P01 — Verifiability by Design
SCD-P01 · Principle 1 of 10
Verifiability by Design
“If it cannot be checked, it does not count.”
Technical Layer
Definition
Every metric in a climate claim must be independently verifiable by any third party — including AI agents — without requiring permission, credentials, or manual intervention from the originating organisation. Verification must be possible from the primary source data alone.
Rationale
The EU Green Claims Directive (2024/825, enforcement September 2026) bans environmental claims that cannot be substantiated with publicly accessible evidence. AI audit tools already scan public data continuously; unverifiable claims are either invisible or automatically flagged as greenwashing. In 2026, verifiability is not a differentiator — it is the minimum floor for market credibility.
Implementation Steps
- Map every reported metric to its primary data source (satellite, government dataset, sensor).
- Ensure the source is publicly accessible without authentication.
- Document the verification pathway: source → method → aggregation → reported figure.
- Test: ask an independent analyst to verify your top 5 climate claims using only public data.
- Resolve any metric that cannot be independently verified before publication.
Compliance Checklist
| Criterion | What it means | |
|---|---|---|
| ☐ | Metric-to-source mapping exists | Every reported figure has a documented primary source. |
| ☐ | Sources are publicly accessible | No login or permission required to access primary sources. |
| ☐ | Verification pathway documented | Steps to reproduce any metric from scratch are written down. |
| ☐ | AI scan performed | Climate TRACE / GFW / EDGAR check confirms the org is findable. |
Regulatory References
- EU Directive 2024/825 (Green Claims / EmpCo) — Art. 5, 6
- IPCC AR6 Working Group III — Chapter 2 (Emissions Methodologies)
- ISSB IFRS S2 — Para. 63 (Disclosure verification)
Recommended Tools and Platforms
Climate TRACE Global Forest Watch EDGAR (EU JRC) Copernicus / ESA
Keywords
verifiability greenwashing EU Green Claims Directive AI audit ESG verification