SustainCERT’s input to Verra’s Scope 3 Standard open consultation
SustainCERT is proud to be a strategic program partner in the development of Verra’s Scope 3 Standard (S3S) Program. Verra, the carbon credit registry behind the Verified Carbon Standard (VCS), recently held a public consultation on its draft Scope 3 Standard (S3S) Program. The program aims to enable companies to credibly account for and report on Scope 3 intervention activities, and includes a set of documents covering the standard, key definitions, and integration guidance.
As a strategic partner, SustainCERT actively contributes to the development of the S3S Program. We believe the framework offers an accessible pathway that incentivizes companies to take action on Scope 3 and credibly report on progress. Scope 3 action needs to be both practical and flexible — allowing companies to select the most appropriate pathways while upholding environmental integrity through robust safeguards.
Below, we summarize SustainCERT’s input on several key elements under development in the Scope 3 Standard Program.
Robustness of the Verra Scope 3 Standard
SustainCERT supports the robustness and reliability of Verra’s emerging Scope 3 framework. We advocate for high standards in accounting and verification, while emphasizing that integrity must be matched with practicality. Climate integrity should not be abstract or overly academic—it must be actionable by companies operating in real-world value chains.
We believe that rules and requirements should be:
- Grounded in real-world value chain operations across diverse industries,
- Flexible enough to adapt to sector-specific contexts,
- Designed to build trust among stakeholders without introducing undue complexity that could hinder adoption.
Advancing a Dual Factor Verification approach
The Scope 3 Standard Program is being developed in phases. Version 1 (V1) of the S3S Program is the first generation of rules and requirements, seeking feedback on a proposed approach to allocation and attribution of mitigation outcomes. While additional details will follow in V2, this early approach aligns with the dual factor verification model developed by SustainCERT.
We advocate for dual factor verification in which:
- The first factor ensures verified mitigation outcomes from value chain interventions,
- The second factor focuses on impact tracing and the right to report those outcomes.
This approach enables companies to credibly claim mitigation outcomes from value chain interventions, meet Scope 3 targets, and share the costs—and benefits—of interventions with partners in their value chain.
Introducing Scope 3 Intervention Units
Verra's Scope 3 Standard Program introduces the concept of Intervention Units, which represent verified GHG outcomes from specific interventions within defined boundaries. According to Verra, unitization helps companies track, account, and report emissions data more effectively by converting aggregated intervention data into standardized units.
Each program version takes a slightly different approach to Intervention Units:
- Version 1.0: Issues Intervention Units (IUs) using standardized VVB-assessed quantification methodologies. V1 also outlines auditing, ownership, management, and tracking of IUs.
- Version 2.0: Introduces Scope 3 Intervention Units (S3IUs), issued to companies with a verified right-to-report based on a demonstrable supply chain link between a reporting company and a Scope 3 intervention.
Verra’s goal is to facilitate co-investment, and co-claiming will be further enabled in the S3S Program V2, with the subsequent issuance of Scope 3 Intervention Units (S3IUs) to companies with an approved right to report.
SustainCERT sees impact unitization as a critical mechanism to help companies transfer verified mitigation outcomes and scale credible Scope 3 action. We support an approach that enables interoperability between standards, making it easier for companies to operate within a resilient and integrated Scope 3 ecosystem.
SustainCERT launched its own Impact Units in 2023 to help companies share the cost of interventions and be recognized for the impact generated. Impact Units:
- Represent quantified GHG reductions or removals from verified interventions,
- Are transferable and tradable, supporting flexibility and accountability,
- Bridge the gap between project-level results and corporate climate disclosures.
We believe intervention owners should have flexibility in how IUs are managed — ideally, including the option to convert carbon credits into Scope 3 Intervention Units. Furthermore, we aim to develop integration guidance for project transfer from SustainCERT’s value chain verification rules and requirements to the Verra Scope 3 Standard Program, and are collaborating with Verra to enable this.
Verra’s Scope 3 Standard Program as a pathway to Scope 3 reductions
SustainCERT recognizes Verra’s Scope 3 Standard Program as a significant step toward more credible and scalable Scope 3 accounting. Verra’s S3S Program offers an auditable framework for companies to account for emissions reductions achieved within their value chains. By emphasizing value chain interventions and mitigation outcomes, Verra’s system promotes collaboration between companies, suppliers, and project developers.
We support approaches that:
- Offer pragmatic pathways for companies to engage in decarbonization,
- Create an inclusive, scalable framework that supports real emissions reductions—not just reporting compliance,
- Help shift focus from reporting-only to one where emissions reductions are achieved, accounted for, and credited within value chains.
As part of our strategic partnership with Verra, we aim to provide transition guidelines and connect our digital impact management platform with Verra’s, enabling seamless integration once the S3S is launched.