Peatland Code FAQs

Q. Is there a minimum size area that makes it worth putting a site through the Peatland Code? 

A. As a minimum it is likely to be desirable to cover the Peatland Code costs (development, validation, verification and unit fees). The number of units an area could generate depends on the type of restoration taking place (restoration of actively eroding areas could generate 5-10 times the units compared of restoring other areas) so a rough estimate of units is a better indication than area of project viability. This will depend on emission factors and carbon price but sites with less than 10 hectares are likely to be marginal.

Q: Will the Peatland code affect any future or existing agri-environment schemes?  

A:  Restoration carried out through the Peatland Code is designed to reduce the emissions from degraded peatlands. This generally does not conflict with any current agri-environment scheme (the modified condition category could however, see below) and the government in England has confirmed that agricultural support will continue to apply to recovering and healthy peatlands. However, until all the details of the new agri-environment schemes is known we cannot be fully sure. 

Please note that engaging with the Peatland Code on land in the ‘modified’ baseline condition category could be interpreted as taking on a prior obligation, depending on the restoration programme being delivered. This could affect the eligibility of that land for Countryside Stewardship or ELMS in England. It is important therefore to seek advice on this before restoration starts. 

Q: The Peatland Code says restoration must not conflict with land management – can it be done retrospectively if, for example, it’s mentioned in the Countryside Stewardship agreement? 

A: No. If CS has paid for partial restoration of the site, you could do the rest as PC. However, the site must be registered before work takes part so it cannot be done retrospectively. If restoration has previously taken place and has failed, that site could then be put through PC going forward.   

Q: Can peatland code sites be on a SSSI?  

A: Yes - Peatland restoration work regularly takes place on SSSIs.  Consent needs to be applied for through Natural England to ensure restoration is carried out sensitively.  Many agencies and contractors working in Peatland Restoration will have experience of working on SSSIs and applying for consents.   

Q: Does the peatland code affect how the land can be managed in any way?  

A: To claim emission reductions, the restoration needs to improve the condition of the peatland (e.g. through revegetation, channel blocking, hagg reprofiling).  The land should be managed in a way that any improvements are maintained whilst the site is in the scheme (minimum 30 years) and that improvements are not at the expense of degradation elsewhere (see leakage question below).  Landowners should check that there are no land management agreements in place that could conflict with achieving the emission reductions.   

Q: How does the code affect land management elsewhere on the land holding?  

A: In addition to achieving the condition change (see above) if any change in management practices occur elsewhere on the landholding as a direct consequence of the restoration, then the project should carry out an assessment to determine the carbon emissions (tCO2e) occurring as a result of this and deduct from the project emission reductions if over 5%.  This could include greater stocking density outside the project area or an increase in burning.   

Q: Is there any impact on other interests i.e., graziers?

A: Aside from maintaining the emissions reductions, the peatland code does not place any other stipulations on how the land is used.  However, landowners should consider whether the activities of other actors on the land could be detrimental to this, for example grazing intensity could affect revegetation. 

Q: If the land is a common, who owns the carbon?

A: The carbon is owned by the landowner. 

Q: Can government owned land enter into a Peatland Code agreement?

A:   Being a government body does not prevent registering a project under the Peatland Code. One thing to note is that the Peatland code states that restoration and management activities shall not conflict with existing land management agreements, which can be more common on these types of lands. Here is some guidance on what to look out for: 

1. Existing land management agreements on the land could include governmental agri-environment payment schemes, continuing obligations under Higher Level Stewardship or other agreements and their equivalents under the Rural Development Programmes of the devolved administrations, access or other management agreements covering access land under the National Parks and Access to the Countryside Act 1949, as well as Site of Special Scientific Interest (SSSI) agreements. Other agreements that may be encountered could include Ancient Monument agreements and Forestry Dedication Covenants. Please refer to paragraph 1.5 for financial additionality rules and eligibility 

    

2. The additionality test:   A peatland restoration project passes the legal test (Test 1 – Legal Compliance) when there are no laws, statutes, regulations, court orders, environmental management agreements, planning decisions or other legally binding agreements that require restoration, or the implementation of similar measures that would achieve equivalent levels of GHG emissions reductions. Statutory designations, such as SSSI status, are not regarded as legal obligations of restoration 

Q: Are grazing, brash removal or burning included in the ‘vegetation removal’ which would make a site ineligible?  

A: No, this is more about intentionally removing vegetation and stripping it down to the bare peat.  

Q: Can you create a mosaic of habitats, e.g. planting scrub on shallower peat to recreate what might be naturally there (possibly as part of a HLS)?  

A: Potentially if very shallow but depends on tree planting regulations.  May have to have a buffer to ensure scrub won’t encroach on newly restored peat. 

Q. Can land entered under the Peatland Code still qualify for business relief?

A. Yes, they can. HMRC are of the view that the activities necessary to create, manage and maintain the land for the purposes of generating credits for use or sale will mean any business undertaking these operations will, in general, not be mainly involved in the holding or making of investments, as required by IHTA84/S105(3).

Q. What does the forestry removal element of eligibility criteria cover? What happens if you need to remove trees/shrubs/rhododendron as part of the restoration? 

A. This can be done but it can’t be included in the Peatland Code. If you require a felling license to for the removal then it is not eligible.

For information on how to register your projects, please visit Registering a project | IUCN UK Peatland Programme 

Q: Why is site registration needed and when should it be done?

Site registration provides a public record of a project intending to become Peatland Code validated/verified. A project must be registered prior to any works starting and ideally to allow time for validation before works begin (see validation and verification section below). Projects are registered on the UK Land Carbon registry.  

Q: Why is an account on the UK Land Carbon Registry needed and how is it created?  

A: A S&P Global account is required to register Peatland Code Projects on the UK Land Carbon registry and to record carbon units issued. A  link to the new account form and user guide that S&P (previously IHS Markit) provide is here (under step 2).  Details on account types are here. Please note that proof of identity/organisation may be required when setting up an account. 

Q: What is a communications agreement and why is it needed?    

A: A communications agreement is required where a landowner wishes to grant another party (i.e. project developer permission to register a site and hold carbon units (and carry out actions associated with these i.e. conversions, transfers, retirements) on their behalf.  A template is available from the Using the Peatland Code webpage.  

Q: Can previous work be entered into a PC agreement?

A: No - a site needs to be registered before any works take place. 

For detailed information on the validation and verification process see Peatland Code Project Plan and Restoration Validation | IUCN UK Peatland ProgrammeQ: What do the project validation, restoration validation and ongoing verifications involve? 

A: Project validation is an independent check on the project documents and carbon calculations carried out by an independent body to assess the accuracy of the calculations and viability of restoration plans.  Restoration validation is a further independent check within 1 year of the restoration being completed that the restoration has been carried out as described.  Project verification is a check that the condition change has occurred and is sustained over time. 

Q: How many validations and verifications are required? 

A: All projects will need two validations (pre and post works).  Verification takes place after 5 years and at 10 year intervals thereafter (i.e. 5,15,25,35,45 etc).  The last verification may only cover a 5 year period to make up to the project length (i.e. if 30, 40, 50 years etc).  The total number of verifications varies between 4 and 11 from minimum (30 year) to maximum (100 year) project length.  

Q: Following validation how long does a landowner have to carry out restoration works?  

A: Restoration works must be carried out within 3 years from project validation.  The works must not take longer than 2 years. 

Q: Can restoration start before validation takes place?                                                                               A: Ideally not but yes if sufficient pre restoration (baseline) evidence is recorded and provided to the validator.  Starting works before validation is complete is at the risk of the project. 

Q: Who decides whether top up restoration works are required and how much? 

A: Top up restoration works are additional restoration works needed to produce the change in peatland condition required to claim the full amount of predicted peatland carbon units (PCUs) at each project verification. It is up to the landowner to assess the site to determine what top up works are required to achieve and / or maintain the desired condition category change and organise for these to be carried out ahead of verification.  An estimate of top up works can be included in the additionality calculator when designing the project.   

Q: If costs are added for ongoing restoration top up works are added but then not needed what happens to the money?  

A:  If a verifier is satisfied that a project can claim the full amount of carbon units predicted at validation without top up restoration works then the money could be kept in reserve to be spent before the next verification (if applicable).  Income associated with the sale of carbon units could be retained by the landowner but grant income tied to a particular activity may need to be returned. 

Q: What if top up works (e.g. hagg re-profiling with an excavator are no longer possible because the surrounding area has become to wet to allow access? 

A:  Issues such as this should be considered when designing the project and in the risk assessment.  If it is not possible to carry out the top up works due to issues which could be reasonably foreseen (i.e. a site become wetter due to damming) then the amount of carbon units may be reduced at verification.  However it may be possible to redesign the works (i.e. by walking onto site) or using airlifting to get around access issues. if access is an issue there may be alternatives such as walking onto site or  ....

Q.Can a site improve by two condition categories?

A. The Peatland Code initially assumes 1 step change in condition category. However, if at any future verification it becomes apparent that your site has moved another condition category, more carbon units can be issued.

Q. Which version of the Peatland Code will my project follow?

A. Project validation and verification are to the latest version of the Peatland Code. From the 1st February 2025 project submitting their information to validation and verification bodies will be against Version 2.1 of the Peatland Code.

Q.  Which version of the Field Protocol will my project follow?

A. All new projects will use the latest version of the Field protocol, unless they can evidence, they have done the Field Survey before the 1st February 2025, in which case an earlier version of the Field Protocol will be eligible. See summary document for more information. 

Q, The Peatland Code was updated during my project. Which version of the Peatland Code do I use?

A.Project Plan Validation and Restoration Validation shall happen to the same version of the Peatland Code, even if there has been a version update in between.

Q. Can the project change between Registration and Project Plan Validation? 

A. Yes this quite normal as most of the information provided at registration is a draft. Q. Can the project change between the validated Project Plan and Restoration Validation?

A.Yes, if that is the case the project developer/landowner will need to submit updated key documents to the validation and verification body for review as well as the restoration report. Q. Is there a minimum project lenght for Peatland Code projects?A. Yes the minimum project duration shall be 30 years. For projects with durations exceeding 30 years, a minimum 75% of peat depth or SOC stock survey points within all assessment units shall exceed the minimum peat depth or SOC stock needed for the project duration. See the Field Protocol for further guidance.

Q. What is needed for a Peatland Code field survey?

A. The Field Protocol outlines all survey requirements under the Peatland Code. Please note that field surveys are valid for 2 years, peat depths up to 5 years. Project will need to evidence they have done the field survey before the 1st February 2025 in order to use an earlier version of the Field protocol. See more guidance in the Peatland Code Guidance document.

Q. What should be mapped on a Peatland Code site?

A. The Field Protocol [link] outlines how to map project areas. A map should be drawn which divide the site into different assessment units. This includes actively eroding (bare peat) and drained areas. Maps can be produced from aerial imagery and checked on the ground. Include the project name, scale, a North arrow, the grid reference of the central point and the access point onto site (if this is relevant) to your map.

Q. Do I need to complete 50m x 50m grid surveys for peat depths?

A. Yes if you are validating your projects to version 2 or 2.1. Start your measurements using a 100m x 100m grid. When a measurement is less than 50 cm deep, increase the measurement frequency to a 50m x 50m grid around this shallow point until all the measurements around the shallow point(s) on the 50m x 50m grid have a peat depth of over 50 cm. At that point revert back to the 100m x 100 m grid.

Q. Do I have to move a 50m x 50m grid if a survey point has a peat depth of 50cm? 

A. No. You only need to move to a 50m x 50m grid if you record a peat depth of 49cm or below. Revert back to the 100m x 100m grid when all measurements around the shallow point are 50cm or over.

Q. Can a landowner enter into the Peatland Code without peat depth measurements? i.e. within a MOD Danger Area where ordnance checks are needed before probing the ground.

A. No, we require a peat depth assessment for all Peatland Code projects.

Q: If you are expecting to stagger different interventions over several years, how do you enter that into the Peatland Code? Do you take all of the work into account at the beginning? Can you put the same area into another PC agreement?  

A: You should take as much of the planned work into account to start with as you can but it’s not always realistically possible to know everything that will be required at the start. The 85% funding, 15% PC balance only applies to the first validation so you can look for other funding to support future works if needed. If you make the boundary of the PC area as close as possible to where the planned restoration work is being carried out, you can also potentially put areas outside of this into another PC agreement in future. 

Q. What sort of costs can be included in the additionality spreadsheet?

A. All restoration, management and maintenance costs associated with the project, Peatland Code levy fees, validator and verifier fees and ‘Other’ costs directly linked to the project such as broker fees and insurance.

 Q. How does the additionality spreadsheet account for inflation?

 A. All figures, including emissions factors, are for current records. We do not account for inflation, but if a revised additionality calculator needs to be submitted for restoration validation, we expect those numbers to be updated.

 Q. Can you explain the additionality costs that the spreadsheet calculates?

A. The calculator works out what percentage of the costs are grant funded against the percentage that relies on carbon income. A minimum 15% of the restoration, management and maintenance costs must come from carbon income

Q. Is the 5% reduction within the emissions calculator recoverable at the verification stage?

A. No, the 5% reduction is not recoverable by projects at the verification stage. This is used to ensure that the emissions calculator is conservative in its predictions and does not contribute towards overselling carbon credits. This is a separate calculation to the 20% Risk Buffer that all projects must contribute towards.

Q. What happens if the emission factors used to calculate the Peatland Code emission reductions (carbon savings) change?  

A. Verification will always happen to the latest emission factors. This is to keep to Peatland Code robust and not oversell carbon savings; some projects run for 100 years and should not be using 100-year-old emission factors.

Q: How much does a tonne of carbon sell for? 

A: Carbon prices are likely to change over time as the market develops.  Estimate (2023) of £23.95 per tonne as per the UK carbon price index .

Q: What are Pending Issuance Units (PIUs) and Peatland Carbon Units (PCUs)?  

A: A Peatland Carbon Unit (PCU) is a tonne of CO₂e emissions savings from a Peatland Code verified peatland. It has been independently verified, is guaranteed to have been achieved, and can be used to report against a business’s UK based emissions as soon as it is purchased. 

A Pending Issuance Unit (PIU) is effectively a ‘promise to deliver’ a Peatland Carbon Unit in the future. It is not ‘guaranteed’ and therefore cannot be used to report against UK based emissions until verified. However, it allows companies to plan to compensate for future UK based emissions or make credible CSR statements in support of peatland restoration. At the start of a project, all units available are PIUs as the restored peatland hasn’t yet made any emissions reductions. 

Q: What assurances are given to buyers about carbon units purchased under the peatland code?  

A: Units under the peatland code are verified according to the International Greenhouse Gas accounting standard ISO 14065.  All validation/verification bodies are appointed by the peatland code executive board and shall possess, or be working towards, accreditation by the UK National Accreditation Body (UKAS) to ISO 14064/3 and 14065. 

Q: Can a landowner buy their own carbon?  

A: Landowners will be the registered holders of carbon units generated through the peatland code.  The landowner can opt to sell the units to a buyer of their choosing or use the units to make claims against the residual emissions of their land holding or wider business interests. In the case of the latter, they will effectively buy their own carbon, and will thus have to invest at least 15% of the project costs into the restoration project.    

Q: How long can landowner hold credits before selling?  

A: Landowners can sell credits at any time during the project lifetime either as PIUs (before verification) or as PCUs.  Landowners can find a buyer themselves or use the help of the Project developer or broker to find one.  See here for a list of current project developers and brokers.   

Q: Can carbon credits be sold to a buyer and then sold again?  

A: Currently sold carbon units can only be resold by an FCA approved broker (none for Peatland code at present). However, retail aggregators can buy carbon units from a project, hold them for a couple of months, and resell them to an end user. 

Q: Can buyers make claims about emission reductions?   

A: Further details on claims (against future or past emissions) that UK based companies can make can be found in the peatland code guidance document. 

Q: Can PIUs be passed from a developer to an owner if so when / how?  

A: After validation, a project developer can transfer all or a proportion of carbon units to the landowner. The landowner will need a UK Land Carbon Registry account (project proponent). 

Q: What is the risk to a buyer of purchasing PIUs / PCUs?  

A: A buyer purchasing PIUs is taking a risk as the restoration is not guaranteed to be successful. When buying a PIU there always must be a legal contract between the buyer and the seller on who carries the risk of the unit not getting verified. The contract should also include details of any financial contributions the landowner is prepared to make towards restoration works. A buyer of PCUs does not have this risk as the emissions have already been saved. 

Q: Can project length be extended or reduced following validation and can a landowner exit a peatland code project without penalty?   

A:  The project length cannot be extended after validation as peat depth additionality, management and monitoring plans are checked against a given project length. However a landowner who does not sell all (or any) of the carbon units up front has the flexibility to exit a peatland code project without penalty once they no longer have any legal obligations to buyers of pending issuance units (PIUs). There is no legal contract between the peatland code and a landowner.   

Q: What happens if the restoration doesn't work?

A:  At verification PCUs will be issued based on areas successfully restored. If an owner has sold more credits than have been verified they may incur a penalty depending on what is agreed in the sale contract. An owner who hasn’t sold the credits and wants to claim against there own activities will have a reduced number of units available for this. If the failure is completely outside of the landowners control e.g. a wildfire, the risk buffer can be called upon.  

Q: Is there an approved list of carbon brokers available?

A: See the Support section of our website. 

Q: Will the rate of carbon rise to match other competitor carbon scheme’s, or purely market dependant? 

A: This is market dependant. 

Q: Can land entered under the Peatland Code still qualify for business relief? 

A: Yes, they can. Please see here and below for further guidance: 

HMRC are of the view that the activities necessary to create, manage and maintain the land for the purposes of generating credits for use or sale will mean any business undertaking these operations will, in general, not be mainly involved in the holding or making of investments, as required by IHTA84/S105 (3).