Nature Markets Dialogue responds to the VCNM Consultation

11 July 2025

Following five workshops, two Ministerial roundtables, two stakeholder surveys and a consultation engaging over 180 professionals from 160 organisations, our Nature Markets Dialogue (NMD) has responded to the Department for Energy Security and Net Zero consultation on Voluntary Carbon and Nature Markets.

Our response draws heavily on the recently published NMD Findings and Proposal paper, and in particular our proposal for a Nature Markets Governance Scheme.

We targeted our responses at consultation questions addressing insetting, high integrity governance and stacking. Our responses continually pointed to the findings and proposal derived from the findings of the Nature Markets Dialogue over the past 18 months, arguing that:


  • Insetting requires strong oversight
  • Assurance and standards are not enough alone
  • Legal clarity is crucial
  • A statutory governance framework is essential
  • Stacking should be enabled, not trialled
  • A robust three-level 'additionality test' would remove the need for the limiting 'investment test' that exists in the Carbon Codes


The NMD urges a holistic, legally grounded approach to market governance. Without decisive government action to establish robust, consistent, and enforceable rules, private sector engagement in UK nature markets will remain limited. Read the whole consultation response here.

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