EU LULUCF Registry 2026: what changes for the forestry sector

Key data

Companies in the forestry and agricultural sector participating in European carbon offset mechanisms must review their position regarding the Union Registry. The Delegated Regulation (EU) 2026/81, published on 7 April 2026 in the EU Official Journal, amends Delegated Regulation 2019/1122 to adapt it to the requirements of Regulation 2018/841, which regulates Member States' obligations regarding emissions and removals in the land use, land-use change and forestry (LULUCF) sector.

The Union Registry is the central electronic platform where accounts are managed that record CO2 emissions and removals from this sector. Any operator with active accounts in this registry linked to forest or soil credits must be aware of this change.

What does this regulation establish?

The regulation updates the operational functioning of the Union Registry to align it with the obligations established in Regulation (EU) 2018/841. This legal framework requires Member States to ensure that emissions from the LULUCF sector do not exceed removals, meaning the sector acts as a net carbon sink.

The amendment to Delegated Regulation 2019/1122 affects the internal mechanics of the registry: how accounts are managed, how forest and soil credits are recorded, and how Member States' compliance is reflected in the electronic platform.

Economic and operational impact

The direct impact of this regulation is not a new fee or specific economic penalty published in the regulation. The impact is operational and compliance-related: entities operating accounts in the Union Registry must ensure their operations align with the updated functioning of the registry.

For companies in the forestry or agricultural sector participating in European carbon offset mechanisms, the practical implications are:

• Possible changes in how CO2 removal credits generated by their forestry or agricultural activities are recorded and accounted for.
• Need to verify that active accounts in the Union Registry remain operational and correctly configured under the new operating rules.
• Review of internal processes for reporting and monitoring emissions and removals to ensure consistency with the updated registry.
• Coordination with national registry administrators, who are the direct contacts for any account management matters.

For national administrators, the change involves adapting the technical and administrative procedures of the registry to the new specifications of the delegated regulation.

Who does it affect?

This regulation directly and indirectly affects the following profiles:

• National administrations responsible for managing the Union Registry in each Member State.
• Union Registry managers at the technical and operational level.
• Forestry sector companies that operate accounts in the registry linked to CO2 removal credits from forestry activity.
• Agricultural sector companies participating in European carbon offset mechanisms through land use accounts.
• Sustainability advisors and consultants managing their clients' participation in European carbon markets.
• CFOs and operations directors of companies with forest or agricultural assets that generate carbon credits under the LULUCF framework.

Practical example

A Spanish timber company managing a certified forest and that has registered its CO2 removals in the Union Registry as part of a European carbon offset mechanism must, following the entry into force of Delegated Regulation 2026/81 on 20 February 2026:

1. Contact the national administrator of the Union Registry in Spain to confirm that its forest credit accounts remain operational under the new operating rules of the registry.
2. Review whether its internal procedures for reporting CO2 removals from its forest are consistent with the updated requirements of Delegated Regulation 2019/1122, now amended.
3. Verify that forest credits already registered do not require any corrective action resulting from the change in registry mechanics.

This same process applies to an agricultural cooperative that has registered carbon removals from sustainable soil management practices under the framework of Regulation 2018/841.

What should companies do now?

1. Identify whether your company operates accounts in the Union Registry linked to forest or land use credits. If you do not have active accounts, this regulation does not generate direct immediate obligations for your operations.
2. Contact the national registry administrator to obtain information about the technical changes applied to the registry's functioning and their impact on active accounts.
3. Review internal processes for reporting CO2 emissions and removals to ensure consistency with the updated Delegated Regulation 2019/1122 and Regulation 2018/841.
4. Consult with advisors specialized in carbon markets if your company actively participates in European carbon offset mechanisms, to assess the concrete operational impact of the change.
5. Monitor future updates to the LULUCF framework, given that Regulation 2018/841 continues to be subject to regulatory development at the European level.