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• Compliance Hedge · CFO & Treasury
NEEDC is new,
It is the Scope 3 accounting instrument
your FY2027 filing requires.
NEEDC is a specific accounting instrument for a specific regulatory line item — Scope 3 embodied carbon — that CSRD now requires to be disclosed. This is the distinction your CFO needs to make in the FY2027 filing.
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⚖ Why a generic offset will not satisfy your FY2027 CSRD auditor
CSRD requires Scope 3 emissions to be reported with source-specific traceability from FY2026 data. A pooled REDD+ credit cannot be attributed to a specific Scope 3 category. NEEDC can — because it is traced to a named building, a named EPD dataset, and a named LETI Band improvement.
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EU Green Claims · Post-September 2026 Compliance
The EU Green Claims Directive bans generic offset claims without specific, traceable, verified reductions. NEEDC provides: named building, named methodology, named VVB, named PDD. This is the level of specificity required.
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The Compliance Runway · Jun 2026 → FY 2027
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Jun 2026 · ERPA executed
Forward off-take secured at £49/t. Certificate of Abatement issued. Zero VAT.
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Sep 2026 · EU Green Claims Directive active
Generic offsets without traceable verification become non-compliant for EU market claims. NEEDC is traceable.
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FY 2026 · CSRD FY2026 data year begins
Scope 3 embodied carbon must be measured and reported. The NEEDC off-take agreement is cited as the offset instrument in Scope 3 Cat 1/2 disclosure.
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Q1 2027 · NEEDC registry issuance (M-7)
Verified credits transferred to Buyer’s registry account. CSRD filing references specific registry serial numbers, building coordinates, and the VVB validation report.
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FY 2027 · CSRD FY2026 report filed
Scope 3 Category 1/2 embodied-carbon line item closed with audit-ready NEEDC documentation. Compliance achieved.
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Asset Traceability
You are buying this building’s embedded offset.
Not a sequestration promise. Not a pooled fund. A specific stake in a specific building’s as-built carbon emission reduction — verified at six independent layers, each traceable to a published document.
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The decision, stated plainly
View the full project document suite →
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What you pay today
Wire on date of sale · zero VAT.
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£505,680
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What you lock in
£101/t alpha spread · £1,042,320 implicit value uplift.
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£49/t vs £150/t ceiling
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VAT saving vs post-compliance
HMRC RCB 7, zero-rated OTC (range spans 20% VAT on £49/t today through the £150/t compliance reference).
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£101,136 – £309,600
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CSRD compliance achieved
Embodied-carbon line item closed for FY2027 filing. Audit-ready documentation.
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Scope 3 Cat 1/2 closed
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What you receive
Certificate of Abatement on execution · quarterly reports · registry serial numbers at M-7 · XDC provenance token.
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Certificate of Abatement + reports
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Zero holding fee · OTC carry advantage
£0/t per annum holding cost on un-retired NEEDC units held as a forward position — compared to £10/t per annum charged by ICE brokers for physically warehoused compliance units on exchange.
Zero VAT (+20% saving) on OTC settlement — the full 20% VAT charge on exchange-cleared units is removed, with VAT mitigated all the way to the £150/t compliance floor.
£0/t NEEDC OTC carry |
£10/t ICE broker carry |
£103,200 Avoided · 10,320t / 12mo |
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The NEEDC forward ERPA functions as a convertible note to the compliance market — VER units held OTC at £49/t convert automatically to Certified Emission Reduction (CER) units upon Gold Standard or GCC 2.0 registry acceptance, at which point they retire into the compliance market at the prevailing SCC-aligned price (ceiling £150/t). No re-purchase, no re-registration, no broker intermediation required at conversion.
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Buying NEEDC OTC today is not a bet on carbon markets. It is a hedge against the cost of not having an audit-ready embodied-carbon instrument when CSRD auditors, GRESB assessors, or SBTi reviewers ask for one in 2027. The cost of that instrument rises — possibly by £101/t — as soon as methodology acceptance is confirmed. The window at £49/t is a function of pre-compliance timing, not product quality.
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[ Open ] · Board-ready
CFO Approval Pack
The full traceability dossier, decision summary, and FY2027 Scope 3 mapping in one board-ready document.
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Direct · +44 7308 139 770 · UK office hours (GMT)
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Best regards,
Alexander Morgan
Director · Circular Clean Wave Ltd
+44 7308 139 770 · [email protected]
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