Environmental integrity beyond carbon: Environmental co‐benefits and differentiated obligations in carbon market governance

Abstract Carbon markets promote nature‐based solutions (NbS) as a means of advancing climate mitigation and biodiversity objectives. Credits from these activities frequently claim benefits beyond carbon. Yet, legal frameworks remain largely structured around carbon accounting, raising questions about how broader environmental outcomes are addressed in practice. Environmental integrity encompasses both harm avoidance through safeguards and the proactive generation of environmental co‐benefits, but their legal treatment remains uneven. This article examines whether, how and with what legal effects environmental co‐benefits are integrated into carbon market governance. It undertakes a comparative, multi‐level analysis of the United Nations Framework Convention on Climate Change (UNFCCC), the European Union Carbon Removal Certification Framework (EU CRCF) and leading voluntary carbon market (VCM) standards. The comparison identifies two patterns. First, environmental safeguards are commonly embedded as procedural risk‐management mechanisms tied to monitoring, eligibility and certification requirements, whereas environmental co‐benefits are recognised but operationalised through flexible or incentive‐based mechanisms, such as disclosure tools, contractual arrangements and market incentives, primarily at the project level. Second, implementation varies across governance levels: UNFCCC mechanisms combine international rules with national implementation; the EU CRCF operates as a regional regulatory certification framework; and VCM standards rely on private certification and verification. These patterns reveal a fragmented governance landscape in which public regulation and private standards structure environmental outcomes while allocating responsibilities unevenly across market actors.