UNFCCC · Article 6.4 / PACMSubmitted
The Article 6.4 Rulebook: opening the mechanism to Africa's pipeline
The Methodological Expert Panel released draft methodologies operationalising the Programme of Activities framework — plus the mechanism's first sampling and reversal-risk tools. It opens the door to the small, bundled projects that make up most of Africa's pipeline, paired with stricter rules requiring adjustment.
Why it matters
As drafted, risk is priced by geography and eligibility by infrastructure: reversal-risk deductions can differ between countries on governance proxies rather than demonstrated risk, and projects can fall out of scope because complete national data systems do not yet exist.
What we proposed
- Evidence-based reversal-risk calibration: human-induced risk values should be uniform across jurisdictions unless a clear causal link between a country-specific factor and actual reversal is demonstrated — governance or political-risk proxies should not, on their own, differentiate deductions between countries.
- Workable leakage data routes: a conservative default leakage value projects can apply where country-specific data or complete national forest-monitoring systems don't yet exist — set low enough to keep the incentive to upgrade, so no project is ineligible solely because national systems are not yet in place.
VCM+ Collaborative
ISO · Net Zero Standard (ISO 14060)Brief circulated
The ISO Net Zero Standard: what is at stake for Africa
ISO's first full standard defining what a credible corporate net-zero claim requires — reduction targets, removals, carbon credits and climate finance. Expected in 2027, it is likely to be the global benchmark for a decade, making it decisive for African credit suppliers.
Why it matters
The draft's design choices decide which African credits buyers may use, whether finance obligations create revenue for African mitigation and adaptation, and to what extent commodity certificates carry demand-side value.
What we did and proposed
- Reviewed the Draft International Standard through the lens of what matters most for Africa, and published a stakeholder brief with clause-by-clause positions and ready-to-use comment language for national submissions.
- Defend the hard-won provisions: a binding corporate climate-finance obligation, nature-based removals recognised throughout, reduction credits usable for excess emissions, accessible entry points for startups, and differentiated net-zero timelines for emerging economies.
- Fix what would exclude Africa: give environmental commodity certificates real weight — removing the same-region restriction and recognising their use towards net-zero targets, guarded by rules on integrity — and replace the rigid two-year credit-retirement cut-off with quality criteria applied at retirement.
- Supported stakeholders to engage through national standards bodies, and encouraged coordination of a consolidated African position through regional and national channels.
VCM+ CollaborativeNCSARethinking RemovalsWest African AllianceEastern Africa Alliance
GHG Protocol · Actions & Market InstrumentsSubmitted
GHG Protocol AMI Standard: making market instruments work for EMDE suppliers
The GHG Protocol is developing a new standard for how companies account for climate actions and market instruments, proposing a multi-statement reporting structure — a physical inventory, a market-based inventory, an impact statement, and non-GHG indicators.
Why it matters
Eligibility and traceability choices made are not neutral: they determine which sectors and geographies can supply qualifying instruments. African producers of low-emission commodities stand to gain — or to be nominally in scope but practically excluded.
What we proposed
- Strong support for the multi-statement structure, including the market-based inventory and a legitimate, transparent home for consequential accounting.
- Chain-of-custody rules designed for real contexts — recognising book-and-claim and mass-balance models for agricultural commodity certificates where strict physical traceability would create disproportionate barriers.
- Cost of compliance treated as a design criterion alongside integrity, so smaller and lower-resourced producers are not excluded regardless of the quality of their climate action.
- Representation in the technical working group from project developers and organisations across geographies — grounded in African cases such as smallholder commodity programmes and low-carbon cement production.
VCM+ Collaborative
Convening · London Climate Action WeekConvened
LCAW: from diagnosis to action on carbon market participation
At London Climate Action Week we designed and convened a joint working session on the current market architecture and how it shapes participation — who shapes the market, what shapes what's investable, and what development really costs in practice.
Why it matters
Most African developers sit in the gap between project viability and market access: technically capable, verified and listed — yet unable to reach buyers at scale. Access to the process is not the same as agency over outcomes.
What the session delivered
- A shared diagnostic — the “participation gap” — mapping actors from the structurally excluded to those in the pipeline but out of the market, and where the system fails each.
- An examination of the structural asymmetry in rule-setting: who designs the rules that govern carbon markets, and who is expected to adapt to them.
- Grounding in real project economics: pricing, risk allocation, revenue certainty and capital access as they present to developers and investors today.
- A closing working agreement: a set of actor-specific actions, each with a named owner and a credible pathway for follow-up beyond LCAW — not a communiqué.
HightideVCM+ CollaborativeVCMIRethinking RemovalsEDFWest African Alliance
European Union · CBAMSubmitted
EU CBAM: recognising carbon prices paid in third countries
The EU's Carbon Border Adjustment Mechanism prices the embedded emissions of imports in covered sectors. The European Commission consulted on how carbon prices paid in third countries — including through carbon credits — should be recognised and deducted from CBAM liability.
Why it matters
How “carbon price paid” is defined determines whether African carbon pricing instruments and credits count at the EU border — shaping both the competitiveness of African exports and the value of African carbon markets.
What we did
- Made a formal submission to the European Commission's consultation on CBAM and carbon prices paid in third countries, setting out how recognition should work so that African carbon pricing and credits are not excluded by design.
- Argued that recognition rules should reward genuine decarbonisation in African production rather than penalising exporters for MRV and data infrastructure gaps they did not create.
- Worked alongside African policymakers as they prepared their own submissions to the same consultation, strengthening the African voice in the process.
VCM+ Collaborative
European Union · 2040 targetSubmitted
The EU's use of international credits: a demand signal Africa can answer
The EU's proposed 2040 climate framework opens the door to a limited share of high-quality international carbon credits counting toward the target. It would be one of the largest structured demand signals ever created for international carbon markets — and the legal framework governing it is being written now.
Why it matters
Where the quality and eligibility criteria land, and which credit classes qualify, will determine whether African supply — including nature-based removals, the continent's comparative advantage — can compete for that demand on its merits.
What we did
- Submitted to the Commission's consultation on the legal framework for the possible use of international carbon credits toward the 2040 EU climate target, making the case for quality criteria that gatekeep on integrity rather than on credit category or geography.
- Submitted to the parallel consultation on national targets and flexibilities in the EU climate policy framework after 2030, so the flexibility is workable in practice.
- Published early thought leadership when the international-credit flexibility was first announced, framing what it could mean for African supply.
VCM+ Collaborative
