This Country Framework is part of the Regulatory Frameworks for Project-Based Carbon Credit Markets. To learn more click here.
Overview
Saudi Arabia has initiated the development of a carbon market framework through the establishment of a domestic crediting mechanism and a state-backed trading platform, although binding regulations governing market participation and credit use have not yet been adopted. The Greenhouse Gas Crediting and Offsetting Mechanism (GCOM),1 overseen by the Clean Development Mechanism Designated National Authority (CDMDNA),2 provides the institutional framework for domestic project registration and credit issuance. In parallel, the Regional Voluntary Carbon Market Company (RVCMC) operates as a trading platform facilitating carbon credit transactions, though it does not have a regulatory or supervisory mandate.3 The government has announced its intention to launch a national compliance carbon market by 2027, although detailed regulatory design elements have not been publicly disclosed.4
Current provisions focus primarily on supply-side processes, including project eligibility, methodology development, validation and verification, and registry tracking. Demand-side requirements, including rules governing credit use, disclosure, accounting treatment, and mitigation hierarchy, have not been established. Market infrastructure has been developed through auction-based trading and partnerships with registry, technology, and analytics providers. Saudi Arabia has indicated that it encourages its domestic crediting scheme and voluntary market infrastructure to align with Article 6 of the Paris Agreement, though detailed regulations governing host country authorization, corresponding adjustments, and internationally transferred mitigation outcomes (ITMOs) have not been published.5
I. Supply-Side Regulations
Saudi Arabia’s supply-side project-based carbon credit market (PCCM) framework is centered on GCOM, administered under the authority of the CDMDNA, which establishes procedures for project registration, credit issuance, validation and verification by accredited third parties, and centralized registry tracking. GCOM allows project activities across sectors and applies additionality testing, , reporting, and verification requirements, while addressing project-level double counting by prohibiting parallel registration under other crediting mechanisms. Publicly available documentation does not specify permanence timeframes, enforcement measures for noncompliance, or detailed rules governing host country authorization and corresponding adjustments for credits intended for international transfer. However, the framework is designed to adapt to future developments, including alignment with Article 6 of the Paris Agreement.
A. Regulatory Framework
- Market Classification: Saudi Arabia’s energy minister has announced an intention to launch a national compliance market by 2027, although no further information has been made available.6 7 The RVCMC has signed a memorandum of understanding (MoU) with the CDMDNA to support coordination and the development of the national carbon market framework ahead of the planned launch of a compliance market.8
- Regulatory Status: No binding rules have yet been established.
- Key Authorities: The domestic crediting mechanism, GCOM, has been established under the CDMDNA.9
- Sanctions: There are no explicit enforcement provisions. It is assumed that if the project fails to qualify, it simply will not be registered with GCOM.
B. Credit Generation Standards
- Eligible Activities: GCOM accepts projects and activities across all sectors, provided they comply with GCOM requirements.10
- Methodology Framework: GCOM develops its methodologies internally and makes them available to proponents. Internationally approved methodologies include the International Renewable Energy Certificate (I-REC), Verra, and Gold Standard.11 The designated national authority (CDMDNA) is responsible for approving and preparing the methodologies.12
- Measurement, Reporting, and Verification (MRV) Requirements: The project proponent may choose a CDMDNA-accredited verification and validation body to verify the project’s MRV documentation.13
- Registry System: The GCOM registry is responsible for maintaining a comprehensive view of issued credits and their status. Upon submitting an application to the registry, projects are issued a unique tracking number that will remain the same throughout their lifetime. Projects that are accepted are registered in GCOM and identified according to their activity classification within the registry. Credit ownership is also tracked to ensure it can be traced to its originating project.14 Project information is required to be disclosed clearly and factually to enable stakeholders to make decisions with reasonable confidence. Information is recorded, compiled, and analyzed in a way that upholds credibility and reliability.15
C. Integrity Principles
- Additionality Tests: “The project must demonstrate that it would not have occurred in the absence of the incentives provided by the mechanism, to prove that the project is additional.”16 For projects to qualify as additional, GCOM requires them to undergo a legal or regulatory additionality test, a common practice test, and an implementation barrier test.17
- Permanence Safeguards: Project proponents are required to assess the risk of and monitor, report, and compensate for the potential reversal of atmospheric benefits.18 However, no specific duration of permanence is specified.
- Quantification Standards: Projects are required to clearly define appropriate inventory boundaries and log appropriate information to ensure they meet meaningful emission reductions. Consistent accounting mechanisms allow for comparable greenhouse gas (GHG) emission data over time.19 Accounting is divided into GHG metric and non-GHG metric (the latter includes man-made habitat hectares produced, hectares of forest land, etc.).20
- Double-Counting Prevention: Credit issuance requires projects to prove that the activity is not registered under any other crediting mechanism.21
D. Sustainable Development
- Co-Benefits: The GCOM handbook does not make any direct reference to co-benefits, although it states that its main purpose is to “drive positive social, environmental and economic impacts beyond emission reductions or removals.”22
- Net-Zero Compatibility: GCOM was established to drive progress toward net-zero emissions by allowing interested companies and entities to offset their GHG emissions through credit purchase.23
II. Demand-Side Regulations
Saudi Arabia has not established demand-side regulations governing the use of carbon credits by companies or other entities, and there are no publicly disclosed requirements related to mitigation hierarchy, scope eligibility, quality thresholds, accounting treatment, disclosure of credit use, or alignment with science-based targets. No oversight bodies or enforcement mechanisms for demand-side participation have been defined, and while the government has announced its intention to introduce a national compliance carbon market by 2027, the interaction between such a market and voluntary carbon credit use has not yet been specified.
A. Use Authorization Framework
- Applications Allowed: The government has no explicit demand-side regulations for PCCMs. A compliance carbon market is expected to be launched in 2027, but its exact relationship to PCCMs is unclear.
- Regulatory Status: No demand-side regulation currently exists.
- Oversight Bodies: No oversight bodies for the demand side have been established.
- Standards Integration: There are currently no demand-side requirements for integrations with standards.
- Enforcement Mechanisms: No demand-side enforcement mechanisms have been established.
B. Corporate Use Requirements
- Mitigation Hierarchy: There are currently no demand-side requirements for mitigation hierarchy.
- Scope Coverage: There is no disclosure on scope coverage requirements.
- Quality Standards: There are currently no requirements for mandatory integrity criteria based on recognized frameworks.
- Accounting Treatment: There is no disclosure on the demand-side accounting treatment requirements.
C. Transparency and Assurance
- Public Reporting: No specific requirements for public reporting have been established.
- Third-Party Verification: There is an absence of regulatory requirements for independent assurance requirements.
- Science-Based Targets: No demand-side requirements for alignment with science-based targets have been established.
- Policy Advocacy: No further details on Paris Agreement alignment requirements have been specified.
D. Market Integrity Protection
- Anti-Greenwashing: , there are no anti-greenwashing mandates.
- Co-Benefits Delivery: There are no requirements on demand-side delivery of co-benefits.
III. Market-Side Regulations
Saudi Arabia’s market-side framework is anchored by the RVCMC, a trading platform established by the Public Investment Fund (PIF) and the Saudi stock exchange, Tadawul, which facilitates carbon credit transactions through auction-based mechanisms and has announced plans to expand transaction types, including request-for-quote (RFQ) and block trades. The platform has established partnerships with registry providers, technology firms, and market analytics and rating entities to support trading operations; however, settlement systems, financial regulatory integration, accounting treatment for traded credits, market conduct rules, and fraud prevention measures have not been publicly disclosed, and the regulatory interaction between the RVCMC, GCOM, and a future compliance market remains undefined.
A. Infrastructure Framework
- Market Structure: The credit trading exchange, the RVCMC, is jointly owned by Saudi Arabia’s sovereign wealth fund, the PIF, and the Saudi Tadawul Group.24 The RVCMC functions as a market infrastructure and trading venue rather than a regulatory authority, with credit issuance and project oversight remaining under the responsibility of GCOM and the CDMDNA.
- Registry Operations: The platform provides the ability to integrate with registries. It has struck partnerships with global market analytics and rating firms, such as MSCI and BeZero, to support credit integrity.25 Xpansiv was said to provide the technology infrastructure required for the exchange.26
- Data Standards: No market-side data standards have been disclosed.
B. Trading and Participation
- Eligibility Rules: No market-side eligibility rules have been specified. Credits traded so far stem from a range of locations and methodologies.27 Some examples of registries in which traded credits were registered include Verra, Gold Standard, and Puro.earth.28
- Trading Mechanisms: Credits may be traded in the RVCMC, which is owned by Saudi Arabia’s PIF and the Saudi Tadawul Group.29
- Settlement Systems: No settlement systems have yet been disclosed.
- Price Discovery: Auction systems have been put in place, and three auctions have been held so far.30 Mechanisms to allow for RFQ transactions and block trade functionality were expected to go live in 2025.31
- Oversight Authority: The platform is majority-controlled by the PIF, which owns 80 percent of the platform and provides its strategic direction.32
- : No information on accounting treatment for credit trading has been disclosed. Carbon credits are defined as “one ton of CO₂ or equivalent that has been reduced, avoided, or sequestered by a project. Carbon credits are designed to reduce overall carbon emissions by being traded in the marketplace.”33
C. Market Integrity Safeguards
- Antimanipulation and Fraud Prevention: There has been no specific disclosure on fraud prevention or anti-manipulation practices.
- Transparency and Reporting Requirements: The platform claims “institutional grade infrastructure to enable transparent and secure transactions,”34 although there are no details about what this looks like in practice.
D. Financial and Cross-Border Integration
- Financial Regulation Integration: No information has been disclosed on financial regulation integration. However, there is an intention to incorporate it into the Islamic finance framework.35
- Cross-Border Trading Framework: GCOM is designed to align with future changes and developments in Article 6 of the Paris Agreement. Credits generated can become ITMOs, subject to authorization by the CDMDNA.36 No explicit information regarding the RVCMC’s cross-border transaction framework has been released, although its auctions reportedly sell credits originating in and transferred to other countries.37 The exchange was built to help expand the voluntary carbon market in the Middle East and North Africa region, and has since established partnerships with Japanese and Singaporean companies to scale its presence in the Association of Southeast Asian Nations and the Global South.38
E. Regulatory Advancement Road Map
- Infrastructure Plans: No infrastructure plans have been disclosed.
- International Cooperation: Recent partnerships with MSCI and BeZero are intended to expand the market’s capability to trade high-quality credits. Additional MoUs with other international companies are aimed at building out an emissions offsetting offering for customers purchasing travel, supporting the generation of credits within Saudi Arabia, and offering internationally generated credits in the exchange.39
- Regulatory Evolution: The Saudi government has announced it intends to launch its compliance market in 2027. The interaction of this market with the exchange is yet to be defined.
- Enforcement Enhancement: No information on enforcement enhancements has been provided.
References
- Clean Development Mechanism Designated Authority, “GCOM Guidelines: Saudi Arabia’s Greenhouse Gas Crediting and Offsetting Mechanism (GCOM),” 11, July 2023, https://gcom.cdmdna.gov.sa/Downloads/KSA-GCOM-GUIDELINE.pdf. ↩
- Saudi Press Agency, “Saudi Arabia Launches Groundbreaking Greenhouse Gas Crediting and Offsetting Mechanism to Advance Global Climate Goals,” October 9, 2023, https://www.spa.gov.sa/en/3f4a1535b6m. ↩
- S&P Global, “COP29: Saudi Arabia Launches Carbon Credit Exchange to Bolster Decarbonization Efforts,” November 12, 2024, https://www.spglobal.com/energy/en/news-research/latest-news/energy-transition/111224-cop29-saudi-arabia-launches-carbon-credit-exchange-to-bolster-decarbonization-efforts. ↩
- XPansiv, “Saudi Arabia to Launch Compliance Market Within Three Years, Close Behind Voluntary Exchange—Minister,” October 9, 2023, https://xpansiv.com/press/saudi-arabia-to-launch-compliance-carbon-market-within-three-years-close-behind-voluntary-exchange-minister; Saudi Press Agency, “Saudi Arabia Launches Groundbreaking Greenhouse Gas Crediting and Offsetting Mechanism to Advance Global Climate Goals,” October 9, 2023, https://spa.gov.sa/3f4a1535b6m. ↩
- Roy Manuell, “Saudi Arabia to Launch Domestic ‘Article 6-Aligned’ Carbon Crediting System in 2024,” Carbon Pulse, October 9, 2023, https://carbon-pulse.com/227909/. ↩
- XPansiv, “Saudi Arabia to Launch Compliance Market Within Three Years, Close Behind Voluntary Exchange—Minister,” October 9, 2023, https://spa.gov.sa/3f4a1535b6m, https://xpansiv.com/press/saudi-arabia-to-launch-compliance-carbon-market-within-three-years-close-behind-voluntary-exchange-minister. ↩
- Paul Zakkour, Anwar Gasim, and Mari Luomi, Carbon Markets and Saudi Arabia: A Review of Options and Analysis of Carbon Crediting Potential, KAPSARC, February 2025, https://www.kapsarc.org/our-offerings/publications/carbon-markets-and-saudi-arabia-a-review-of-options-and-analysis-of-carbon-crediting-potential/. ↩
- Vasil Velev, “Saudi Arabia Moves Closer to 2027 Carbon Market Launch,” Carbon Herald, November 2, 2024, https://carbonherald.com/saudi-arabia-moves-closer-to-2027-carbon-market-launch/. ↩
- Saudi Press Agency, “Saudi Arabia Launches Groundbreaking Greenhouse Gas Crediting and Offsetting Mechanism to Advance Global Climate Goals,” October 9, 2023, https://www.spa.gov.sa/en/3f4a1535b6m. ↩
- Clean Development Mechanism Designated Authority, “GCOM Guidelines: Saudi Arabia’s Greenhouse Gas Crediting & Offsetting Mechanism (GCOM),” 11, July 2023, https://gcom.cdmdna.gov.sa/Downloads/KSA-GCOM-GUIDELINE.pdf. ↩
- Note: I-REC is not a carbon crediting standard but an energy attribute certificate system; Clean Development Mechanism Designated Authority, “GCOM Guidelines: Saudi Arabia’s Greenhouse Gas Crediting & Offsetting Mechanism (GCOM),” 15–16, July 2023, https://gcom.cdmdna.gov.sa/Downloads/KSA-GCOM-GUIDELINE.pdf. ↩
- Clean Development Mechanism Designated Authority, “GCOM Guidelines: Saudi Arabia’s Greenhouse Gas Crediting & Offsetting Mechanism (GCOM),” 4, July 2023, https://gcom.cdmdna.gov.sa/Downloads/KSA-GCOM-GUIDELINE.pdf. ↩
- Ibid., 17–21. ↩
- Ibid., 18–19. ↩
- Ibid., 8. ↩
- Ibid., 9. ↩
- Ibid., 21–24. ↩
- Ibid., 8. ↩
- Ibid., 7–8. ↩
- Ibid., 9–10. ↩
- Ibid., 13. ↩
- Ibid., 5. ↩
- Ibid., 4. ↩
- S&P Global, “COP29: Saudi Arabia Launches Carbon Credit Exchange to Bolster Decarbonization Efforts,” November 12, 2024, https://www.spglobal.com/energy/en/news-research/latest-news/energy-transition/111224-cop29-saudi-arabia-launches-carbon-credit-exchange-to-bolster-decarbonization-efforts. ↩
- Carbon Pulse, “Saudi VCM Inks New Partnerships as Govt Pushes Integrated National Carbon Market,” November 25, 2025, https://carbon-pulse.com/452863/; VCM, “RVCMC Launches Voluntary Carbon Market Exchange Platform to Channel Finance to High Quality Climate Projects,” November 12, 2024, https://vcm.sa/en/media-detail/rvcmc-launches-voluntary-carbon-market-exchange-platform-to-channel-finance-to-high-quality-climate-projects/; Zawya, “VCM Announces New Strategic Partnerships to Grow Corporate Advisory,” November 5, 2025, https://www.zawya.com/en/press-release/companies-news/vcm-announces-new-strategic-partnerships-to-grow-corporate-advisory-e2rvu2uq. ↩
- Xpansiv, “Saudi Arabia to Launch Compliance Carbon Market Within Three Years, Close Behind Voluntary Exchange—Minister,” October 29, 2024, https://www.xpansiv.com/press/saudi-arabia-to-launch-compliance-carbon-market-within-three-years-close-behind-voluntary-exchange-minister. ↩
- VCM, “RVCMC Launches Voluntary Carbon Market Exchange Platform to Channel Finance to High Quality Climate Projects,” November 12, 2024, https://vcm.sa/en/media-detail/rvcmc-launches-voluntary-carbon-market-exchange-platform-to-channel-finance-to-high-quality-climate-projects/. ↩
- S&P Global, “COP29: Saudi Arabia Launches Carbon Credit Exchange to Bolster Decarbonization Efforts,” November 12, 2024, https://www.spglobal.com/energy/en/news-research/latest-news/energy-transition/111224-cop29-saudi-arabia-launches-carbon-credit-exchange-to-bolster-decarbonization-efforts. ↩
- Ibid. ↩
- Paul Zakkour, Anwar Gasim, and Mari Luomi, Carbon Markets and Saudi Arabia: A Review of Options and Analysis of Carbon Crediting Potential, KAPSARC, 26, February 2025, https://www.kapsarc.org/our-offerings/publications/carbon-markets-and-saudi-arabia-a-review-of-options-and-analysis-of-carbon-crediting-potential/. ↩
- VCM, “RVCMC Launches Voluntary Carbon Market Exchange Platform to Channel Finance to High Quality Climate Projects,” November 12, 2024, https://vcm.sa/en/media-detail/rvcmc-launches-voluntary-carbon-market-exchange-platform-to-channel-finance-to-high-quality-climate-projects/. ↩
- S&P Global, “COP29: Saudi Arabia Launches Carbon Credit Exchange to Bolster Decarbonization Efforts,” November 12, 2024, https://www.spglobal.com/energy/en/news-research/latest-news/energy-transition/111224-cop29-saudi-arabia-launches-carbon-credit-exchange-to-bolster-decarbonization-efforts. ↩
- VCM, “What Are Carbon Credits?,” accessed April 1, 2026, vcm.sa/en. ↩
- VCM, “RVCMC Launches Voluntary Carbon Market Exchange Platform to Channel Finance to High Quality Climate Projects,” November 12, 2024, https://vcm.sa/en/media-detail/rvcmc-launches-voluntary-carbon-market-exchange-platform-to-channel-finance-to-high-quality-climate-projects/. ↩
- Ibid. ↩
- Clean Development Mechanism Designated Authority, “GCOM Guidelines: Saudi Arabia’s Greenhouse Gas Crediting & Offsetting Mechanism (GCOM),” 5–7, July 2023, https://gcom.cdmdna.gov.sa/Downloads/KSA-GCOM-GUIDELINE.pdf. ↩
- S&P Global, “COP29: Saudi Arabia Launches Carbon Credit Exchange to Bolster Decarbonization Efforts,” November 12, 2024, https://www.spglobal.com/energy/en/news-research/latest-news/energy-transition/111224-cop29-saudi-arabia-launches-carbon-credit-exchange-to-bolster-decarbonization-efforts; Paul Zakkour, Anwar Gasim, and Mari Luomi, Carbon Markets and Saudi Arabia: A Review of Options and Analysis of Carbon Crediting Potential, KAPSARC, 26, February 2025, https://www.kapsarc.org/our-offerings/publications/carbon-markets-and-saudi-arabia-a-review-of-options-and-analysis-of-carbon-crediting-potential/. ↩
- VCM, “VCM Expands Global Reach and Regional Collaboration in Asia with New Partnerships,” December 3, 2025, https://vcm.sa/en/media-detail/vcm-expands-global-reach-and-regional-collaboration-in-asia-with-new-partnerships-and-exchange-entrants/; VCM, “RVCMC Launches Voluntary Carbon Market Exchange Platform to Channel Finance to High Quality Climate Projects,” November 12, 2024, https://vcm.sa/en/media-detail/rvcmc-launches-voluntary-carbon-market-exchange-platform-to-channel-finance-to-high-quality-climate-projects/. ↩
- Zawya, “VCM Announces New Strategic Partnerships to Grow Corporate Advisory,” November 5, 2025, https://www.zawya.com/en/press-release/companies-news/vcm-announces-new-strategic-partnerships-to-grow-corporate-advisory-e2rvu2uq. ↩