What the Carbon Markets Couldn't Hold
I.
For nearly two decades, voluntary carbon markets were treated as the working answer. Funds built portfolios around them. Foundations channeled grants through them. Corporations made net-zero commitments backed by them. Governments referenced them in policy as evidence that the market mechanism could handle what regulation had not. People who came up in environmental finance during this period learned to read the apparatus (additionality assessments, permanence projections, leakage calculations, registry balances) the way an earlier generation had learned to read balance sheets, and with roughly the same confidence that the numbers meant what they said.
Then, over a relatively short period, the apparatus stopped connecting to outcomes.
Investigative journalism, specifically a joint investigation by The Guardian, Die Zeit, and SourceMaterial published in January 2023, found that more than ninety percent of the Verra rainforest carbon offsets analyzed had produced no meaningful emissions reductions. Peer-reviewed studies found that carbon sequestration had been systematically overestimated, in some cases by an order of magnitude. Field measurements found that permanence claims were being undermined by fires, by changes in land use, by political shifts the original analyses hadn't priced.
The people who had built careers around this apparatus, who had spent years reading the numbers, who had structured funds around the commitments those numbers implied, found themselves holding tools that no longer connected to outcomes. They could see the mismatch. They couldn't yet say what to do about it.
This is not primarily an essay about what went wrong with carbon markets. The failures are documented, the investigations published, the papers peer-reviewed. It is an essay about the kind of experience that produced those failures: a framework that serious people built in good faith, applied with care and rigor, stops producing the outcomes it was designed to produce. Not because the people were careless, not because the intent was wrong, but because assumptions baked into the design turned out not to hold under the conditions the framework was eventually asked to work in. That experience is recognizable far beyond this domain. The carbon markets are the case. The pattern is what travels.
II.
The original design intent was serious, and the problem being solved was real. The theoretical case for pricing carbon emissions was well-grounded: if atmospheric carbon imposes costs that markets don't price, a mechanism that prices them is a rational response. The cap-and-trade approach had produced measurable results when applied to sulfur dioxide under the 1990 Clean Air Act Amendments, reducing acid rain through market mechanisms more efficiently than direct regulation had managed.
The Kyoto Protocol's Clean Development Mechanism, established in 1997, applied the same logic to greenhouse gases, allowing developed countries to meet reduction commitments partly by financing mitigation projects in the developing world. The voluntary carbon market grew alongside compliance markets (the EU Emissions Trading System, California's cap-and-trade program) as corporations and institutions sought to address emissions that existing regulatory frameworks hadn't yet reached.
By 2021 the voluntary carbon market was a roughly two-billion-dollar global system. Verra's Verified Carbon Standard was the dominant registry. Projects ranged from avoided deforestation in the Amazon to cookstove programs in sub-Saharan Africa to industrial gas capture in South Asia. Each project issued credits representing a metric ton of carbon dioxide equivalent avoided or removed; buyers purchased those credits against their own emissions, on the shared understanding that the credit represented a real-world reduction that would not have occurred otherwise. Reasonable people, looking at the scale of the system and the rigor of the certification apparatus, concluded this was a workable mechanism and invested accordingly. That conclusion was not unreasonable given the information available at the time.
This essay is primarily concerned with the voluntary market: the self-certified, largely unregulated system that grew alongside the compliance markets. The EU ETS and California's compliance program operate under different structural conditions, including mandatory participation, regulatory enforcement, and iterative government reform. They have different track records and have been substantially revised in response to early design failures. The voluntary market, whose structural properties and failure modes are the subject of what follows, is a distinct mechanism with distinct analytical problems.
III.
The failures, when they came, were not random. Each one was predictable from the structure of the mechanism itself. Not execution failures, not bad actors making unusually bad choices, but structural failures built into the design whether or not anyone saw them coming. There are four of them, and they deserve to be named carefully.
Additionality
A carbon credit is supposed to represent an emissions reduction that would not have occurred in the absence of the market, such as a forest protected that would otherwise have been cleared, or a stove installed that would not otherwise have been affordable. The technical term for this condition is additionality: the credit is only real if the reduction was additional to what would have happened anyway.
The structural problem is that additionality is a counterfactual. You cannot directly observe what would have happened in the world without the project; you can only model it. Those models, developed by verification consultants retained and paid by project developers and submitted to registries for approval, required assumptions about baseline deforestation rates, alternative land use, and whether the financial incentive was actually necessary to change behavior.
The relationship between the party being audited and the party conducting the audit created predictable selection pressure on the model's conclusions. The January 2023 investigation by The Guardian, Die Zeit, and SourceMaterial analyzed Verra's REDD+ tropical forest protection credits and found that more than ninety percent of those credits produced no meaningful emissions reductions. The structural problem in the additionality mechanism (the auditor-paid-by-audited relationship generating predictable overestimation) shows up across categories, but its severity varies with how directly counterfactual the baseline modeling must be.
Permanence
A credit representing a ton of carbon sequestered in a forest assumes that carbon stays there over the period for which the credit is claimed, typically decades. The structural problem is that forest carbon is not permanent. Fire, disease, land-use change, and political instability can release stored carbon quickly. The California compliance market discovered this explicitly in 2021, when wildfires burned through forest areas covered by the market's protocol. The buffer pool, maintained as a reserve against this contingency, was depleted to levels that called the market's integrity into question because climate-driven fire conditions outpaced the prior permanence assumptions.
Leakage
Protecting one area of forest from logging should not simply shift the logging to an adjacent area. The technical term for this displacement is leakage. The structural problem is that leakage is genuinely difficult to measure across boundaries and across time. Research published in the Proceedings of the National Academy of Sciences by West and colleagues in 2020 found that additionality had been substantially overestimated, with leakage at larger geographic scales than the protocols measured as a significant contributor. The measurement was technically defensible at the scale at which it was conducted; it was incomplete at the scale at which the actual displacement was occurring.
Double-counting
A single ton of avoided emissions should not be claimed twice: once by the country hosting the project toward its national climate commitments, and again by the corporate buyer toward its net-zero commitment. The voluntary carbon market's registry architecture was not designed to prevent this. Agreement on Article 6.4 was finally reached at COP29 in 2024, establishing a UN-supervised mechanism with clearer corresponding adjustment requirements. What the decade-long negotiation record documents is that the original voluntary market design had not solved the problem, and that solving it required a level of intergovernmental coordination the market itself could not produce.
IV.
The more important question is why competent, analytically rigorous people couldn't see the failures coming, and why the system continued attracting serious institutional investment even as warning signs accumulated.
Large-scale governance systems necessarily simplify the realities they coordinate. The carbon market's structural vulnerability ran through two channels simultaneously: the fungibility of the underlying good was weak, and the verification architecture was self-certified rather than regulated. Three assumptions were doing the most load-bearing work:
- Commensurability: The assumption that one ton of $CO_2$ equivalent avoided in a Brazilian rainforest is interchangeable with one ton avoided in an American industrial facility. This is an artifact of the measurement system, not a property of carbon in ecological systems.
- Fungibility: The assumption that credits can substitute for each other without meaningful loss. This served the market's liquidity, but ignored the specific characteristics of specific places that determined whether permanence and additionality claims held.
- Measurability: The assumption that emissions reductions could be accurately quantified using available methods. This became untenable as remote sensing and peer-reviewed study produced measurements that diverged significantly from verification protocols.
Carbon markets persisted because they solved institutional problems: they translated climate obligation into financial instruments, allowed corporations to demonstrate action, and gave governments a mechanism where direct regulation was politically difficult. When an instrument is simultaneously analytically fragile and institutionally useful, the process of registering the fragility tends to be slower than external analysis would suggest.
V.
The assumptions that undermined voluntary carbon markets are now being carried into new domains:
- Biodiversity Credits: This mechanism is structurally identical. Research published in Nature in 2023 by zu Ermgassen and colleagues found that the commensurability assumption—that an acre of wetland is exchangeable for an acre of woodland—is even harder to defend ecologically than the carbon equivalent.
- Water Markets: The Murray-Darling Basin water market in Australia was the subject of a Royal Commission in 2019 that documented measurement failures and leakage. Treating water in specific ecological functions as fungible produced predictable consequences.
- Payment for Environmental Services (PSA): Costa Rica's program has performed better by using a different design: a direct relationship between payer and steward, place-specific measurement, and an arrangement designed for durability rather than liquidity.
The survey suggests that voluntary carbon market failures were not anomalies. This is what happens when a framework's blind spots are structural: users address symptoms case by case while missing the pattern in the premises.
VI.
The new playbook does not exist yet. What we have is a more precise version of the question: which environmental goods can be abstracted to the tolerances commodity markets require, and what institutional arrangements are capable of handling the ones that cannot.
The work of determining where the threshold runs is underway in peer-reviewed literature and in legal and financial experimentation. What is available, for now, is the discipline of articulating the failure precisely: naming the assumptions that didn't hold, watching where those same assumptions are being carried into new domains, and refusing the temptation to replace one set of overconfident answers with another. The question of what can hold that weight, at scale, over time, remains genuinely open.


