Does Verra require us to follow laws that nobody enforces?
Yes. VCS Standard v5.0 says the project and its activities must not lead to the violation of any national, state, local or other applicable law, whether or not the law is enforced. Where laws conflict, the more restrictive one prevails. This is separate from the regulatory surplus test.
The rule
Section 3.1.6 of VCS Standard v5.0 asks project proponents to conduct themselves lawfully at all times and to make sure the project and its activities do not lead to the violation of any national, state or provincial, local or municipal, or other applicable law, regardless of whether the law is enforced. Where laws conflict, the more restrictive requirement prevails.
Two different tests
- Regulatory surplus asks whether a law already requires the activity, and only systematically enforced laws count there.
- This rule asks whether the project breaks any law, and it counts every law, enforced or not.
- The baseline scenario must also take government policies and legal requirements relevant to the project activity into account.
What to have on file
- The consents, licences and permissions the plant and the project activity need, with their dates.
- Anything the project adds that those documents do not cover, such as a new boiler, a new discharge point or a new storage area.
- A note of any place where two rules disagree, and which is the stricter.
A caution
This page explains what the standard says. It is not legal advice. Which laws apply to your plant is for your lawyer or consultant to confirm.
What Senseible does here
Senseible does not check legal compliance or permits. It keeps dated invoices and bills, so the fuel, power and production trail behind a project is easy to show.
Sources: Verra, VCS Standard v5.0 (16 December 2025), Sections 3.1.6 and 3.12.4
Last reviewed 2026-11-04. Section numbers are from VCS Standard v5.0 (16 December 2025); re-check them when Verra publishes a new version.