Most law firms have already taken some form of action on carbon. For many, that has meant purchasing carbon credits, often through avoidance projects, and increasingly through early-stage carbon removal. That first step matters. But it also creates a new challenge.

The question is no longer whether to act. It is how to ensure that what has already been done and what comes next is structured, defensible, and aligned with how  law firms want to operate. Because in a market as complex as carbon removal, the real difficulty is not access. It is decision-making.

Projects vary widely in how they work, how long carbon is stored, how risks are managed, and how outcomes are verified. At the same time, decisions often involve multiple stakeholders and need to stand up to scrutiny from clients, peers, and regulators. This is where defining clear decision criteria for carbon removal in law firms becomes essential.

From activity to strategy

Many law firms first entered the carbon market through broad carbon neutral models: buying credits against annual emissions, often across the full footprint, and often with more emphasis on cost and convenience than on long-term climate strategy. That may once have been a pragmatic place to start, but it is becoming harder to defend.

As expectations have evolved, firms are under more pressure to separate reductions from compensation, be clearer about what is genuinely residual, and show more rigour around the quality of any credits used. That is pushing the market away from box-ticking offsetting and towards more considered approaches.

The Oxford Offsetting Principles have helped shape that direction by arguing for a transition towards carbon removals with increasing permanence over time. For law firms, that makes high-quality carbon removal a more credible fit: better suited to a sector where claims need to be precise, strategies need to be defensible, and climate action increasingly needs to stand up to long-term scrutiny.

This is where decision criteria become essential. They provide the structure needed to evaluate projects consistently, compare different approaches on a like-for-like basis, and explain why decisions were made. In that sense, the difference between activity and strategy is not just what a firm buys, but how it decides.

What good decision criteria look like

There is no single “right” carbon removal project. Every option involves trade-offs. Some offer high permanence but come at a higher cost. Others are more accessible but involve greater uncertainty. The role of decision criteria is not to eliminate these trade-offs, but to make them explicit and manageable.

In practice, strong decision criteria for carbon removal in law firms tend to focus on five core areas. The first is climate impact, meaning whether a project genuinely removes CO₂, how long that carbon is stored, and whether the activity is additional. This goes beyond headline claims and focuses on the underlying climate outcome.

The second is delivery and risk. Not all carbon removal is delivered with the same level of certainty. Some projects issue credits only after removal has occurred, while others involve forward delivery. Understanding timing, monitoring, and potential risks is critical.

The third is co-benefits and alignment. Many projects generate additional social or environmental impact, but the more important question is whether they connect to the firm’s broader positioning for example, regions it operates in or sectors it advises.

The fourth is price and trade-offs. Cost should be understood in context. Lower-cost options often come with lower permanence or higher uncertainty. The goal is not to minimise cost, but to understand what is being prioritised and what is being accepted in return.

The fifth is verification and transparency. Carbon removal claims need to be supported by evidence. This includes how removals are measured, verified, and tracked over time. Strong criteria ensure decisions can be supported with clear, auditable information.

If you’re exploring how these elements can come together in practice, you can read more about how we do things here at Klimate when it comes to our due dligence.

From criteria to consistent decisions

Defining criteria is only valuable if they are applied consistently. In practice, this means using the same framework across all projects and maintaining a clear link between criteria and decisions. Instead of asking which project feels most appealing, the question becomes how each option performs against the agreed criteria.

This creates a more objective process and makes it easier to compare fundamentally different approaches. It also acknowledges an important reality: there is no perfect project. The goal is not perfection, but consistency and transparency in how decisions are made.

Aligning stakeholders and reducing friction

One of the biggest challenges for law firms is organisational rather than technical. Carbon removal decisions often involve sustainability teams, finance, operations, and partners, each with different perspectives and levels of expertise. Without a shared framework, discussions can become fragmented and difficult to resolve.

Decision criteria provide a common language. They allow sustainability teams to structure recommendations, finance teams to understand risk, and partners to assess whether decisions align with the firm’s broader direction. Over time, this reduces friction and shifts discussions away from individual project preferences towards shared principles.

Decision-making as part of commercial positioning

Carbon removal is not just a sustainability issue. It is increasingly a commercial one. Clients are placing greater emphasis on climate and ESG, and the legal sector is responding through initiatives such as the Legal Sustainability Alliance, the Net Zero Lawyers Alliance, and collaborations like the Legal Charter 1.5.

In this context, law firms are expected not just to act, but to act in a way that is coherent and credible. Clear decision criteria make it easier to explain what has been done and why. They help ensure that climate activity aligns with the advice firms give to clients, and that decisions can be communicated with confidence. Decision-making, in this sense, becomes part of how a firm positions itself in the market.

Building a strategy that holds up over time

The carbon removal market is still developing, and expectations are evolving quickly. Frameworks such as the Science Based Targets initiative (SBTi) are shaping how companies approach carbon removal, particularly in the context of net zero.

For law firms, this creates an important consideration. Decisions made today need to remain credible in the future. Approaches that seem reasonable now may not hold up as standards mature and scrutiny increases.

Clear decision criteria help mitigate this risk. By grounding decisions in structured principles, firms are better positioned to adapt without needing to rethink their entire approach. They move from reactive decisions to a more resilient, forward-looking strategy.

Unlocking the strategic and commercial value of climate reporting

Climate reporting is not just a “nice-to-have” document at the end of the year. Stakeholder expectations are rising, and the gap between ambition and reality is getting easier to spot.

In our recent webinar session, I was joined by Ata Bærentsen (Partner at SustainX) and Molly Baxter (Carbon Consultant at Zevero) to unpack what is driving Environmental, Social and Governance (ESG) reporting today, how priorities are evolving, and what it takes to turn reporting into action inside your organisation. Here’s what we uncovered.

What is changing in ESG reporting

1) The move from ambition to credibility

A recurring theme in our discussion was the shift from high-level targets to proving what is actually happening. Many companies have bold commitments. The hard part is showing the plan, the progress, and what it takes to reduce emissions in practice. This means transparency even if—or especially if—progress is not linear.

2) Scrutiny is increasing

We are seeing growing media attention on ESG reports. Journalists (and the public) are getting better at reading disclosures and calling out inconsistencies. One example we discussed was a major Danish company being in the press as emissions continued to grow alongside business growth, even while reduction ambitions stayed high. Proactively addressing these pitfalls and plan to course-correct, backed by trustworthy data, can turn this reputation risk into a cause of credibility.

3) Pressure is coming from multiple directions

Regulation is a clear driver, still including the Corporate Sustainability Reporting Directive (CSRD). But, it’s not only regulators. We also see increasing pressure from customers and supply chains, including suppliers being asked to engage through Science Based Targets initiative (SBTi) expectations.

The role of data and tools

If credibility is the destination, data is the route.

Across organisations, ESG data is often spread across teams, systems, and spreadsheets. Ownership is unclear. Definitions drift. And when reporting deadlines approach, the work becomes a scramble.

A simple idea came through strongly: good reporting does not start in the report. It starts with structured, centralised data that is built for repeatable tracking and decision making.

That matters for three reasons:

• it helps you see where emissions sit across your value chain, including Scope 1, Scope 2 and Scope 3 emissions,
• it makes it easier to explain your numbers internally and build confidence in the strategic direction of climate plans, as well as the story you are telling,
• & it reduces the risk of errors and contradictions that can undermine trust.

Where carbon removal fits

Carbon Dioxide Removal (CDR) is becoming a bigger part of climate strategies. Many companies start with nature-based approaches and move towards more permanent carbon removal as they get closer to their net zero years.

But for many sustainability teams, carbon removal is only one part of a much wider plan. Tracking purchases and reporting on them can be complicated, and it can feel like a low reward, high risk activity if the data is not organised.

That is where structure matters most. To report on carbon removal responsibly, you need:

• clear records of what was purchased, when, and why
• consistent documentation you can use in disclosures
• a way to connect carbon removal to your wider decarbonisation journey, without overstating what it does

Without that support, the same action can start to feel risky in terms of greenwashing, or simply hard to explain.

What to do next

If you are trying to turn ESG reporting into something that actually drives progress, start here:

• be clear on what you are reporting for, and who needs to trust it
• agree definitions early, especially for emissions scopes and what sits inside your reporting boundary
• assign data ownership, and build a central place to track progress rather than a last-minute spreadsheet exercise
• treat carbon removal reporting as part of the wider ESG picture, with the same discipline on data, documentation and communication

Reporting is becoming a test of credibility. The organisations that do well will be the ones that make the data usable, the story honest, and the actions measurable.

If you want to listen back to the discussion access the webinar recording here.