Building a Land-Sector Accounting Program That Holds Up

Getting your land-sector inventory right is one thing. Making sure it holds up under scrutiny is another.

The GHG Protocol Land Sector and Removals Guidance sets a high bar for assurance, and the gap between a sophisticated calculation and a credible, auditable result is wider than many companies expect.

In the final part of our conversation with Zander Dale of Schneider Electric (SE) Advisory Services, we get into implementation realities: what auditors will flag, how to govern insetting programs without double counting, where the boundary between insetting and offsetting actually sits, and the one piece of advice every sustainability lead should hear before diving into 518 pages of guidance.

Regrow: Assurance gets a full chapter in the Guidance. What's the most common failure point you expect auditors to flag once companies start reporting under the Standard?

Zander: Definitely weak traceability and a thin audit trail being the biggest issue.

Calculation errors will happen, but they're not the real risk. The bigger question is whether you can evidence the chain from product or activity through to spatial boundary, data source, method, assumptions, calculation and reported category. If that chain's weak, the number is hard to assure, however sophisticated the calculation looks.

The flags I'd expect auditors to raise are things like unclear spatial boundaries, inconsistent traceability assumptions, not enough evidence for sourcing regions, generic factors used on material categories, emissions and removals mashed into a single net number, and thin documentation of exclusions or methodological choices.

Removals will get the most scrutiny by far. If you're choosing to report them, you'll need to evidence empirical data, uncertainty, physical traceability, allocation, storage monitoring and reversal treatment. That's a much higher bar than simply saying a land-based program is expected to sequester carbon.

If the process isn't auditable, it's probably not robust enough to report with confidence.

My advice is always to design for assurance from day one, a clear methodology paper, version-controlled assumptions, data quality ratings, traceability evidence, calculation files and decision logs.

Regrow: Assurance readiness clearly depends on more than good data. What governance structures do companies need if they want land-sector accounting, FLAG targets and insetting programs to be credible and scalable?

Zander: Credible, scalable programs need clear ownership of the decisions, the data, the claims and the benefits.

In practice that means getting sustainability, procurement, finance, legal, suppliers, data teams and assurance providers aligned around one set of rules: eligibility criteria, claims protocols, data quality thresholds, carbon rights, benefit-sharing and clear decision-making. Without that, what I see is fragmented pilots, inconsistent assumptions and weak audit trails, which is exactly what pulls credibility apart once you try to scale.

Regrow: That alignment challenge gets even harder when a company is already running a carbon program alongside its Scope 3 reporting. How should they think about avoiding double counting?

Zander: You have to be really clear about who has the right to report what, especially where multiple actors are involved in the same value-chain intervention.

That is the issue I would focus on first. In a typical agricultural value chain, the farmer, supplier, processor, brand, downstream customer and sometimes co-investors may all have contributed to, or benefited from, the same intervention. They may all have a legitimate role in the program, but they cannot all claim the same reduction or removal in the same way.

So the starting point is not “can this generate credits?” It is: what is the value-chain relationship, what outcome has been created, who helped create it, and how should that outcome be allocated and reported without double claiming?

For me, the practical rules are fairly simple:

• Define the boundary: is this on-farm, within a specific sourcing relationship, or linked to a broader supply shed?
• Prove causality: what contracts, finance, activities or procurement commitments show that the intervention happened because of the company’s role?
• Report to the right scope: for example, the supplier may report a Scope 1 or 2 improvement, while the buyer may report the relevant Scope 3 change, provided the inventory rules and evidence support that treatment.
• Assign rights to report: if several parties contributed, the verified outcome needs to be allocated clearly, for example by funding share, contracted volume, sourced volume, or time-bound exclusivity.
• Prevent double counting: the same outcome should not be reported multiple times across parties without a clear allocation basis and supporting evidence.
• Assure and disclose: the company should be able to explain the methodology, data quality, traceability, allocation basis and claims position in a way that can stand up to review.

This is where a co-claiming protocol becomes important. It should set out who can report the outcome, on what basis, over what period, and for which purpose. That includes whether the claim supports supplier reporting, buyer Scope 3 reporting, FLAG target tracking, product-level communication, procurement decisions, or a broader contribution claim.

For Scope 3 programs, the question I always come back to is: are we trying to evidence a value-chain reduction, allocate a shared outcome between actors, support supplier transition, or make a broader contribution claim?

Those are different use cases, and they need different levels of evidence, traceability and assurance.

The advice I give clients is to lock this down early. It is much easier to design contracts, data collection, allocation rules and reporting rights upfront than to retrofit them once several parties are already using the same outcome in different ways.

So, the key is not to stop companies from co-claiming. Co-claiming can be legitimate and commercially useful. The key is making sure it is governed properly: clear boundary, clear causality, clear allocation, clear reporting rights, and no unsupported double claiming.

Regrow: Staying with the theme of claims, companies are increasingly interested in insetting, but the boundary between insetting, offsetting and broader climate contribution claims can be confusing. How should companies make that distinction?

Zander: I would use three tests, applied in order.

First, value-chain connection: is the intervention linked to your sourcing, suppliers, products or land-sector footprint in any meaningful way, and can you prove it? Second, accounting relevance: can the outcome credibly support inventory or target progress, or is it really a broader contribution or an external credit claim? Third, claims control: who gets to claim it, and how do you avoid double counting? Work through those three and the boundary usually gets a lot clearer.

Regrow: Those three tests are a good framework. SE Advisory brings along track record developing offsetting projects and nature-based solutions in the voluntary carbon market. Has that shaped the way you approach the Standard?

Zander: Quite a lot, actually. It's one of the things I think that sets us apart.

A big part of our market experience is developing offsetting projects and nature-based solutions in the voluntary carbon market. That means years of working with methodologies from standards like Verra and Gold Standard, and with the integrity questions that come with them, additionality, baselines, permanence, leakage, buffer pools, MRV and uncertainty. Those are exactly the concepts the Land Sector and Removals Standard now brings into corporate accounting, so for us it's familiar ground rather than a new discipline.

Developing projects on the ground also taught us that carbon is rarely the whole story.

The best nature-based solutions have to work for the people and landscapes they sit in, so community benefit-sharing, land and carbon rights, biodiversity and wider ecosystem outcomes have always been part of how we design and assess them. That's shaped how we pressure-test removals and interventions, we've seen where projects deliver real, durable outcomes and where the claims outrun the evidence.

So when a client moves from LSRS accounting into actual interventions, we're not starting from a blank slate. We're bringing that project-development experience, the methodologies, the integrity requirements and the social and nature benefits, into how the accounting translates into credible action on the ground.

Regrow: And as those projects start to scale, the legal and commercial side becomes important. What questions should companies resolve before scaling land-sector removals or insetting projects?

Zander: I'd want ownership, reporting rights, benefit-sharing, data access, confidentiality, exclusivity, claims and double-counting risk all resolved before you scale.

It doesn't always need a complex carbon-rights agreement at the outset, but you do need enough clarity to avoid a dispute later. That means agreeing on what data gets collected, who can use it, what claims are allowed, whether credits might be issued, and how benefits are shared with suppliers or growers. Sorting that early is far easier than trying to unpick it once projects and claims are already live.

Regrow: Are there requirements in the Guidance that you expect will be harder to implement in practice than they look on paper?

Zander: Yes, and it's usually the requirements that sound simple but depend on messy supply-chain realities.

Traceability is the obvious one. In theory you just need to know where products come from and which spatial boundary applies. In practice, agricultural supply chains are full of aggregators, traders, blending, shifting supplier relationships and patchy origin data.

Disaggregated reporting will be hard too. A lot of companies rely on emission factors or LCA datasets that bundle several effects into one number. The Standard wants more separation between land use change, land management emissions, production emissions, land occupation, leakage, biogenic products and removals, and that often means new data structures, not just better factors.

Removals are another area where practice will be harder than it looks. Reporting them needs empirical evidence, uncertainty estimates, physical traceability, allocation controls and ongoing storage monitoring. I'd caution anyone against treating removals as a simple extension of emissions accounting.

I'd also flag leakage and biogenic product emissions. They can be technically fiddly and commercially sensitive, especially if you're dealing with bioenergy, biomaterials, food and feed products, or interventions that might just shift production somewhere else.

The common thread is that none of this is a sustainability-team-only exercise.

Procurement, suppliers, data teams, legal, finance, assurance and commercial all need to be in the room.

Regrow: Last question: if you could give one piece of advice to anyone just beginning to wrap their heads around the 518-page Guidance, what would it be?

Zander: Start with the business decision, then work backwards to the data and the method.

The Guidance is long because land-sector accounting is complex. Trying to read all 500-odd pages cover to cover as step one is a fast route to overwhelm. Trust me, I tried!

I'd flip it and ask: what do we actually need this inventory to help us decide?

For one company that's FLAG target setting. For another it's CSRD readiness, regenerative agriculture investment, supplier engagement, bioenergy accounting, product footprinting, removals reporting or getting ready for assurance. Once the objective is clear, the relevant chapters, requirements and data needs fall into place much more easily.

I'd take it in phases.First, map applicability and materiality. Second, pin down the accounting categories and traceability gaps. Third, prioritize the commodities, geographies and suppliers where better data makes the biggest difference. Fourth, improve the methods over time, especially where the results will support targets, claims or investment.

The headline, as ever: don't wait for perfect data, but don't overclaim either. Use year one to build the architecture, understand the gaps and set out a credible roadmap.

A transparent, well-governed improvement plan beats a superficially complete inventory that falls over under scrutiny every time.

And I'd frame this as an opportunity. Yes, the Standard asks more of companies, but it also helps sustainability teams make better decisions, design stronger programs, and have far more credible conversations with suppliers, customers and investors.

Regrow: Great stuff. Thanks again for your time here.

Zander: My pleasure!

This concludes our three-part conversation with Zander Dale of Schneider Electric Advisory Services on the GHG Protocol Land Sector and Removals Guidance. If you missed them, we encourage you to check out Part 1 (covering why LSRS matters and how to prepare) and Part 2 (on Tier 3 methods, vendor evaluation, and digital MRV platforms).