federation
· · filed 30 Sept 2025 · source
The French Banking Federation (FBF) is the professional organization representing all banks operating in France, comprising 320 member banking institutions, including 115 foreign banks. The FBF welcomes the European Commissions ambition to structure a nature credit market, complementary to carbon credits, to accelerate the mobilization of private capital for biodiversity.
Meo Carbon Solutions GmbH as representative partner of EU LIFE co-founded project consortium
· · filed 30 Sept 2025 · source
Feedback on the European Commission’s Roadmap for Nature Credits Submitted in the framework of the EU LIFE co-funded project “Biodiversity Governance and Performance in the Food Sector” The European Commission’s initiative to develop a framework for nature credits is welcomed as a step towards mobilising private sector engagement in biodiversity restoration.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ECOS recommendations on the European Commission's Roadmap towards Nature Credits: Ensuring a system that disincentivises nature destruction Europe is facing a biodiversity emergency: over 80% of habitats are in poor condition, while billions in harmful subsidies continue to cause their decline. Regulating and divesting from economic activities which harm nature must be the EUs first strategy.
Born Free welcomes the opportunity to provide input to the EU Roadmap towards Nature Credits. We cautiously welcome this initiative, which seeks to create an innovative tool to help bridge the funding gap for nature conservation in Europe, but raises several questions and concerns. Please find our detailed feedback in the document attached.
Rewilding Europe
· · filed 30 Sept 2025 · source
We welcome the initiative of the European Commission to create a Roadmap towards Nature Credits to scale-up financing in support to EU conservation and restoration goals. There is no easy or quick solution to conservation or restoration challenges, which typically require sustained public support, multi-stakeholder engagement, and enabling policy environment.
"Aggregates Europe represents the largest non-energy extractive industry with a production of 3 billion tonnes of sand, gravel, crushed rock, marine, recycled and manufactured aggregates, produced by 15,000 companies, operating 26,000 sites exclusively in Europe. We are essential to Europes economy and are the backbone of the construction industry.
The Irish Creamery Milk Suppliers Association (ICMSA) represents all Irish farmersparticularly dairy and livestock farmers and we place a special emphasis on preserving the family farm structure and defending the rights and incomes of farm families. We were formed in 195) and have spent the last 75 years defending and advocating on behalf of Irish farmers at Irish and European level.
Biodiversity in Good Company e.V.
· · filed 30 Sept 2025 · source
The German National Business and Biodiversity Initiative Biodiversity in Good Company appreciates the opportunity to comment. 1) Nature credits are essential for integrating biodiversity into economic systems as a prerequisite for effective biodiversity protection and regeneration.
Institute of Agricultural Resources and Economics
· · filed 30 Sept 2025 · source
The Institute of Agricultural Resources and Economics (AREI), Latvia, welcomes the European Commissions initiative to develop a roadmap for the introduction of nature credits as a market-based instrument to support biodiversity conservation and ecosystem restoration.
Association BIOM
· · filed 30 Sept 2025 · source
The Association Biom BirdLife Croatia welcomes the opportunity to provide comments on the European Roadmap towards Nature Credits. The latest report by the European Environment Agency on the state of Europes environment presents alarming findings, showing that many ecosystems and species are at risk of irreversible damage or extinction.
We welcome the implementation of Nature Credits aimed at giving value to those activities that provide meaningful advantages to the ecosystems. As reported in the Roadmap Towards Nature Credits (COM(2025) 374 final), with a view to strengthening the bioeconomy, these tools can also provide an opportunity to generate income to the people involved in the protection, restoration, and sustainable management of…
The ARTEMIS Interreg Euro-MED project (https://artemis.interreg-euro-med.eu/) - developing Payment for Ecosystem Services (PES) schemes based on seagrass biodiversity and blue carbon - partnership welcomes the initiative. We recognize its timeliness and potential to mobilize private investment to fill the current nature financing gap, provided it builds on integrity, scientific credibility, and sound governance.
Coldiretti
· · filed 30 Sept 2025 · same text as 1 other organization · source
With regard to the Nature Credits Roadmap to reward nature-positive action and boost private finance, we believe that the development of nature credits, within the wider landscape that is emerging through the construction of a European bioeconomy, should be seen as an opportunity for the agricultural and forestry sector, giving operators in the sector the opportunity to make greater use of their vital contribution…
Filed in Italian · English published by the European Commission
Filiera Italia
· · filed 30 Sept 2025 · same text as 1 other organization · source
With regard to the Nature Credits Roadmap to reward nature-positive action and boost private finance, we believe that the development of nature credits, within the wider landscape that is emerging through the construction of a European bioeconomy, should be seen as an opportunity for the agricultural and forestry sector, giving operators in the sector the opportunity to make greater use of their vital contribution…
Filed in Italian · English published by the European Commission
Friends of the Earth Europe sees the European Commissions plan for nature credits as a dangerous distraction from the urgent tasks of phasing out harmful subsidies and establishing strong regulation. Instead of addressing the root causes of biodiversity loss, this proposal risks prioritising private profit over the public interest and deepening ecological and social injustices.
Bellona cautiously welcomes the Commissions initiative on nature credits as an important opportunity to mobilise private finance for biodiversity restoration. However, we stress that nature credits must never be used as a substitute for real nature restoration.
Copenhagen, September 2025 DI Consultation Response: Nature Credits Roadmap to reward nature-positive action and boost private finance Introduction: Danish Industry (DI) welcomes the opportunity to provide feedback on the European Commission's Roadmap towards Nature Credits. DI represents more than 20.000 Danish companies across industries with high ambitions to achieve a green transition.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
IFOAM Organics Europe welcomes the opportunity to provide feedback on the Roadmap towards Nature Credits. Nature with intact ecosystem functions and a thriving biodiversity are a pre-requisite of healthy agricultural systems and long-term food production. Farmers who are actively contributing to biodiversity protection and nature restoration should be appropriately rewarded for the benefits they are providing.
Finance Denmark
· · filed 30 Sept 2025 · source
We support the EU Commissions work on establishing a road map towards nature credits. Nature credits have the possibility of having a significant impact on financing and investments in nature conservation and restoration projects.
Carbon Market Watch
· · filed 30 Sept 2025 · source
Carbon Market Watch welcomes the opportunity to provide input on the draft certification methodologies. Unfortunately, schemes as these carry many issues: They fail to address the root cause of nature destruction. The EU should first ensure that existing public funding schemes and policies actually guarantee nature-positive action.
Etangs de France
· · filed 30 Sept 2025 · source
Dear All, Etangs de France welcomes the European Commissions initiative to develop a framework for nature credits. We fully support the ambition to reward landowners, managers, and communities that safeguard biodiversity and ecosystem services. However, we note with concern that inland ponds (étangs) are not explicitly recognised in the roadmap, despite their exceptional ecological and socio-economic contributions.
The German association DIE PAPIERINDUSTRIE e. V. represents the interests of the German pulp and paper industry. In terms of turnover, it covers more than 94% of the sector, speaking on behalf of the largest national pulp and paper industry in Europe and the fifth largest worldwide.
CEMBUREAU welcomes the possibility to give feedback on the ideas for the roadmap towards nature credits. Our main points are: 1. Strong ambition is conveyed in the tools presented in the note, but few guarantees or encouraging studies on the actual market potential are provided. 2. The ambition is described in vague terms, with little reassurance offered to issuers, buyers, or certifiers.
Maanomistajainliitto/Finnish landowners`association
· · filed 30 Sept 2025 · source
Statement by the Finnish Landowners’ Association thank you for the possibility of saying and representing landowners who are underneath around 1.6 million hectares of forest. Please note that the presentation has identified landowners as relevant for the implementation of nature credits. The natural value market opens up conservation and restoration efforts, as well as increasing natural capital for private actors.
Filed in Finnish · English published by the European Commission
Nature credits are emerging as a new voluntary market-based instrument to incentivize and reward nature-positive actions. At the heart of these credits lies the land, which supports essential ecosystem servicessuch as biodiversity, water retention, and carbon sequestrationthat must be preserved for nature credits to hold real value.
Buglife- The Invertebrate Conservation Trust
· · filed 30 Sept 2025 · source
Buglife- The Invertebrate Conservation Trust welcomes the chance to submit a response to the call for feedback on the "Roadmap towards Nature Credits. While there is clearly a need for higher and sustained levels of funding to meet nature restoration ambitions across Europe, Nature Credits are not the route to achieving the necessary levels of investment.
Södra appreciates the opportunity to comment on the European Commissions Roadmap towards Nature Credits. As a member owned forest owners cooperative with over 50,000 members and a long tradition of sustainable forestry, we welcome the ambition to develop a voluntary, transparent and science based framework that promotes biodiversity and strengthens natures role in the European economy.
As the leading representative organisation of French businesses, the Mouvement des Entreprises de France (MEDEF) brings together, with its members - 101 professional federations and 119 territorial organisations - more than 200 000 companies of all sizes, from small and medium-sized enterprises to large corporations, covering all sectors of the French economy.
Climate Action Network Europe
· · filed 30 Sept 2025 · source
The EC's roadmap, while correctly identifying the massive biodiversity financing gap, does not underline the continuous need for public financing, which can be increased by reforming existing public funding mechanisms.
International Advisory Panel on Biodiversity Credits
· · filed 30 Sept 2025 · source
The International Advisory Panel on Biodiversity Credits (IAPB) warmly welcomes the publication of the Roadmap towards Nature Credits. This is a timely and important step, and IAPB strongly supports the creation of a European market for nature credits. The environmental urgency requires moving forward without delay.
FNSEA is fully in line with the visibility that the European Commission wishes to give to agricultural practices conducive to biodiversity through the use of natural credits. These credits, in addition to giving pride to the farming profession, constitute income supplements that will be welcomed on many farms.
Filed in French · English published by the European Commission
NOAH Friens of the Earth Denmark
· · filed 30 Sept 2025 · source
- EU Member States allocate billions to burning primary woody biomass for renewable energy. Those billions should be redirected toward activities that restore and protect ecosystems. - Nature credits should not be an excuse to reduce public funding for nature restoration or protection. Nature credits should only be used as a way to generate new money for nature beyond the available public funding.
Forestry Europe
· · filed 30 Sept 2025 · source
We welcome the publication of the Roadmap for Nature Credits and wish to give our feedback based on our experience as practitioners working with forest. Our contribution is therefore rooted primarily in forest ecosystems. Forests are at the intersection of biodiversity protection, carbon dynamics, water regulation, and social value.
Beitrag des Verbands der Automobilindustrie zum von der EUKommission vorgeschlagenen „Fahrplan für Naturgutschriften“ Datum 30.09.2025 Die Europäische Kommission hat am 7. Juli 2025 eine Roadmap zum Thema Naturgutschriften veröffentlicht, um Anreize für private Investitionen in den Schutz und die Erhaltung der Natur zu schaffen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BDI Federation of German Industries
· · filed 30 Sept 2025 · source
This statement represents more than 100,000 companies and 8 million employees. The German economy like the European economy is under considerable pressure. Bureaucratic hurdles, rising energy costs, stringent environmental regulations, and international trade conflicts are undermining competitiveness and hindering investments that are urgently needed for biodiversity, climate protection, and the necessary…
The Finnish Association for Nature Conservation
· · filed 30 Sept 2025 · source
The Finnish Association for Nature Conservation thanks for the opportunity to give feedback on the European Commission's Roadmap Towards Nature Credits. We would like to point out the concerns and problems related to nature credits. It is crucial to make sure that the introduction of these credits does not hinder or slow down the work done in halting the biodiversity loss locally or globally.
Roadmap to Nature Credits (EU): Comments and recommendations 1. Who we are: The DGNB is an independent non-profit association that was founded in 2007 and has developed into Europe's largest network for sustainable building. As a content-driven solution provider, we support all those who have understood that "business as usual" has no future.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Nature is a common public good at the basis of social and economic well-being but also has a right to exist in itself and for itself. Nature credits carry significant risks of commodification, privatization, and financialisation of ecosystems and natural elements such as water or land. Biodiversity is complex, long-term, and site-specific, making it inherently unsuitable for fungible credit schemes.
BirdLife Sverige
· · filed 30 Sept 2025 · source
Our society’s economy and survival are both dependent on ecosystem services, which are becoming more threatened every day. The EU natural credit roadmap shows a large funding gap for biodiversity. At the same time, harmful subsidies for bioenergy from high nature value forests contribute to forest degradation and loss of soil carbon sinks.
Filed in Swedish · English published by the European Commission
PEFC, the Programme for the Endorsement of Forest Certification, follows the developments by the European Commissions on Nature Credits, and the roadmap in particular, with interest. PEFC is a leading global alliance of national forest certification systems.
Attorney at Law
· · filed 30 Sept 2025 · source
We have two concrete suggestions for the following planned measure: The Commission will carry out an EU-wide assessment of the supply and demand for nature credits. Subsequently, the Commission will invite the expert group, on this basis, to provide contributions to foster markets for nature credits. 1.
Nattergal welcomes the opportunity to provide feedback on the Roadmap towards Nature Credits. We are a UK-based nature restoration company working to demonstrate that nature is an investable asset class capable of generating sustainable financial returns alongside biodiversity and social benefits.
Public consultation – Roadmap towards Nature Credits ( COM(2025) 374) Czechia welcomes the initiation of a structured and representative dialogue on the development of a nature credit framework. It acknowledges the European Commission’s efforts in advancing international and EU biodiversity targets, as set out in the Kunming-Montreal Global Biodiversity Framework and the EU Biodiversity Strategy for 2030, as well as…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
NatureMetrics
· · filed 30 Sept 2025 · source
NatureMetrics welcomes the opportunity to feedback on the EUs Nature Credits Roadmap. We are a nature intelligence company on a mission to make biodiversity measurable at scale to accelerate finance into nature restoration and conservation.
Deutscher Forstwirtschaftsrat e. V.
· · filed 30 Sept 2025 · source
We welcome the idea of making nature-positive measures visible and mobilising additional private investment for biodiversity and climate action. For a successful implementation from a forestry perspective, the following points are crucial: Clear, science-based standards for certification, monitoring and reporting, including to prevent greenwashing.
Filed in German · English published by the European Commission
Maa- ja metsätaloustuottajain Keskusliitto MTK – Central Union of Agricultural Producers and Forest Owners MTK
· · filed 30 Sept 2025 · source
MTK welcomes the European Commissions roadmap regarding the development of nature credits. Nationally and internationally, there is an urgent need to find innovative and widely acceptable solutions to better protect biodiversity and to arrange adequate funding for action. According to MTK, voluntary nature value market is a central part of reaching success.
BirdLife Europe and Central Asia | EU Consultation Response | 09/2025 Ref. Ares(2025)8233627 - 30/09/2025 BirdLife consultation response: Nature Credits Roadmap Setting the Scene – What role can Nature Credits play? The nature crisis is accelerating, and attention increasingly turning away from it – with dramatic costs.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Organic Certifiers Council EOCC
· · filed 30 Sept 2025 · source
The European Organic Certifiers Council gathers 74 Control Bodies and Control Authorities active in 165 countries worldwide. EOCC members control and certify according to EU organic standards: - In European Union: at least 180 000 operators and 6 million hectares; - In Third countries: at least 180 000 operators and 20 million hectares.
Technical Frameworks The restoration of rich ecosystems presents a high degree of complexity. Priority must be given to the restoration of primary ecosystems. Many professionals in the field, primarily accustomed to designing standardised, artificial landscapes, must be sensitised to the specific techniques of restoring natural ecosystems.
Nature is a common public good at the basis of social and economic well-being but also has a right to exist in itself and for itself. While the EU explores the development of nature credits, these mechanisms carry significant risks of commodification, privatization, and financialisation of ecosystems and natural elements such as water or land.
The European sawmill industries are concerned about the absence of a clear framework on how nature credits will be developed in practice. Without proper safeguards, such schemes risk undermining the availability of raw materials for the wood-processing industries, which are the backbone of Europes bioeconomy.
The Forest Stewardship Council (FSC) welcomes the publication of the new Roadmap towards Nature Credits by the European Commission and supports the ambition to mobilise private investment in nature-positive action. To ensure this initiative delivers genuine, lasting and scalable benefits, both environmental integrity, economic and social value must be secured.
The European Confederation of Woodworking Industries (CEI-Bois)
· · filed 30 Sept 2025 · source
The European Confederation of Woodworking Industries (CEI-Bois) welcomes the opportunity to provide feedback on the European Commission's Roadmap towards Nature Credits. At the same time, our sector shares concerns about the lack of clarity on how nature credits will be developed and integrated into existing policy frameworks.
Finance for Biodiversity Foundation
· · filed 30 Sept 2025 · source
The Finance for Biodiversity Foundation (FfB) Secretariat welcomes the European Commissions (EU) Roadmap on Nature markets, as well as the establishment of an Expert Group. It recognises efforts to mobilise additional resources for biodiversity, a key objective of the Global Biodiversity Framework (Target 19). There are several concerns that the Commission should consider when developing the nature credits market.
Stellungnahme der Landwirtschaftskammer Österreich Roadmap to Nature Credits Wien, 30. September 2025 Wird ein System zur Vergabe von Nature Credits eingeführt, muss dieses einen echten Beitrag zur Förderung der Biodiversität und zum Schutz natürlicher Ressourcen leisten und die entsprechenden Leistung der Land- und Forstwirt:innen honorieren.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The TÜV Association welcomes the European Commissions Roadmap towards Nature Credits and supports its objective to establish high-integrity, transparent, and science-based instruments for financing biodiversity and ecosystem services.
A roadmap towards nature credits provides a useful basis to assess their credibility, scientific rigour, and potential contribution to nature restoration. However, nature credits are only one of several tools available to mobilise finance for nature protection and restoration.
The Union of Unions welcomes the European Commission’s initiative to launch a participatory process to design a European credit system of nature that recognises and remunerates the environmental benefits derived from sustainable practices.
Filed in Spanish · English published by the European Commission
Response from the Institute of Sustainable Finance to the European Commission's consultation on nature credits Created in October 2022, the Institute of Sustainable Finance, a branch of Paris EUROPLACE, aims to coordinate, unite, and accelerate the Paris financial center's efforts to achieve ecological transition and transform the economy towards a low-carbon and inclusive model, in line with the objectives of the…
EuroNatur welcomes the European Commissions consultation on the recently published Roadmap for Nature Credits. Facing natures rapid decline, it is of utmost importance that the EU fulfills its environmental obligations under the EU Biodiversity Strategy, particularly through the implementation of the Nature Restoration Regulation.
Austropapier position on nature credits Nature credits are relatively new market-based instruments designed to assign measurable value to the protection, restoration, or sustainable management of natural ecosystems. Nature credits are measured and tradeable units of nature-positive outcome linked to a project. Schemes for nature credits already exist and can be of different types.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We recognise the need to mobilise funding to protect and restore biodiversity. The chemical, pharmaceutical and biotech industries have the greatest interest in having an intact nature as a basis for many economic activities and innovations. This is why we are committed to the protection of biodiversity and the sustainable use of nature.
Filed in German · English published by the European Commission
Union of European Foresters European Forestry House Rue du Luxembourg 66b 1000 Brussels Belgium European Commission Brussels, 30th of September 2025 Object : UEF statement on the European Commission’s Communication: Roadmap Towards Nature Credits Dear Madam, Dear Sir, The Union of European Foresters (UEF) welcomes the EU Commission's initiative to promote ecological objectives in forests.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Manulife Investment Management
· · filed 29 Sept 2025 · source
Dear Sir/Madam We welcome the European Commissions initiative to develop a framework for nature credits and appreciate the opportunity to contribute to the consultation. Manulife Investment Management is a global wealth and asset management business with over 440 billion in assets under management and administration globally, including a substantial institutional investor base in the EU.
This collaborative effort behind the Nature Credit Roadmap is highly valued and we see it as a potential global cornerstone for supporting nature conservation and ecosystem restoration. By combining diverse expertise, reliable data, and innovative finance, it offers a scalable system that benefits ecosystems, farmers, investors, and communities while bridging environmental goals with real financial action.
IMA-Europe Position Nature Credits Communication – Open public consultation FINAL (29.09.2025) Industrial Minerals Association Europe (IMA-Europe), representing the interest of industrial minerals producers in Europe, welcomes the opportunity to provide input on the drawing up the criteria to define nature credits and recognise the role of the directly and indirectly involved stakeholders along the value chain…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Finnish Forest Industries Federation
· · filed 29 Sept 2025 · source
Through interaction with people ecosystem services become commodities and benefits that promote human well-being. Forests produce many different ecosystem services. Biodiversity maintenance, wood and wood fibres are important provisioning services. Other key ecosystem services the forest produces include eg. carbon sequestration, regulation of water quality and cycles, food production, and recreational use.
IEG Members Voices on Nature Credits The voices of IEG members from different regions strongly support the development of an EU Roadmap on Nature Credits as an essential step toward valuing and restoring ecosystems. Members emphasized that Nature Credits should: Ensure inclusivity and equity, recognizing the rights of local communities and Indigenous Peoples.
There are five key principles which should be adhered to, to ensure nature credits schemes contribute to sustainable, resilient economies in harmony with nature and people: please see the attached paper for these principles, reflective of the roadmap (e.g complementarity, non-offsets, compliance, EU-wide framework). The EU faces a significant biodiversity funding gap, where nature credits can play a role.
The Nature+ Coalition brings together EU-based companies and project developers dedicated to promoting forest conservation and restoration around the world. We welcome the first communication from EU institutions on their roadmap to develop nature credits, and thank the Commission for establishing the related public engagement initiatives (public consultation, expert group). Our detailed feedback is in attachment.
Together, we welcome the initiative of the European Commission. Read can play a key role in developing credible and effective biodiversity credit mechanisms. Four levers appear essential: Clarify: the term ‘nature credit’ covers very different realities, creating confusion and heterogeneity of integrity. Read could clarify definitions and perimeters to create shared vocabulary.
Filed in French · English published by the European Commission
In principle, the German Farmers’ Association (DBV) considers it necessary to develop new financing pathways for the promotion of biodiversity and the conservation of ecosystems and ultimately private capital for nature conservation. The German Farmers’ Association is committed to ensuring that biodiversity-enhancing measures can become a source of income for agricultural holdings or a branch of the farm.
Filed in German · English published by the European Commission
The Association of Austrian Land and Forest Owners welcomes the initiative of a nature credits system that should offer an opportunity for land managers to generate additional income. Ecosystem services previously without market value could be thus rewarded in the future. The applicability of existing laws such as the NRL or the Taxonomy Regulation is a prerequisite for a practicable system.
National Council of Land, Agricultural and Forestry Expertise (CNEFAF)
· · filed 29 Sept 2025 · source
The National Council of Land, Agricultural and Forestry Expertise (CNEFAF) a French organization representing Land and Agricultural Experts and Forestry Experts welcomes the European Commissions initiative to develop a roadmap for nature credits.
EY welcomes the opportunity to respond to the European Commissions (The Commission) Roadmap towards Nature Credits and commend the Commissions commitment to fostering nature-positive actions and exploring innovative financial solutions.
Athena Blue
· · filed 29 Sept 2025 · source
Athena Blue welcomes the European Commissions Roadmap to Nature Credits. We are on a mission to unlock finance for the ocean: we build the pipeline of high-impact blue carbon and ocean projects powered by AI, grounded in science, and designed for impact. Our work sits at the ocean-nature nexus, where restoring marine and coastal ecosystems delivers climate resilience, biodiversity protection and social co-benefits.
Irish Co-operative Organisation Society (ICOS)
· · filed 29 Sept 2025 · source
ICOS warmly welcomes the opportunity to provide feedback through this Commission forum on Natural Capital Accounting proposals, we recognize that early and continual stakeholder engagement is essential. Whilst nature and biodiversity has an economic, social and of course immeasurable environmental value, these three core pillars are often somewhat disconnected.
The Directorate-General for Environmental Policy and Natural Heritage of the Government of Catalonia welcomes the Commissions Roadmap and its emphasis on integrity, subsidiarity and usability. We support the two-step model of certification and crediting, the think small first principle, and the intention to pilot, seed-finance and co-design the system with land managers and SMEs, as these features are essential to…
ClientEarth welcomes the opportunity to provide feedback in the present Commission Call on its proposed "Roadmap towards Nature Credits". To that end, ClientEarth has prepared a submission (cf below, attachment). Generally, while there is a need for a significant quantitative increase and qualitative improvement in biodiversity finance, the concepts formulated in the present Roadmap bring little added value.
Great Lakes and Wetlands Association
· · filed 29 Sept 2025 · source
The Communication from the Commission about the Roadmap towards Nature Credit rightly points out that "nature is our strongest ally to support our livelihoods, health and prosperity because it provides essential ecosystem services. There is a loud narrative to argue that private funding must be mobilised for nature conservation in order to close the existing biodiversity financing gap.
Please find attached the submission of Eurogroup for Animals. Recalling that nature, biodiversity and wild animals are extremely fragile and have an intrinsic value that cannot be monetarily quantified, Eurogroup for Animals calls for extreme caution and transparency in the development and implementation of nature credits.
The Partnership for Policy Integrity (PFPI) is a US-based NGO that uses data-driven advocacy and litigation to advocate internationally for forests, communities, and the climate. Thank you for the opportunity to respond to this consultation. In our attached consultation feedback, Section 1 offers comments on the role of nature credits in addressing the biodiversity funding gap.
CEPF recognises the potential of nature credits in safeguarding biodiversity and creating new income opportunities for forest owners. CEPF emphasises the importance of a clear and implementable framework that is attractive to all market parties.
ISEAL Alliance
· · filed 29 Sept 2025 · source
ISEAL welcomes the objectives of the EU Nature Credits Roadmap: namely to restore nature, halt and reverse biodiversity loss, ensure the long-term provision of ecosystem services, and strengthen Europes natural capital. We recognise the importance of this initiative in mobilising private finance to support nature restoration and in ensuring that investments are channelled towards measurable and transparent outcomes.
BLUEGent welcomes the Commissions initiative to establish a Roadmap for Nature Credits and strongly supports efforts to mobilise private finance for biodiversity restoration while safeguarding ecological integrity and social value. The biodiversity financing gap in Europe is significant, and public funds alone will not suffice.
Austrian Federal Economic Chamber - Wirtschaftskammer Österreich (WKO)
· · filed 29 Sept 2025 · source
WKO supports the Commissions ambition to catalyze private investment in nature-friendly measures, but the current roadmap is not yet an economically viable or trustworthy basis for business action. Only once legal clarity, binding and robust certification/monitoring, simple digital assessment tools, and market-wide integration deliver tangible economic benefits should a Nature Credits market be advanced; until then…
CEMBUREAU welcomes the possibility to give feedback on the roadmap towards nature credits. In general we agree to the concept, but still we have some remarks. 1. The strong ambition is conveyed in the tools presented in the note, but few guarantees or encouraging studies on the actual market potential are provided. 2.
TheRockGroup
· · filed 29 Sept 2025 · source
TheRockGroup, a sustainability consultancy pushing for the transition towards a sustainable and fair economy with offices in Amsterdam, Brussels and Cape Town, welcomes and supports the proposal of the EU to develop a roadmap for nature credits. Time is pressing for nature and nature credits could enhance a strong movement towards preserving & creating more nature.
Agentschap Natuur en Bos
· · filed 29 Sept 2025 · source
Belgian feedback on EU Roadmap towards Nature Credits: As Belgian pilot, we hereby present the consolidated feedback on the EU roadmap towards nature credits, based on consultation with relevant stakeholders. 1. Synergies with existing systems Most CRCF-methods currently applied offer significant co-benefits that are directly or indirectly nature- and biodiversity-related.
POSITION DES FACHVERBANDES DER HOLZINDUSTRIE ZUM FAHRPLAN FÜR NATURGUTSCHRIFTEN Grundsätzliches Aus der Pressemitteilung der Europäischen Kommission geht hervor, dass drei Viertel der Unternehmen in der EU von der Natur abhängig sind.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Regional Ministry of Agriculture, Livestock, Fisheries and Food. Government of Catalonia
· · filed 29 Sept 2025 · source
The Regional Ministry of Agriculture, Livestock, Fisheries and Food (DARPA) of the Government of Catalonia welcomes with great interest the communication on the Roadmap towards Nature Credits. DARPA DARPAs integrated agri-food strategies focus on biodiversity, ecosystem services, sustainable land management, and resilience, exemplified by the Bioeconomy Strategy, Sustainable Agricultural Production project…
With the EUs biodiversity financing needs estimated at 65 billion annually, and a global biodiversity financing gap of US$700 billion per year, Voluntary Nature Credits (VNC) could theoretically play a pivotal role in closing this gap.
spiritsEUROPE
· · filed 29 Sept 2025 · source
Spirits producers in Europe have long traditions of working from farm to glass, relying on high-quality agricultural raw materials and local ecosystems managed responsibly and sustainably. Our sectors geographical indications reflect centuries of knowledge in safeguarding landscapes, biodiversity, and rural economies.
TIC Council, the global association of the Testing, Inspection and Certification sector would like to provide its comments on the Roadmap towards Nature Credits. The new framework for Nature Credits represents a valuable opportunity for the European Union to promote nature-based solutions than benefit both the biodiversity and the competitiveness of industry.
The Federation of Swedish Farmers (LRF) appreciates the opportunity to contribute to Commissions Call for Evidence on the EU nature credits framework. Clarifying Incentives for Buyers A more thorough analysis is needed to understand the incentives for purchasing nature credits. The roadmap mentions growing business interest in nature, but does not specify what these business reasons are.
Allianz der öffentlichen Wasserwirtschaft e.V.
· · filed 29 Sept 2025 · source
While the Commission’s Communication is an important first step, it remains too vague on many points. The purpose of this critical assessment is therefore to provide a constructive follow-up to further developments. In particular, the water balance and related ecosystem services highlight the importance of protecting natural resources. This is becoming increasingly noticeable in the face of climate change.
Filed in German · English published by the European Commission
SCA FERME DE VAUROISY
· · filed 29 Sept 2025 · source
As a farmer, this opportunity goes in the right direction. We look forward to the possibilities of “validating” our projects, which have already been initiated or are under discussion. We have planted 5 km of hedges and invest in a rational processing tool (ECOROBOTIC. investment over 100 000). We are planning to locate hemp in water abstraction areas (10 ha to 20 ha will be affected).
Filed in French · English published by the European Commission
September 2025 EARSC Response: Roadmap towards Nature Credits The European Association of Remote Sensing companies (EARSC) is a trade association representing approximately 140 members across Europe in the Earth Observation (EO) downstream industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Finnish Food and Drink Industries' Federation
· · filed 27 Sept 2025 · source
We consider the proposed roadmap a significant step forward in strengthening nature-related efforts. We emphasize the importance of broad and inclusive collaboration throughout the preparatory process. The process must be transparent and participatory.It is essential that the EU-level preparation takes into account the specific characteristics of different Member States and regions to ensure effective and…
We have read with interest the Commissions Roadmap towards Nature Credits and welcome the opportunity to provide our input. Nevertheless, our analysis of the concept (see attached briefing) does not show a useful role for nature credits, and pursuing them is likely to distract from higher-priority and more proven solutions for biodiversity financing.
The Independent Advisory Committee on Nature Restoration in Ireland (RestoreNature.ie) welcomes the opportunity to contribute to EU discussions around nature credits as part of the Nature Restoration Regulation and the drafting process of our national Nature Restoration Plan. We have taken the opportunity to identify a series of concerns and issues that we believe require clarification.
As a major player in the energy transition, the EDF Group supports any initiative that could contribute to the restoration of nature on a large scale and welcomes the European Commission’s approach to building a framework for a high integrity, transparent and robust credit market.
Filed in French · English published by the European Commission
FoodDrinkEurope welcomes the European Commissions initiative to develop a high-integrity, science-based framework for nature credits. We regard this as a crucial step towards closing the biodiversity finance gap, mobilising private investment, and ensuring that restoration and conservation efforts are credibly rewarded.
The European State Forest Association (EUSTAFOR) welcomes the opportunity to contribute to the European Commissions feedback communication on the Roadmap towards Nature Credits. EUSTAFOR represents state forest organisations managing more than one-third of Europes forests.
The nature crisis is accelerating, and public attention drifts elsewhere with serious consequences. According to the latest analysis from the Stockholm Resilience Centre on planetary boundaries, the loss of biodiversity has already pushed ecosystem integrity beyond safe limits. This decline continues, increasingly endangering the ecological processes and services on which human well-being relies.
The Confederation of European Paper Industries members are deeply committed to advancing the European Unions ambition to enhance the health and resilience of forest ecosystems. We recognize that biodiversity is not only a cornerstone of forest ecosystem stability and productivity, but also a vital factor in achieving the Unions wider environmental and climate goals.
Enclosed, you will find an article I wrote a couple of years ago on nature credits (I call them eco credits) and how one can develop a system where nature's benefits can be Quantified, Monetized, Capitalized and Traded. This article might be interesting for you initiative.
Bayer appreciates the opportunity to contribute to the call for evidence for the European Commission Communication Roadmap towards Nature Credits. Bayer is a company with core competencies in the life sciences, active in agricultural products and services, pharmaceuticals and consumer health products.
WWFs response to the public consultation on the nature credits roadmap For WWF there are 5 key principles that need to be complied with to ensure that nature credits genuinely benefit both nature and people, and that companies funding them continue to reduce the impact of their operations. 1.
The European Dairy Association (EDA) supports the EU Commissions efforts to establish clear standards and certification for nature credits that are both effective and practical. Key recommendations include: ensuring tradability without undermining company targets, adopting flexible and modular scoring systems, and maintaining price stability.
eMission-X gGmbH
· · filed 26 Sept 2025 · source
Emission-X gGmbH welcomes in principle the European Commission’s initiative to mobilise additional private funding for biodiversity protection and restoration through natural credits. We see this as a great opportunity to promote environmental measures that go beyond existing public funding.
Filed in German · English published by the European Commission
Accounting for Nature
· · filed 25 Sept 2025 · source
We welcome the European Commissions leadership in developing a coherent and ambitious framework for nature credits in Europe. The Roadmap represents a strong step towards building a trusted, outcomes-based market that supports biodiversity protection and restoration while giving confidence to investors and buyers.
Consultation Submission to the European Commission Subject: Communication from the Commission – Roadmap towards Nature Credits [COM(2025) 374 final] Submitted by: CreditNature Ltd. Date: 23 September 2025 Contact: Dr [name removed], Head of International Projects and Cain Blythe, CEO ([email removed]) I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Qarlbo Biodiversity
· · filed 25 Sept 2025 · source
The Roadmap towards Nature Credits presented by the EU commission on the 7th of July represents a promising first step towards a standardized and credible European nature market. Nature credit markets are inherently complex structures with inbuilt risks and opportunities. Building a new market infrastructure with integrity safeguard from scratch is a very resource-demanding and time-consuming project.
RICS welcomes the European Commissions initiative to develop a high-integrity framework for nature credits. As the global professional body for Chartered Surveyors, RICS supports market-based mechanisms for nature-positive action, provided they are underpinned by robust standards, transparent governance, professional integrity, and public benefit. Please find our detailed feedback attached.
EUROPARC Federation
· · filed 25 Sept 2025 · source
EUROPARC Federation acknowledges the work of the European Commission towards achieving the international and EU biodiversity targets agreed in the Kunming-Montral Global Biodiversity Framework and the EU Biodiversity Strategy for 2030.
Open Call for Feedback - Roadmap Towards Nature Credits Contributor: The Swedish Biocredit Alliance The initiative Swedish Biocredit Alliance aims to create a viable, transparent, and responsible market for nature credits.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Our feedback outlines a strategic proposal to integrate Nature Credits into the European Trade Indexes Registry (EUTIR), establishing a unified digital trust infrastructure for environmental, trade, and sustainability data.
Circ is a France-based textile-to-textile chemical recycler that turns end-of-life poly-cotton into recycled MMC and polyester, substituting water- and forest-intensive virgin cotton/MMCs to cut land, water, and chemical pressures on biodiversity.
GRUPO SYLVESTRIS
· · filed 23 Sept 2025 · source
The Sylvestris Group highly appreciates the present initiative of the European Commission, as it considers it vital to draw up a roadmap for nature credits, building on the experience of projects that have been developed in Europe in recent years and serve as a reference.
Filed in Spanish · English published by the European Commission
The introduction of natural credits follows the neoliberal logic of solving problems by creating markets. However, this is a deception. The main causes of the environmental and social crisis are the profit-orientation of our economic system, the associated permanent growth pressure and the ever-increasing concentration of wealth.
Filed in German · English published by the European Commission
European Marine Board
· · filed 22 Sept 2025 · source
The European Marine Board (EMB) Secretariat is supportive of the ECs efforts to explore additional approaches for protecting and valuing nature. We are also encouraged by the recognition of the importance of supporting and informing the initiative by sound science. We are happy to see the marine ecosystems and nature users and the EU Ocean Pact mentioned.
Gobierno de Canarias
· · filed 22 Sept 2025 · source
The Government of the Canary Islands wishes to draw attention first of all to the difficulty in structuring the Plan itself, as reflected in the Communication from the European Commission (COM (2025) 374 final).
Filed in Spanish · English published by the European Commission
The European Commissions Roadmap to Nature Credits (COM(2025) 374 final) sets out mechanisms to mobilize private financial resources in support of a competitive and resilient economy. Building on this framework, the School Nature Credits proposal aims to extend the logic of nature credits to the educational sector, enabling schools to generate, manage, and invest credits in Nature-Based Solutions (NBS).
Land Niederösterreich
· · filed 19 Sept 2025 · source
Nature conservation projects under the 2023-2027 EU rural development funding programme are co-financed with 43 % of EU funds and 57 % of national funds (public funding from the federal government, Länder or municipalities). These projects contribute significantly to the protection and promotion of biological diversity.
Filed in German · English published by the European Commission
The European Outdoor Conservation Association (EOCA) welcomes the opportunity to submit feedback on the "Roadmap towards Nature Credits" on behalf of it's membership. The full response is attached as a pdf but please see the summary below: In EOCAs view any proposed Nature Credit system must: - Be a mechanism for nature and investment Nature Credits should be the mechanism from which businesses can invest in nature…
RegenPorts Barcelona
· · filed 18 Sept 2025 · source
This roadmap represents a key opportunity for Europe to advance towards financing mechanisms that recognize and enhance the value of biodiversity. From our field of action in port environments, we stress that marine and coastal ecosystems remain underrepresented in the debate.
Blue Marine welcomes the opportunity to provide feedback on the Commission's Roadmap towards Nature Credits. In our reply (attached), we underline that EU nature credits could potentially be further developed only if: (1) Biodiversity harmful subsidies are first eliminated and/or re-directed to close the biodiversity financing gap; (2) They are used as a complement, not a substitute, to adequate levels of public…
Nature Credits UG
· · filed 17 Sept 2025 · source
Developing high-integrity nature credit projects in forests, we welcome the EUs Roadmap towards Nature Credits and the opportunity for early feedback. Partnering with forest owners, we manage the full biodiversity project journey from design and implementation through verification and credit sales, supported by our proprietary digital MRV solution using AI and remote sensing.
FEAP Feedback on the Inclusion of Traditional Freshwater Fish Farming in the EU Nature Credit System The Federation of European Aquaculture Producers (FEAP) strongly supports the European Commissions initiative to create a robust, voluntary Nature Credit system.
The European Molluscs Producers Association (EMPA) welcomes the publication of the European Commissions new Roadmap toward Nature credits (COM (2025)374) and fully shares its ambitious and cutting-edge objectives.
As the first group to successfully deploy a global blockchain-based water credit system, Hypercube strongly supports the Roadmaps emphasis on scientific rigor, transparency, and integration with EU sustainability frameworks. We highlight five key points from our direct experience in developing and scaling an international water credit system.
Volvo Cars welcomes the European Commissions initiative to develop a roadmap for nature credits and particularly values the recognition of the need for public seed funding and the linkage with the Nature Restoration Regulation, which together provide a strong foundation for fostering collaboration between public and private actors.
Verra supports the actions outlined in the roadmap, particularly the goal of leveraging global standards for EU policy development. Rather than investing limited resources in creating new methodologies for nature crediting, we strongly encourage the European Commission (EC) to identify and employ internationally relevant, high-integrity methodologies that already exist (e.g., Verra's SD VISta Nature Framework…
LA ALMORAIMA
· · filed 10 Sept 2025 · source
A major step toward creating a framework. We manage both certified, purely forested areas and extensive livestock farming and organic agriculture, so we find a transfer of biodiversity between forestry (forests) and agriculture. It would be very interesting to consider these interactions and the transfer of biodiversity.
The EU Biodiversity Strategy for 2030 sets out ambitious targets for conserving and restoring nature, underscoring the crucial role of sufficient and sustainable financing. While the initial funding gap was estimated at EUR 20 billion annually, this figure has since been revised upward to EUR 48 billion per year, even before factoring in the financial demands introduced by the Nature Restoration Regulation.
Fundación Global Nature (FGN) welcomes the European Commissions Roadmap towards Nature Credits and commends its ambition to establish a high-integrity, transparent, and science-based framework. This could be a crucial opportunity to design a system that mobilizes private investment while safeguarding ecological integrity and social equity.
We welcome the Commissions initiative to explore a nature credit system as a tool to support nature restoration and conservation. Assigning value to actions that benefit nature can help mobilise private investment and incentivise positive environmental outcomes. However, we caution that while nature credits may play a supporting role, they cannot substitute for strong and direct government actions.
Sylva Nova SRL
· · filed 2 Sept 2025 · source
At the service of sustaining, restoring or building Europe’s forests for more than 30 years, we are convinced of the need to reconcile the world of businesses and that of forest owners on whom we all intend to contribute to the fight against global warming and biodiversity loss.
Filed in French · English published by the European Commission
EUs roadmap for nature credits confirms the fears we expressed about the leaked version. We understand that nature credits will most likely be used as international compliance offsets, despite the consensus that biodiversity offsetting is impossible in most cases. We note that privatising conservation policies will weaken them by introducing a profitability requirement.
Feedback from Fransylva (Federation of Private Forest Owners in France) on EU Nature Credits European Commission Public Consultation on the Nature Credits Roadmap Fransylva acknowledges the potential of nature credits to help preserve biodiversity and create new income streams for forest owners. The organization emphasizes the need for a clear, operational, and attractive framework for all stakeholders.
Fossagrim AS
· · filed 25 Aug 2025 · source
Fossagrim welcomes and celebrates this initiative! We believe this will encourage greater business engagement and mobilize private capital to reward landowners who adopt more sustainable land management practices, thus strengthening ecosystem resilience for the benefit of future generations.
Professor José Luis Suárez, IESE Business School (Spain, Germany, Brazil, USA) I strongly welcome the EU Roadmap to Nature Credits because it fills a gap left by primarily focusing almost exclusively on carbon credits. A more holistic framework was needed to embrace the many ecosystem services, ES, that nature provides. That was stated in one IESEs note I co-authored (enclosed).
Grupo EULEN
· · filed 21 Aug 2025 · source
It is necessary to develop a simple methodology to integrate various metrics such as tree absorption units (TnCO2), Shannon or Simpson or Margalef biodiversity indices, together with methodologies for the valuation of ecosystem services (iTree in Euros). This is to make it easier for the audit and verification to be carried out in a comprehensive manner.
Filed in Spanish · English published by the European Commission
We welcome the European Commissions initiative to develop a high-integrity, science-based framework for nature credits. This is a vital step toward closing the biodiversity finance gap, attracting private investment, and ensuring that restoration efforts are credibly rewarded.
Agrocortex Florestas do Brasil
· · filed 14 Aug 2025 · source
As a Brazilian forestry company operating in the Amazon for over a decade, Agrocortex welcomes the European Commissions initiative to develop a Nature Credits framework and expresses its full support. We manage over 180,000 hectares of tropical forest certified under FSC® and lead a large-scale REDD+ project (VCS 1686) that delivers verified outcomes in carbon sequestration, biodiversity conservation, and community…
As a leader in developing high-quality nature-based solutions projects globally, PUR commends the European Commissions leadership in developing a roadmap for high-integrity nature credits. We strongly support the ambition to mobilize greater levels of private finance to support the critical needs of biodiversity and ecosystem services; reward the contributions of farmers, foresters, and local communities; and…
Regenerate Asset Management
· · filed 13 Aug 2025 · source
Regenerate Asset Management welcomes the European Commission's Roadmap towards Nature Credits and strongly supports the ambition to establish credible, transparent, and scalable nature credit markets with an explicit emphasis on agriculture, across the EU by 2027.
I strongly support the EUs initiative to develop a high-integrity nature credit market. However, I would like to highlight a significant gap in the current roadmap: the lack of dedicated consideration for marine and coastal ecosystems.
I find 'Roadmap towards Nature Credits' initiative of EU sets out an exploratory process to develop high-integrity tools that reward nature-positive action. This is time to incentivize and reward those who undertake these nature -positive actions and invest in them.
PIMEC (MEMBER OF SME UNITED)
· · filed 24 Jul 2025 · source
We welcome the EC's initiative to develop a Nature Credits system within the EU. Subject to further elaboration, we believe that Nature Credits should be linked to the EU Emissions Trading System (ETS) and its related market, so that credit owners can monetise their contributions to biodiversity and nature preservation.
Nature Credits and Community Tourism I warmly welcome the Commissions roadmap towards nature credits, and its strong ambition to create a high-integrity, inclusive framework for valuing and investing in nature-positive action. I encourage the Commission to explicitly recognise Community Tourism as a key nature-positive sector.
The Institute of Environmental Engineering Kaunas University of Technology
· · filed 16 Jul 2025 · source
Feedback from the Institute of Environmental Engineering, Kaunas University of Technology on the Communication COM(2025) 374 final A Roadmap towards Nature Credits The Institute of Environmental Engineering at Kaunas University of Technology Lithuania, welcomes the European Commissions initiative to establish a roadmap for nature credits as a voluntary, market-based instrument to support biodiversity protection and…
Aquatic Life Institute
· · filed 15 Jul 2025 · source
Aquatic Life Institute (ALI) welcomes the European Commissions initiative to explore nature credits as part of a broader strategy to address biodiversity loss. We appreciate the recognition that marine and freshwater ecosystems are crucial to Europe's ecological and economic resilience.
UCi CA Interstate Holdings Inc.
· · filed 14 Jul 2025 · source
Looking for Partnering with the European Commission, their network, and specifically add value to your Nature Credits initiative. We/I believe that we have a platform and a synergy. Here is an explainer link: Well-Being Stewardship ON YouTube: https://youtu.be/hU82WExFSes I/we are a "Steward-Ownership" private corporate structure, with a Global footprint. Yours Truly, Murray A Persicke
Feedback on the EU Initiative for Nature Credits Submitted by a nature-based solution provider working at the intersection of biodiversity, regenerative land use, and environmental accounting. We strongly support the European Commissions vision to create a Nature Credit framework that recognizes, measures and rewards ecosystem services beyond carbon.
RESTORE Biodiversity together
· · filed 14 Jul 2025 · source
This document proposed an innovative approach to integrate biodiversity conservation into agricultural and forestry practices, while transforming investment in nature restoration into a lever for economic value creation and long-term sustainability. We welcome this pragmatic vision that balances innovation, ecological resilience and economic opportunities.
Filed in French · English published by the European Commission
The Commissions Roadmap towards nature credits starts with a rightly cautious approach of setting up an expert group to work on vital technical issues for both the supply and demand sides of nature markets. But it also needs a political message of caution about not reducing public funding under the assumption that markets will replace it. So far, nature markets are very small.
Comment on the Need for EU-Wide Harmonisation and Accountability in Biodiversity Enhancement Measures: As the European Union develops its Nature Credits framework and associated monitoring infrastructure, it is essential to ensure that not only positive actions are incentivisedbut that poorly implemented, abandoned, or even harmful biodiversity-enhancing activities are systematically tracked and addressed.
I note the following: 1. The document refers to organic farming as a useful standard for biodiversity protection and ecosystem services. This is not necessarily the case, since organic farming does not require measuring its effect on the environment or achieving certain results in terms of improving the natural environment.
Filed in Italian · English published by the European Commission
Stora Enso supports the European Commission's plans to develop an EU framework for nature credits. Drawing on our practical experience and insights, we would like to offer the following recommendations to help shape a credible, transparent, and effective voluntary framework for nature credits, one that delivers real ecological value: 1.
Huge potential ahead for European nature-tech startups as well The MycoNest Team (@myconester) is currently developing nature-based habitat structures which are designed to support wild pollinators and biodiversity regeneration. We warmly welcome the Commissions effort to create a nature credits framework that rewards scalable, meaningful ecological action.
Consultation - Roadmap towards Nature Credits As a practitioner working on nature-based microhabitat restoration in Central Europe, I welcome the Commissions effort to develop a Nature Credits framework that is credible, inclusive, and innovation-friendly.
Dear European Commission Team, On behalf of Pachama, we warmly welcome and applaud the European Commissions Roadmap towards Nature Credits. We strongly support this pioneering initiative to catalyze investment in biodiversity and nature-positive outcomes and commend the Commission's commitment to high-integrity, transparent, and science-based market design.
Fundación Citoliva
· · filed 8 Jul 2025 · source
I welcome the European Commissions proposal to develop a roadmap for Nature Credits as a strategic step toward aligning ecological restoration with private investment and the long-term resilience of rural production systems.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.