DAX40 Carbon Credit Disclosures Face Transparency Scrutiny Under CSRD

A new joint analysis by carbon credit provider Senken and carbon ratings platform Sylvera has raised concerns over the transparency and quality of carbon credit disclosures among Germany’s largest listed companies under the EU’s Corporate Sustainability Reporting Directive (CSRD).

The report, titled “Buying Blind?”, reviewed FY2025 disclosures from 39 companies in the DAX40 index — Germany’s benchmark stock market index comprising 40 of the country’s largest publicly traded companies — and found that 21 companies reported purchasing a combined 4.84 million tonnes of carbon credits.

However, none of the companies disclosed project-level identifiers that would allow independent verification of the credits used.

According to the analysis, approximately 2.17 million credits — representing 45% of the reported total — could not be traced to identifiable projects across major public carbon registries. Among the projects that researchers were able to identify and assess, 57% scored below Sylvera’s BBB credibility threshold, raising questions about the environmental integrity of a large share of disclosed offsets.

The report argues that current CSRD reporting requirements under ESRS E1-7 do not require sufficient detail to verify whether purchased carbon credits are linked to credible climate mitigation projects. Only six of the 21 identified buyers provided additional information on credit sourcing, with four doing so voluntarily and two through compliance obligations under California regulation.

Adrian Wons, CEO and founder of Senken, said the findings demonstrate a major transparency gap in Europe’s corporate carbon market disclosures. He noted that while companies reported millions of carbon credits, the lack of project identifiers makes independent assessment nearly impossible.

Sylvera CEO and co-founder Allister Furey added that certification alone does not guarantee climate impact quality, arguing that project-level transparency will become increasingly important as voluntary carbon markets mature and scrutiny intensifies.

The report proposes a targeted amendment to CSRD disclosure rules requiring companies to publish project-level carbon credit information. According to the authors, such a change would significantly improve market transparency without creating additional reporting burdens for companies.

The findings come as European regulators, investors, and climate watchdogs continue to push for higher integrity standards in voluntary carbon markets and stronger accountability around Scope 3 emissions and offsetting claims.

H2Bulletin View: The report underscores the increasing scrutiny facing corporate carbon credit strategies as sustainability disclosure requirements evolve across Europe. While the CSRD has accelerated transparency in climate reporting, the absence of project-level disclosure standards may expose companies to growing reputational and regulatory risks around the credibility of their offsetting activities. The findings are likely to strengthen calls for higher-integrity carbon markets, improved traceability, and more rigorous verification frameworks as investors and regulators place greater emphasis on the quality — not just the quantity — of corporate climate claims.