In cases where governments are unable or unwilling to engage the private sector to reduce their emissions, non-governmental actors have stepped in to fill this governance gap. While the global environmental governance literature has produced a breadth of studies focused explaining the emergence of these actors, we still know relatively little about the internal dynamics of these organizations, their interactions with the state, as well as the environmental outcomes that they produce. In particular, it remains unclear why scaling non-governmental carbon registries remains so difficult, and why scaling does not happen uniformly across different contexts. Drawing on an in-depth case study of Green Economy Canada, a non-governmental carbon registry operating nationally across Canada, I argue that non-governmental carbon registries face scaling pressures that arise from successful normative entrenchment. I argue that the relationship between the state (and its policies), and non-governmental organizations is the most significant determinate of the organization’s ability to overcome these scaling pressures. The state is still at the heart of private actor governance.

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