Much of the carbon offsetting that public bodies buy is not tendered on its own. It sits inside an energy contract. In the Netherlands, municipalities tender “carbon-compensated natural gas”, with the supplier arranging the offsetting. Public examples on the Dutch procurement platform TenderNed include a joint tender by the municipalities of Uithoorn and Ouder-Amstel in 2025 for renewable electricity and carbon-compensated gas, and a supply of carbon-compensated gas for 2024 to 2029 through the IJmond & Kennemerland regional purchasing office. In both, the requirement on the offsetting is that the supplier demonstrates it with Gold Standard certificates.
Naming a standard is a start, but it says little about which project, which year, whether the credits are retired in your name and what you pay for them. For public bodies, which spend public money and account for it publicly, that is a gap.
This guide covers public procurement of carbon credits: when an EU tender applies, which requirements to set, how to award on quality and how to communicate about it. The examples are Dutch, but the approach works for any EU public buyer.
The short answer. In public procurement of carbon credits, set requirements on the credits themselves, also when they are part of an energy or travel contract: programme and label, registry and verification, retirement in your name, no double counting, vintage and a price per tonne. Award on best price-quality ratio, and check the EU thresholds to see whether an EU procedure applies.
When does an EU tender apply?
The estimated contract value decides the route. For supplies and services, these EU thresholds apply from 1 January 2026 to 31 December 2027, excluding VAT, as summarised by PIANOo, the Dutch public procurement expertise centre:
Contracting authority | Threshold for supplies and services |
|---|---|
Central government | EUR 140,000 |
Sub-central authorities (municipalities, provinces, water boards) and other contracting authorities | EUR 216,000 |
At or above the threshold, an EU procedure applies. Below it, your own procurement policy decides the route. If the offsetting is part of a larger energy or travel contract, the value of that whole contract counts. This is orientation; have the choice of procedure checked by your procurement adviser or lawyer.
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Which requirements to set for the carbon credits
Split the requirements into exclusion criteria (yes or no) and award criteria (scored on quality). A practical set:
Requirement | Type | Why |
|---|---|---|
Credits issued under an ICVCM CCP-Eligible programme, preferably with the CCP label | Exclusion or award | The CCP label is the most widely supported integrity benchmark; labelled supply is still limited |
Public registry, unique serial numbers, verification by an accredited body | Exclusion | Without a registry nothing can be checked |
Retirement in the public body’s name, with serial numbers within 30 days | Exclusion | Prevents retirement in a supplier’s pooled account |
No double counting: one registry, not claimed elsewhere | Exclusion | Each tonne may count only once |
Vintage no older than a set number of years before the delivery year | Exclusion | Recent credits match the year you offset |
Price per tonne excluding VAT, costs shown separately | Exclusion | Makes bids comparable, also inside an energy contract |
Evidence of additionality and conservative quantification | Award | The core of the climate impact |
For nature-based projects: buffer pool or other reversal safeguard | Award | Carbon in forests can be released again |
Social and environmental safeguards, benefit sharing | Award | Public money should not come at the expense of local communities |
Article 6 status and corresponding adjustment | Information or award | Determines which claim you can make |
Documentation for communication and reporting | Exclusion | You need to be able to show what you bought |
Our list of 19 questions to ask every carbon credit supplier turns these requirements into questions for bidders. To understand how to judge quality, see how to assess carbon credit quality.
Award on best price-quality ratio
Do not award on price alone. Prices differ widely between project types, and a low price says little about climate impact. A common set-up weighs price against quality, for example 30% price, 40% integrity and impact, 15% social and environmental safeguards and 15% delivery and supplier; that is also the default weighting in Regreener’s RFP builder. Fix the weighting in the tender documents and make the scoring scale concrete, for example 0 to 5 per criterion.
If the offsetting is part of an energy contract, ask bidders to price and document the offsetting part separately. Otherwise the quality of the credits disappears into the total price of the gas.
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What a public body should and should not say about offsetting
EmpCo, the EU directive that bans “carbon neutral” claims based on offsetting since 27 September 2026, regulates companies’ commercial communication towards consumers. A public body’s own communication is usually not covered directly, but its suppliers are, and public scrutiny is the same. “Carbon neutral gas” or “climate neutral municipality” based on credits suggests the emissions are gone, and they are not.
Communicate the way companies now have to: as a contribution. “In 2026 the municipality financed 1,500 tonnes of verified emission reductions from [project] in [country], certified under Gold Standard. This does not reduce the emissions from our gas use, which we are cutting through [measures].” Our guide to contribution claims gives more examples, and our article on carbon neutral claims under EmpCo explains the rules.
Tip from Bernard de Wit, Co-founder of Regreener: “In many public contracts, the offsetting is one line in the gas contract: ‘Gold Standard certificates’. That tells you which rulebook applies, but not which project, which year or in whose name. Ask for the projects, the serial numbers and a price per tonne. It costs a bidder an hour, and you can show your council exactly what was paid for.”
Plan the tender
A simple sequence:
Set the volume and purpose. Which emissions do you offset, how many tonnes a year, for how long? A multi-year contract gives suppliers room to reserve credits of good quality.
Choose the route. Stand-alone or bundled with energy or travel, and EU or national based on the estimated value.
Write the requirements and award criteria. Use the table above as a basis.
Publish and answer questions. On your national procurement platform, with a clear timeline for questions, answers and submission.
Evaluate and award. Exclusion criteria first, then scores, then price.
Check after delivery. Verify the retirements in the registry before you communicate or report.
For the general structure of a tender, see our carbon credit tender guide. If you are buying carbon removals rather than avoidance credits, also read how to run a carbon removal tender.
Draft your tender documents
Regreener’s free RFP builder works for companies and public bodies. You get a first draft of your public tender for carbon credits with quality requirements based on public frameworks, a bidder questionnaire and an evaluation sheet, plus an indication of whether the EU thresholds come into play. It is a starting point: you add your own terms, procedure and legal review.
Want to discuss the requirements or the carbon credit market? Talk to a Climate Strategist. Every project Regreener offers has been assessed with our 100+ datapoint quality framework.
