Carbon inclusion data is a key driver for the implementation of carbon inclusion practices under the “dual carbon” goals. It is generated by carbon inclusion platforms through collecting and processing massive and multi-source information on individuals’ low-carbon behaviors. It not only constitutes a production factor held by platforms, but also represents the carbon reduction benefits obtained by individuals. Currently, during the generation and utilization of carbon inclusion data, there exist multiple risks, including data privacy intrusions, data misuse, and impeded circulation of carbon reduction benefits. These issues have given rise to uncertainties such as undefined boundaries for the collection of personal low-carbon behavior information, unclear attribution of rights and interests in carbon inclusion data, and divergent understandings of the nature of user-side carbon reduction benefits. These challenges severely constrain the effective operation and standardized development of carbon inclusion programs. Accordingly, it is necessary to establish a systematic analytical framework for data-related risks. With respect to the generation process of carbon inclusion data, the personal low-carbon behavior information collected by platforms constitutes personal information and may involve certain private information. Differentiated information collection rules are therefore required: platforms collecting general personal information must obtain users’ general authorization, whereas for areas involving private information, no intrusion shall be permitted unless special authorization in the form of “explicit consent of the right holder” is obtained. Regarding the attribution of rights and interests in carbon inclusion data, it is inappropriate to simply adopt the behavioral regulation approach or the traditional property rights regulatory path. Instead, it should be recognized that carbon inclusion data features a dual structure of rights and interests: individuals who provide the underlying data enjoy the prior rights of data source persons, while platforms that process the data hold the property rights of data processors. When exercising their data property rights, platforms must not only respect users’ prior rights but also comply with the public-interest purpose of carbon inclusion. As for the economic value of individual carbon reduction benefits in contexts such as redeeming goods or services, participating in transactions, and substituting for ecological and environmental damage restoration responsibilities, these benefits should not be viewed merely as public welfare incentives. Rather, carbon reduction benefits should be regarded as an institutional commodity, possessing both use value guaranteed by the institutional framework and exchange value formed in the market.