Methodology

We conduct seventy-nine interviews with participants in the early CDR market, including investors, suppliers and purchasers, to provide that much-needed context. The interviewees (complete list in the appendix) were identified by consulting public announcements of corporations, as well as relevant registries of ecosystem actors, such as accelerators, incubators and online communities. The interviews were conducted starting in July 2023 and concluded in September 2024. The geographical distribution of the participants is concentrated in regions that can be described as “Global North” countries. We acknowledge that this presents a limitation in the perspectives reflected in this study. The share of different stakeholders in the pool of participants is slightly skewed towards CDR suppliers, with them representing around 45% of the interviews conducted. Given their roles with a commercial interest in the CDR sector, the participants should not be seen as neutral or academic experts, especially not on justice and equity. They should be regarded as representatives who might argue for measures supporting their respective roles. In the recruitment, we did not screen the participants for prior involvement with the oil and gas sector.

During the semi-structured interviews, the participants were asked about their views on “principles and components of fair and equitable CDR systems” as a concluding question for the interview. The answers to this question and its follow-up questions are subject to this paper. Other questions that were part of the interviews alluded to areas such as risk perceptions, general challenges, hurdles and motivations. These latter questions are covered in another publication separate from this paper.Footnote ¹⁴ The interviews had a maximum duration of 48 minutes and were conducted using Google Meets.Footnote ¹⁵ Subsequently, they were transcribed and anonymised using Condens.Footnote ¹⁶

The interviewees’ answers go beyond the initial scope of the question as outlined above. The answers tend to address governance principles more generally from the perspectives of market participants. We conducted our analysis as follows: First, we examine overarching elements of the interviewees’ perspectives to inductively construct a baseline on their perspectives by inductive coding. Then, we cluster these elements along the CDR policy instrument assessment framework by Holland-Cunz and Baatz (2025).Footnote ¹⁷ In this setting, we also describe how different actors weigh the framework elements as a function of how frequently they mention the topic. We use example statements extracted from the interviews to illustrate the positions of individual stakeholders. We stress that these statements are used for illustrative purposes only and shall not be seen as representative of the breadth of perspectives brought forward by the participants. Second, we examine the interviewed actors’ apparent differences and conflicting opinions. These results are situated in the relevant contemporary governance discussions surrounding CDR specifically and climate ethics and justice topics more generally.

Actor perspectives on the governance of CDR systems

Holland-Cunz & Baatz (2025) propose a framework for assessing policy instruments governing CDR. Fifteen criteria define standards for governing CDR (see Figure 1). They are structured around six dimensions of interest that are derived from the fundamental questions of what makes a CDR policy feasible (what can be done) and desirable (what should be done according to specific shared values):

1. A. Feasibility: How feasible is the process of formulating, adopting, implementing, evaluating, and refining a policy instrument?

2. B. Procedural Fairness: How fair is the process of formulating, adopting, implementing, evaluating, and refining a policy instrument?

3. C. Climate Effectiveness: How effective is a policy instrument in terms of its intended climate impact?

4. D. Impacts on Individuals and Society: How does a policy instrument impact individuals and society beyond its intended climate effect?

5. E. Impacts on Non-Human Entities: How does a policy instrument impact non-human entities beyond its intended climate effect?

6. F. Ratio & Distribution of Impacts: What is the ratio of inputs (resources) and outputs (impacts) of a policy instrument, and is the distribution equitable?

Figure 1. Framework for assessing CDR policy instruments, reproduced from Holland-Cunz and Baatz (2025).

What makes this framework particularly suitable for the following analysis of the interviews is that it is currently the only assessment framework for the particular topic of “CDR policy instruments,” which is closely connected to CDR governance. There are, of course, other frameworks for assessing CDR optionsFootnote ¹⁸ or climate policies in general.Footnote ¹⁹ However, assessment frameworks for climate policies in general are unhelpfully broad for the analysis undertaken in this paper. And assessment frameworks for CDR options, but crucially not CDR policy instruments, contain elements that are unhelpful when assessing the latter or lack policy instrument-specific elements. For example, assessment frameworks for CDR options usually include criteria on the technological feasibility of CDR options (e.g. Baatz et al. 2025). While technological features are relevant for the feasibility assessment of CDR options it doesn’t make sense for the feasibility assessment of policy instruments like taxes, regulations or subsidies. Their feasibility, however, depends, among others, on administrative resources that may not be as relevant for the assessment of CDR options. By applying the Holland-Cunz & Baatz (2025) framework we do not deny that this framework overlaps in some aspects with other frameworks within the discussion or that other frameworks could also be employed to analyse the interviews featured in this paper. We do think, however, that because of its specificity the Holland-Cunz & Baatz (2025) framework is the most suitable one for this task.

What also makes the framework particularly valuable for analysis is that it explicitly highlights the value judgments that underlie our ideas about the desirabilityFootnote ²⁰ of CDR. Analysing the interviews against the theoretical background in the form of the assessment framework can serve the following purposes. First, it enhances the analysis of the interviews by using the framework to structure statements according to the values that the interviewees explicitly or implicitly mentioned. Structuring the statements in this way makes it possible to identify which values regarding CDR governance are widely shared, which are highly controversial, or which may not be relevant enough to be mentioned, and where linkages, synergies and trade-offs between dimensions may arise. Secondly, the interviews serve as an iterative reality test of the framework, where dimensions and criteria can be tested for relevance and comprehensiveness. Moreover, practitioners’ insights into which criteria and dimensions are considered more relevant can contribute to future research on trade-offs between them. Given the framework’s novelty, it has yet to undergo practical application or critical examination. Its potential limitations stem from its development being rooted exclusively in German and European contexts, which may limit its broader applicability.

Additionally, the framework lacks established methods for aggregating its criteria, posing challenges for systematic implementation and evaluation. This also makes the application of the framework to the qualitative interviews at hand challenging. Despite these limitations, it can serve as a helpful tool to categorise and interpret the practitioners’ perspectives, mainly because it is especially suited to categorise statements on issues beyond feasibility, particularly fairness and equity.

For the analysis, we cluster the views/statements of the actors as outlined below. We rate the level of focus the actor group assigns to the individual dimension in question as “low” (grey), “mid” (light blue), or “high” (dark blue), depending on the distribution of thematic codes of that actor. For example, more than 60% of purchasers refer to lean and efficient processes and third-party methodological enforcement. At the same time, only 11% of interviewees mention climate justice and equity considerations. As a result, we rate the former as “high” and the latter as “low.” This is not to say that the latter dimension is of no interest to the interviewee. Instead, it indicates what is on their mind regarding CDR governance. Further, we stress that individual statements of participants can be challenging to classify. For example, a statement like: “We care about co-benefits for biodiversity” might aim to enhance biodiversity for agricultural productivity, for the sake of flora and fauna, or both. In our analysis, we classify the interviewees’ responses to the best of our knowledge using the context in which they are mentioned.

The results (Table 1) reveal distinct perspectives across suppliers, purchasers and investors in the early CDR market, highlighting areas of alignment and divergence. Across the board, the involved actors stress the importance and need for strong third-party regulation and governance. This includes mandated incentives for private organisations to be involved with CDR:

Table 1. Thematic cluster of CDR governance topics according to the framework mentioned above. The relative importance of elements colour-coded as low (grey), mid (light blue), and high (dark blue).

One of the main reasons for this need for governance is climate effectiveness, the most commonly referred topic. All actors care about a governance system for CDR that ensures proper monitoring, reporting and verification (MRV) of the climate mitigation effects of CDR methods. Two considerations link climate effectiveness to issues of fairness and equity. First, climate effectiveness considers not only how much CO2 is removed after CDR options are implemented, but also how quickly the options are scaled up (criterion 9). Scaling up CDR options too quickly may conflict with equity requirements. We discuss this point in section 3. Second, when we looked at the statements from the interviews that are systematised under climate effectiveness, terms such as “rely” or “trust infrastructure” point to another dimension, namely procedural fairness. An instrumental value of procedural fairness lies in strengthening societal support for the CDR governance in question. Relying on and trusting in the climate effectiveness of a CDR governance is only possible if the traceability and verification of CDR efforts are procedurally fair, i.e., in a transparent and inclusive way with widely available information.

Interestingly, interviewees didn’t bring up the concern about mitigation deterrence/moral hazard, at least not explicitly. The criterion of “climate effectiveness” in the Holland-Cunz & Baatz (2025) framework takes into account the overall climate impact of a governance system, inducing that a governance system that leads to more mitigation deterrence is less climate effective. The theoretical tool chosen for our analysis thus has the capacity to recognize statements about mitigation deterrence/moral hazard. The interviewees simply did not raise this topic.Footnote ²¹

Further, interviewed suppliers heavily emphasise the importance of positive impacts on local communities and individuals, with purchasers following suit. This emphasis also seeps into the distribution of positive and negative effects. Across all actor groups, ensuring a proper distribution of burdens and benefits is a priority. All actors see this as an underpinning of the acceptance of CDR methods. Suppliers allude to climate justice ideas and polluter-pays-principles. Purchasers and investors talk about this in the scope of global carbon markets. Specifically, they discuss the importance of adequate burden sharing across industrialised and developing countries. Outside of the immediate framework at hand, many participants stress the element of transparency about the characteristics of a CDR verification system rather than a transparent process of enacting the governance system. They also focus on the governance structures and processes of the CDR market that will emerge rather than the overarching governance system.

Pragmatism for speed and scale vs. normative ideas and public support

There are diverging opinions regarding the tradeoff between pragmatism in speed and scale as opposed to normative ideas about CDR governance. These tradeoffs reveal the challenge of creating governance structures that accommodate the urgency of scaling CDR solutions and the demand for ethically grounded systems. On the one hand, we see latent needs for, and prioritisation of integration, usage of existing infrastructure, and commodification. On the other hand, we recognise normative ideas that strongly emphasise due processes, equity, and fairness. The issue is that the rapid development of CDR governance sometimes fails to meet the demands of equity and fairness. In contrast, implementing fair CDR governance takes time, which is a problem of fairness relative to the victims of delayed action. Simon Caney (2015)Footnote ²² uses the distinction between “burden-sharing justice” and “harm-avoidance justice” to describe the occasionally conflicting demands of climate justice: equitable burden distribution and avoidance of unfairly delayed action need not always go together.

In our interviews, we experience some purchasers and investors who are advocating for integration and reliance on existing infrastructure to streamline scalability, with traceability and verification as foundational to a functional market. For many participants, this goes hand in hand with the call for the commodification of CDR. On the other hand, we have representatives of the same actor group strongly encouraging the inclusion of co-benefits, sometimes citing them as their primary area of inquisition when purchasing credits. For them, social justice and giving back to underserved communities are at the forefront of their evaluation and selection criteria, with a strong focus on co-benefits, such as soil enhancement or community uplift.

Commodification could potentially yield higher development speed and adoption rates. It might trigger new waves of needed capital to bridge the massive gap in financing the first-of-a-kind (FOAK) plants and help reach commercial scale in production facilities. The effects of commodification of carbon emissions have been viewed critically, though, for example, in forestry projects, where commodification is said to have failed to create livelihood co-benefits and other forms of sustainable development (e.g., reducing emissions from deforestation and forest degradation in developing countries. (REDD)).Footnote ²³ For CDR as a potential ingredient for a just transition, Nawaz et al. (2024) recently argued that commodified carbon markets might not allow for prioritising climate justice elements. We see this trade-off as a potential field for much tension as the build-out of CDR continues to accelerate:

Another issue that is closely related to the previous one is the inclusion of the oil and gas sector. While leveraging their infrastructure and capital might be crucial to accelerate CDR implementation,Footnote ²⁴ scholars argue that this risks undermining justice in the CDR system and reinforcing existing inequalities.Footnote ²⁵ Across all actor groups, participants emphasised the importance of addressing this conflict and meaningfully incorporating climate justice. In the eyes of this study’s participants, failing to address this inherent climate justice conundrum will lead to a loss of trust in the integrity of the CDR sector. This integrity is seen as the bedrock for a functioning CDR sector.

Adequately governing this interplay so as not to lose integrity and thus, public support is seen as one of the key tasks of a given governance system. As a prerequisite, they see an independent governance system and not under the influence of the oil and gas sector. Our participants’ perspectives on governing concepts frequently express the need to make polluters pay. Here, the participants allude to the responsibility of countries and companies, accounting for the historical responsibility and context of the accumulated emissions.Footnote ²⁶

When touching on potential mechanisms for this to occur, participants again incorporate the idea of CO2 as a tradeable commodity, illustrating the complexity of this discussion:

Concluding remarks

According to global climate change mitigation goals, the volumes of CDR will need to increase significantly over the following decades. The governance of such a CDR system will pose a formidable challenge. Private organisations already actively engaging with this nascent sector are starting to influence the development of such governance. This study gives a glimpse into their perspectives, showing both commonalities and areas of tension.

Despite their varied perspectives, all actors converge on the necessity for robust governance systems characterised by vigorous third-party enforcement, transparency and accountability. These foundational elements are critical to ensuring the climate effectiveness of CDR. Key tensions emerge in the trade-off between the urgency to scale CDR solutions rapidly and the need for equitable, justice-centred governance frameworks. This juxtaposition reflects broader debates in climate justice, including the distinction between burden-sharing and harm-avoidance justice. While rapid commodification and integration with existing infrastructure may accelerate sectoral development, these approaches risk undermining equity, reinforcing historical injustices and compromising public trust. Conversely, though slower, embedding climate justice principles and co-benefits into governance structures strengthens the sector’s societal legitimacy. The oxymoron of the involvement of the oil and gas sector underscores this tension. Participants overwhelmingly stress that a successful governance system hinges on its independence. Such a system must navigate these tensions, for example, by prioritising a Polluter Pays Principle and addressing historical emissions. Otherwise, participants see the looming threat of losing public trust in the CDR sector, which ultimately undermines its feasibility.

Moving forward, the scientific community must actively steer these discussions surrounding and enactment of CDR governance. Scholars must also know market participants’ evolving priorities and challenges for this. Reconciling these apparent tensions and trade-offs will be neither straightforward nor swift. However, it is imperative to address these issues to build a credible and effective CDR market. As the sector evolves, its long-term success depends on its ability to balance pragmatic development needs with meaningful commitments to fairness and equity – ensuring that CDR contributes to climate mitigation and a just transition.