Four Open Questions in LSRS Implementation, and What We Think the Answers Should Be
26 March 2026
As companies begin implementing the GHG Protocol Land Sector and Removals Standard (LSRS), they face several unresolved questions on key methodological issues. These include whether dynamic baselines can be used for removals, how adjacent land should be treated, whether stratified emission factors are permitted, and how the “right-to-report” rules should be applied. These questions came out repeatedly in the Q&A of our February 11 webinar, Operationalising the GHG Protocol LSR Standard: Live Discussion, reflecting how widely practitioners are grappling with them.
The prevailing advice on all four is broadly the same: wait. Wait for official guidance on additionality for removals, adjacent land, traceability... This caution is understandable, but we think it carries its own risks: companies that adopt the most conservative interpretations today may be locking in reporting approaches they will need to revise as the standard matures, and in some cases may be systematically undercounting carbon removals in their current inventories. Below we explain where we align with prevailing interpretations and where we diverge. We do not claim definitive answers (the standard's authors and the broader practitioner community will ultimately decide) but our perspectives are grounded in deep technical expertise in carbon estimation.
This post reflects Chloris’s current interpretation of the LSRS. It is not legal or compliance advice, and we welcome discussion and pushback from others in this space.
1. Dynamic baselining: the question the LSRS doesn't answer yet
The question
Should corporate land-sector accounting adopt dynamic baselines demonstrating additionality for measuring carbon removals?
A baseline is the counterfactual against which removals are measured: what would have happened to carbon stocks in the absence of an intervention. In corporate GHG reporting, baselines have traditionally been static: carbon stocks (or rates of change) are estimated for a fixed historical reference period and then held constant for the duration of the reporting period.
Carbon markets have largely moved beyond this. Methodologies under programs such as Verra's Verified Carbon Standard require baselines to be updated at defined intervals (typically every ten years, with provisions for earlier revision if conditions change materially). The logic is straightforward: a reference scenario that drifts too far from current conditions produces credits that don't reflect real-world outcomes.
The same question now faces companies implementing the LSRS. Land systems are not static. Forests grow and recover, drought and fire reduce biomass, land-use pressures shift, and climate change alters growth trajectories. A baseline defined from conditions in 2020 may look increasingly unrealistic by 2030. And without a credible counterfactual, it becomes impossible to distinguish removals that result from a company's active mitigation efforts from those that would have occurred regardless.
The LSRS does not clearly answer this: dynamic baselining is not required but encouraged, and additionality requirements for removals are framed as a "should" rather than a "must."
Our read
Dynamic baselining, and the establishment of additionality for removals, is where land-sector accounting is heading, driven by the rigor that quality carbon markets already demand, and increasingly by the expectations of investors, customers, and other stakeholders who want assurance that a company's reported removals reflect genuine change. The same methodological standards that underpin credible carbon credits will need to apply to insetting: audiences scrutinizing corporate ESG performance are not interested in reported removals they cannot trust. Our recommendation is to adopt dynamic baselines now, wherever it is possible to establish meaningful synthetic controls, rather than waiting for formal guidance to require it.
The case is straightforward. Measurement capability has improved to the point where continuous satellite monitoring allows large-scale forest carbon baselines to be updated regularly at relatively low cost, using historical archives to establish pre-intervention trajectories. The technical barrier that historically justified static baselines is much lower today. At the same time, static baselines carry a structural risk: when a baseline is locked in, a company cannot later demonstrate that reported removals in intervention areas represent genuine change rather than business-as-usual dynamics. For example, if biomass is also increasing in non-intervention areas, not all removals in intervention areas can be claimed as additional.. Climate change compounds this problem, already altering growth rates, disturbance regimes, and land-use dynamics in ways that make stable-baseline assumptions increasingly unrealistic.
Dynamic baselines built using synthetic controls (counterfactual trajectories constructed from satellite time series of comparable, unmanaged landscapes) represent best practice where they can be established. This approach allows companies to track carbon stock changes year over year and distinguish removals attributable to active interventions from pre-existing or background trends, directly addressing the additionality question.
Dynamic baselines raise legitimate design questions: how to design representative synthetic controls for interventions, how often to update them and how to avoid discontinuities in reported performance. These are solvable problems, but they require clearer guidance than the LSRS currently provides. Future GHG Protocol guidance, and potentially SBTi FLAG requirements, will likely address additionality for removals more directly, and companies that have already adopted dynamic approaches will be better positioned when that happens.
Where synthetic controls cannot yet be meaningfully established, companies should at minimum maintain the data infrastructure needed to support future baseline updates: consistent time-series observations, stable methodologies, and well-documented reference periods. Locking into a static baseline while discarding underlying monitoring data would be a mistake.
Chloris's annual above-ground biomass (AGB) time series are designed with this in mind. Built from consistent satellite imagery and calibration protocols, they preserve a continuous observational record, allowing any year in the series to serve as a defensible reference point if baselines are updated in the future.
1.Box 17.1 Recommendations on net targets to programs, regulators, and companies not participating in target-setting programs, pp.99, Land Sector And Removals Standard
2. Adjacent land: can companies count it now?
The question
The LSRS includes provisions for land adjacent to, or closely connected with, a company's sourcing operations, the so-called near-value-chain mitigation. Can companies already count removals from adjacent land in their GHG inventories, or must they wait for further guidance? And how should expressions like "connection to productive agricultural lands" and "single land management plan" be interpreted?
Our read
The short answer is: the framework exists, and companies that can demonstrate active management of adjacent land are on solid ground. Our view is set out below (however, there are competing interpretations held by a share of practitioners).
The LSRS does not prohibit companies from reporting emissions or removals on adjacent or connected land. Instead, it requires that the land in question falls within the same management system as the land generating sourcing-related emissions. In this context, “management” is interpreted broadly enough to include conservation buffers, restoration commitments, and landscape-level programs, provided the company has a documentable role in them.
One open question is whether this extends to non-contiguous parcels under different ownership but shared governance: the standard’s own examples appear to contemplate single-ownership situations, and several practitioners have read “single land management plan” restrictively as a result. Our read is that functional connection can satisfy the criterion even without unified ownership: a landscape compact, a shared conservation commitment, or a jurisdiction-wide programme can plausibly qualify if the company’s role is documented and verifiable, but this interpretation will need to be tested against future guidance.
Crucially, this connection cannot be purely nominal. A company listing a third-party project in its sustainability report without a contractual relationship or direct influence over land-use decisions would fail the standard. The distinguishing factor is whether the company’s actions materially shape what happens on that land, not just that it funds something nearby.
Because "connection to productive agricultural lands" and "single land management plan" are not yet defined with precision, companies should apply a three-part functional test:
Is there a documented management plan covering both the sourcing land and the adjacent area?
Does the company have a direct contractual or operational relationship with whoever manages that adjacent land?
Is the carbon flux on the adjacent land measured independently, rather than being inferred from other parcels?
If the answer to all three is yes, including adjacent removals or emissions in the primary inventory is supportable under our reading of the standard, though companies should be aware that the restrictive interpretation exists. In either case, the underlying measurement quality, not just the proximity of the land, is what determines whether the claim holds up to scrutiny.
Chloris's satellite-based AGB mapping can delineate and quantify carbon stocks at the parcel level, making it feasible to treat adjacent land as a distinct monitoring unit even when physical boundaries are informal.
2.REQUIREMENT 7: Interim requirement on proximate and adjacent non-productive lands within LMUs for scope 3 LMU-level accounting, pp.25-27, Land Sector And Removals Standard
3. Stratified emission factors: what's allowed inside the GHG inventory?
The question
A company funds interventions (better land management practices, agroforestry introduction, cover cropping) on a subset of farms in a broader sourcing region. How should it account for those impacts? Can it use stratified emission factors (one rate for intervention farms, another for the rest), or must it report a single averaged factor across the whole supply shed?
Our read
The prevailing practitioner interpretation is that stratified factors are not permissible within the physical inventory unless a company has farm-level traceability and is able to “segregate” the exact commodities produced in those farms from the rest. The logic is that emission factors must reflect what a company can actually substantiate about its supply chain: if a company can only trace its sourcing to the first point of aggregation (a mill, trader, or cooperative) it has no basis for assigning a different emission factor to a subset of farms it cannot individually identify. In that case, averaging across the supply shed is not a concession but the most honest representation of what is known.
Our reading is more permissive, and the distinction that matters is between physical segregation and traceability. These are not the same thing: a company does not need to physically separate volumes from intervention farms to have traceability to those farms. Consider a palm oil buyer sourcing from a region under an RSPO certification scheme or a landscape initiative: even if certified and uncertified volumes are commingled in the supply chain, the company knows the proportion of its sourcing that comes from certified farms and what practices apply there. That mass balance is sufficient to stratify land-use change emissions accordingly (for example applying a separate, specific, LUC emission factor to the certified share, based on the average LUC emissions of the certified farm, and a different one to the remainder, based on the average of the rest of the production areas) without requiring physical segregation of product flows. The same logic applies to direct supplier programmes or other landscape initiatives where farm-level participation is documented even if the commodity itself is not traceable through to the end buyer.
More broadly, we think stratified emission factors should be permissible in physical inventories wherever three conditions are met: there is strong traceability or control over which farms or suppliers are involved; the boundary between intervention and non-intervention parcels is clearly and auditably defined; and there are adequate controls to prevent double-counting or over-claiming. Where those conditions hold, forcing companies back to a sourcing-region average is not conservative: it is inaccurate, and it actively penalises companies that have invested in supply chain transparency and landscape intervention.
Sourcing-region averages should be the fallback for situations where traceability genuinely breaks down: where a company knows only its first aggregator or supply shed and has no credible basis for distinguishing strata. They should not be the default for everyone: where that farm-level traceability exists, stratified factors can reasonably be used inside the physical inventory. The basis for doing so is that the stratification reflects a real, observable difference in land management.
Chloris's long time-series satellite data at 30m resolution, and the ability to derive nested dLUC estimates spanning from individual farm to full supply shed, provides the spatial and temporal foundation that makes stratified emission factors defensible in an audit context.
3. CHAPTER 5: Spatial boundaries and traceability, pp.22-30, Land Sector And Removals Standard
4. Right to report: how should it work in practice?
The question
The LSRS establishes a voluntary right-to-report mechanism that allows companies to claim reductions or removals from land they don't own or directly operate. But what makes such a claim legitimate? Is direct landowner consent sufficient? Are supplier contracts enough?
Our read
The right-to-report question is fundamentally about avoiding double-counting and ensuring that claimed benefits are real. Our view is that the mechanism must satisfy three criteria regardless of the legal form it takes:
Exclusivity: the claim must be made by only one entity. If a farmer grants rights to a company and also sells a carbon credit for the same ton to another buyer, the company's claim is invalidated.
Traceability: there must be a documented chain linking the claimed outcome to a specific piece of land and a specific intervention or land use change, not just a regional estimate.
Verification: the underlying data must be independently verified, not self-reported by the claimant.
In practice, we think the most robust mechanism is a direct bilateral agreement between the company and the landowner or farm operator, specifying which land, which monitoring methodology, and who holds the right to report. Supplier contracts can work if they include these specifics, but boilerplate sustainability clauses in procurement agreements almost certainly don't.
Inset credits from intermediaries are a more complex case. A well-structured inset credit that transfers the right to report alongside the carbon unit is conceptually equivalent to a bilateral agreement. But the market is immature, and many credits on the market today do not transfer a clearly exclusive right. Buyers should be cautious.
One implication for Chloris clients: the monitoring layer needs to be agreed before the right-to-report agreement is signed, not retrofitted afterward. Carbon claims require a measurement baseline, and baselines require data. For removals specifically, this is where Chloris's 10m resolution AGB mapping becomes directly relevant: distinguishing genuine removals at the farm or parcel level, rather than inferring them from landscape-wide averages, requires the spatial resolution to separate intervention from non-intervention areas and track stock changes over time.
4.13.3 Recommendations and options, “Right to report”, pp.77, Land Sector And Removals Standard
How we approach these questions
Through ongoing discussions, practitioners are beginning to align on interpretations of the standard - often in ways that are more stringent than companies might prefer. On issues like adjacent land and stratified emission factors, the dominant interpretation is generally conservative. In some cases, our approach is more permissive, reflecting considered interpretations rather than settled positions.
In the coming months, companies should prioritize aligning around interpretive positions that better reflect and enable on-the-ground mitigation efforts, and translate that alignment into coordinated reporting approaches, while identifying where rules are genuinely missing and where the GHG Protocol standards could fill gaps.
Our focus is on providing the data infrastructure that makes better interpretations operational: remote sensing at scale does not resolve every LSRS ambiguity, but it changes which interpretations are practically defensible: farm-level AGB time series make stratified emission factors operational, and parcel-level monitoring allows verification of right-to-report agreements. In other words, better measurement infrastructure gives companies the tools to support interpretations that recognize real on-the-ground mitigation outcomes and to implement them consistently in reporting.
If you're working through any of these questions for a specific sourcing landscape, whether that's deciding how to structure a baseline, assessing whether adjacent land qualifies for inclusion, or evaluating a supplier programme's eligibility for stratified factors, we're happy to think through the specifics with you. These are genuinely complex interpretive questions, and the right answer often depends on the details of how your supply chain is structured and what data you already have.