Reform der afrikanischen CO₂-Märkte (EN)

Summary

Kigali and the question nobody can avoid

Carbon markets allow emissions reductions to be sold as credits, but under the Paris Agreement, authorising these credits for international transfer means the host country surrenders the right to count them towards its own climate commitments.

At the Carbon Markets Africa Summit in Kigali in October, the language was that of delivery: investment-ready projects, credible credits, willing buyers, transactions at scale. COP31 was a month away, and climate finance remained scarce. Yet a week before Kigali, Kenya had supplied an awkward footnote to the programme. It announced a cumulative ceiling of 10 million tonnes of CO₂-equivalent for international transfers between 2025 and 2030, to safeguard its own climate commitments.

Kigali was asking how Africa might export more carbon. Nairobi was asking how much carbon it could afford to export at all. The contradiction lies between a continental market largely imagined around foreign demand and sovereigns whose Paris obligations increasingly require them to reserve emissions reductions for themselves. COP31 should confront that distinction.

Kenya and the price of permission

Kenya’s caution did not emerge from an academic debate over accounting rules. In January, KOKO Networks closed, laying off roughly 700 employees after the government declined to issue the letter of authorisation it needed to sell its clean-cooking credits under CORSIA and Article 6. KOKO’s business rested on a sensible social bargain: Supply bioethanol cooking fuel cheaply to households, then recover part of the subsidy through carbon revenues. Without that authorisation, the revenues on which that bargain depended could no longer be relied upon. By October, administrators were struggling to find a meaningful buyer for the credits remaining in its estate.

KOKO’s January collapse and Kenya’s October ceiling reveal the same problem from opposite directions. Developers may create and hold credits, but their use in particular international markets can depend on a sovereign decision. KOKO’s model relied on selling about 6 million credits a year. Against a national ceiling of 10 million tonnes for 2025 to 2030, one company would have used up the whole allowance in under two years. When a private business treats that decision as routine paperwork, it may discover that the state’s carbon budget is neither its property nor an inexhaustible export licence. Equally, withholding permission does not automatically produce a domestic buyer. That is the more uncomfortable lesson of KOKO: Protecting national headroom without building a market at home can strand commercial value, jobs and the mitigation activity itself.

From the Kyoto reflex to the Paris constraint

In my November 2025 APRI essay, I described the persistence of a Kyoto reflex: African carbon markets organised to produce inexpensive credits for buyers elsewhere. Under the Paris Agreement, the basic transaction has changed. For mitigation outcomes authorised for international use, corresponding adjustments ensure that a reduction counted abroad does not also count towards the host country’s nationally determined contribution (NDC). What leaves the country is the accounting entitlement to the reduction. A government that transfers an inexpensive reduction may later have to find a more costly one to fulfil its own pledge.

This is why the distinction between a project’s credit and a country’s permission to export its mitigation outcome cannot be treated as legal pedantry. The former may generate commercial revenue; the latter reallocates part of a treaty-agreed sovereign climate budget. Not every voluntary credit sale requires such an adjustment, and the categories must not be confused. But for authorised international transfers, the economic rule is clear: Exportable mitigation ought to be the residual after domestic needs have been assessed, not the starting assumption from which national policy works backwards.

Asia has already confronted the dilemma

Indonesia paused international carbon trading in 2021 by making foreign sales conditional on meeting sectoral NDC targets. With domestic trading still thin, it reopened in October 2025 under Presidential Regulation 110/2025, which lets international trading go ahead before those targets are met. In December 2022, India declared that credits would be used first towards its own NDC, with selective external sales possible. Vietnam’s April 2026 decree similarly established differentiated ceilings on international transfers, including limits tied to the mitigation activity concerned. These governments did not follow one identical policy. India and Vietnam make the export market answer to the domestic climate balance sheet. Indonesia applied the same rule before it had domestic demand to absorb what it held back, and had to relax it.

None of this makes international trading futile, and Indonesia’s reopening shows governments still want the foreign capital it brings. What changes is that the permission to trade becomes more valuable, and more politically contested, once governments understand what they are surrendering. Africa is approaching that moment with an export industry already under construction and domestic markets still thin.

Reforming the ambition

The Africa Carbon Markets Initiative (ACMI), launched at COP27, aspired to 300 million credits a year, USD 6 billion in revenues and 30 million jobs by 2030. Those remain ambitions, not outcomes. More importantly, producing credits is not the same as having permission to export them, and permission is not the same as a viable price. If more African governments begin reserving reductions for their own NDCs, the assumption that export volumes can rise almost independently of domestic climate obligations becomes increasingly fragile.

An indiscriminate export ban would be the wrong answer. Such a policy could extinguish the foreign finance on which many existing projects depend before domestic demand has emerged. Reform requires sequencing: credible national emissions accounts; published eligibility criteria, approval deadlines and review procedures for authorisation and corresponding adjustments; registries capable of tracking both domestic retirement and international transfer; and domestic compliance obligations or purchasing arrangements that give locally retained reductions a price. Community benefits and financing must attach to actual projects, not merely to expectations of a future foreign buyer.

The ACMI can still perform a continental service, but its task should evolve from multiplying export pipelines to helping African countries create functioning carbon economies. Some credits will properly be sold abroad, once national mitigation budgets identify a credible surplus after domestic commitments and a prudential reserve. Others will be worth more retained at home. The distinction should arise from sovereign accounting and domestic value, not the accident of where the first buyer happens to sit. At COP31 in Antalya, African governments should seek support for national emissions accounting, carbon registries and domestic purchasing mechanisms. The measure of progress should change. Africa’s success cannot begin with how much raw carbon it exports. It must begin with how much value its carbon reductions create at home.

About the Author

Ebipere K. Clark

Ebipere K. Clark is a Visiting Fellow at APRI and Managing Partner at Frontier-Alpha LLP. He works on capital markets, energy and infrastructure, and on climate policy and finance.