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This Country Framework is part of the Regulatory Frameworks for Project-Based Carbon Credit Markets. To learn more click here.
Overview
Singapore’s project-based carbon credit market (PCCM) is built around the Carbon Pricing Act (CPA) and the International Carbon Credit (ICC) Framework, along with the Guidance on the Role of Carbon Credits in Corporate Decarbonisation released in October 2025, which addresses the functioning of voluntary carbon markets (VCM). Beginning in 2024, carbon tax-liable facilities may offset up to 5 percent of their taxable emissions with eligible ICCs that satisfy Singapore’s seven integrity principles and comply with Paris Agreement Article 6 authorization rules. The National Environment Agency (NEA), which administers the ICC Framework, has issued operational guidance on how liable entities surrender ICCs for tax payment. Singapore also raised its carbon tax to S$25 (US$19.40)1 per ton of carbon dioxide equivalent (tCO₂e) in 2024–2025 and S$45/tCO₂e (US$34.90/tCO₂e) in 2026–2027, with a view to reach S$50–S$80/tCO₂e (US$38.80–US$62.00/tCO₂e) by 2030, strengthening price signals while allowing limited use of ICCs,2 as explained later.
In parallel, the government is operationalizing Paris Agreement Article 6 supply via bilateral Implementation Agreements (IAs), with recent agreements including Vietnam (IA signed September 16, 2025)3 and Mongolia (IA signed October 6, 2025),4 to enable authorization and corresponding adjustments for credits that may be admitted to Singapore’s Eligibility List, which is a list of host country-specific eligible Carbon Crediting Programmes (CCPs)5 and methodologies that spell out which crediting programs and methodologies are acceptable once projects are authorized.6
On the VCM side, the Ministry of Trade and Industry (MTI), together with the National Climate Change Secretariat (NCCS) and Enterprise Singapore (EnterpriseSG), published official guidance in October 2025 on the role of carbon credits in corporate decarbonization, following a public consultation process. The guidance sets expectations for credible corporate use of carbon credits outside Singapore’s carbon tax regime, emphasizing that companies should prioritize real and feasible emissions reductions across their value chains before using carbon credits to address residual emissions. It advises firms to use high-quality carbon credits aligned with Singapore’s integrity principles, conduct appropriate due diligence, and make transparent disclosures and claims regarding credit use.
The guidance also clearly distinguishes voluntary use of credits from compliance use under Singapore’s carbon tax framework, including the separate requirements that apply to ICCs. The document was released as part of the government’s broader effort to build confidence in carbon markets and promote high-integrity demand in the VCM.7 Singapore’s approach couples a rising carbon tax and a tightly specified ICC channel for compliance with a separate VCM guidance, aimed at scaling high-integrity demand while minimizing misleading environmental claims through steps on how to present and use carbon credits as part of a credible decarbonization plan.8
Singapore’s next steps include continuing to emphasize nature-based solutions as a key element of its climate mitigation and carbon finance strategy. In September 2025, the government announced plans to procure 2.175 million tons of Article 6–aligned nature-based carbon credits from four projects located in Ghana, Paraguay, and Peru, with an estimated contract value of about S$76 million (US$58 million). These initiatives are designed to deliver a mix of outcomes—including reducing emissions from deforestation, enhancing soil organic carbon sequestration in grasslands through sustainable management, and removing emissions via reforestation of degraded pastureland—advancing both environmental integrity and Singapore’s international cooperation under Article 6.9
I. Supply-Side Regulations
Singapore signed a new Paris Agreement Article 6 Implementation Agreement with Mongolia on October 6, 2025, expanding its partner set to 10 countries: Papua New Guinea, Ghana, Bhutan, Peru, Chile, Rwanda, Paraguay, Thailand, Vietnam, and Mongolia.10 The IA establishes the legal and procedural framework for generating and transferring authorized credits, along with corresponding adjustments, i.e., Internationally Transferred Mitigation Outcomes (ITMOs). This includes roles for host-country authorization; measurement, reporting, and verification (MRV) requirements; and financial provisions such as share-of-proceeds arrangements. In effect, it broadens the pipeline of high-integrity supply that could, once authorized and admitted to Singapore’s Eligibility List, be available to tax-liable companies alongside ICCs under the CPA.11
While Singapore and partner governments have signed agreements, the next steps will be to operationalize the Eligibility List. The Ghana-Singapore list is public and will be reviewed periodically, giving developers clarity on eligible project types, baseline approaches, and MRV expectations ahead of investment decisions.12 These lists translate Singapore’s seven integrity principles into project-level guardrails, aiming to reduce uncertainty for investors and developers and align future supply with Article 6 authorizations and the government’s high-integrity standards. These steps will be replicated for the other countries as part of the Eligibility List in the upcoming months.
A. Regulatory Framework
Market Classification: Singapore’s PCCM comprises voluntary and compliance markets. Compliance markets allow the use of credits from the ICC Framework.
Regulatory Status: Singapore has introduced two complementary frameworks to guide the use of carbon credits: the ICC Framework, which governs the use of eligible credits to offset a portion of liabilities under Singapore’s carbon tax regime, and the Guidance on the Role of Carbon Credits in Corporate Decarbonisation, which sets expectations for the voluntary use of high-quality carbon credits as part of credible corporate decarbonization strategies outside the tax regime.
Compliance: The ICC Framework under the CPA allows tax-liable facilities to voluntarily offset up to 5 percent of their taxable emissions using eligible international credits.13 The eligibility of ICCs to be used toward the carbon tax offset is subject to the seven eligibility criteria (not double counted, additional, real, quantified and verified, permanent, no leakage, and no net harm),14 though the credits can be sourced from multiple channels. The credits can be sourced first from the Eligibility List, subject to the eligibility criteria, and second by working with a project developer (or a third-party service provider) to identify eligible ICCs from existing projects or develop new ones.15
VCM: The VCM guidance, jointly released by the NCCS, the MTI, and EnterpriseSG on October 28, 2025, sets out how companies should use high-quality carbon credits as part of credible decarbonization plans, referencing integrity criteria such as additionality, permanence, verification, leakage, and safeguards against double counting.16
Key Authorities:
Compliance: The NEA serves as the administrator of the ICC Framework under the CPA. The NEA manages processes including the Eligibility List of host-country programs and methodologies, verification of credits used to offset carbon tax liabilities, and operation of the Carbon Credits Registry.17 The Ministry of Sustainability and the Environment (MSE), which oversees the NEA, provides strategic climate policy direction and co-issues the ICC eligibility criteria and related guidance, but does not handle credit registry or surrender procedures.18 MSE’s own policy mandate covers the development and coordination of Singapore’s broader climate and sustainability policies, including the Carbon Pricing Act and the Singapore Green Plan 2030.19
VCM: The NCCS, together with MTI and EnterpriseSG, leads Singapore’s work on the voluntary carbon market. These agencies jointly issued the Guidance on the Role of Carbon Credits in Corporate Decarbonisation on October 28, 2025, which sets out integrity principles and policy expectations for credible corporate use of carbon credits outside the tax regime. MTI and EnterpriseSG also support the growth of Singapore’s carbon services and trading ecosystem, including project developers, traders, advisory firms, and MRV providers.20
Sanctions:
Compliance: The sanction for non-compliance with the eligibility or procedural standards under the ICC Framework is disqualification of the credit that can be used as an offset against the carbon tax, which is imposed by the NEA rather than a separate financial penalty.21
VCM: The guidance does not explicitly state any penalties or sanctions for non-compliance.
B. Credit Generation Standards
Eligible Activities:
Compliance: The ICC Framework standards do not comprise a single, universal list of eligible activities, but are instead determined based on a layered, bilateral agreement system under the ICC Framework. For an ICC to be eligible for tax offset, the underlying activity (defined by its methodology) must meet three criteria concurrently: (1) It must be located in a host country that has an IA with Singapore, which is necessary for corresponding adjustments to prevent double counting; (2) it must be issued by one of the preapproved CCPs; and (3) the specific methodology used by the activity must be included in the Eligibility List—a list whose contents can and often do differ by host country, reflecting the unique negotiations and domestic priorities agreed upon in the bilateral IA.22
VCM: The guidance does not define eligible activities or provide an exhaustive list of standards or programs, instead encouraging companies to use additional tools and standards to assess carbon credit quality.23
Methodology Framework:
Compliance: The ICC Framework references Article 6 of the Paris Agreement (especially corresponding adjustments); the methodologies of specific, pre-existing Singapore CCPs (Verra, Gold Standard, etc.); and the eligibility criteria.24 The stringency of other standards, like the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), is referenced in official press releases.25
VCM: The guidance references the ICC Framework’s integrity principles for context but does not require corresponding adjustments for voluntary corporate use. As such, claims do not count toward nationally determined contributions (NDCs).26
MRV Requirements:
Compliance: The ICC Framework requires that the ICCs be procured from Singapore’s CCP registry, in which they were issued, so the MRV process follows the CCP’s requirements.27
VCM: The guidance encourages companies to measure and report their baseline-year emissions, develop a credible decarbonization plan, and transparently disclose their use of carbon credits, while using the ICC Framework’s integrity principles as a reference for identifying high-quality credits.28
Registry System:
Compliance: The registry system under the ICC Framework is structured around three core pillars to ensure integrity and transparency. First, the NEA is developing its own national registry to centrally account for and track all ICCs surrendered by taxable facilities, ensuring compliance with Article 6 of the Paris Agreement. Second, the procurement of credits is currently limited to five pre-approved external registries, which could be expanded in the future: Gold Standard, Verra’s Verified Carbon Standard, Global Carbon Council, American Carbon Registry, and Architecture for REDD+ Transactions. Finally, to enhance global transparency and prevent double counting, Singapore has partnered with the World Bank and the International Emissions Trading Association on the Climate Action Data Trust (CAD Trust) initiative, which is building a data dashboard for public access to information across multiple global registries.29
VCM: The guidance encourages companies to acquire high-quality credits from reputable registries and to disclose where those credits are held.30
C. Integrity Principles
Additionality Tests:
Compliance: The ICC Framework states that certified emissions reductions or removals must exceed any required by law or any regulatory requirement of the host country in the eligibility criteria of ICCs.31
VCM: The guidance states that voluntary use of credits is not bound to Article 6 or the ICC Framework (compliance regulations), but the principles from the ICC Framework serve as a good guide on high-quality credit attributes, which include additionality.32
Permanence Safeguards:
Compliance: The ICC framework states that certified emissions must be permanent, and reductions or removals must not be reversible, or if there is a risk that the certified emissions reductions or removals may be reversible, measures must be in place to monitor, mitigate, and compensate for any material reversal of the certified emissions reductions or removals. The duration for permanence is not specified.33
VCM: The guidance states that voluntary use of credits is not bound to Article 6 or the ICC Framework (compliance regulations), but the principles from the ICC Framework serve as a good guide on high-quality credit attributes, which include permanence.34
Quantification Standards:
Compliance: The ICC Framework states that certified emissions must be quantified and verified, and reductions or removals must have been calculated in a manner that is conservative and transparent, and must have been measured and verified by an accredited and independent third-party verification entity before the ICC was issued.35
VCM: The guidance states that voluntary use of credits is not bound to Article 6 or the ICC Framework (compliance regulations), but the principles from the ICC Framework serve as a good guide on high-quality credit attributes, which include quantification.36
Double-Counting Prevention:
Compliance: The ICC Framework states that certified emissions reductions or removals must not be double counted in contravention of the Paris Agreement.37
VCM: The guidance states that voluntary use of credits is not bound to Article 6 or the ICC Framework (compliance regulations), but the principles from the ICC Framework serve as a good guide on high-quality credit attributes, which include double-counting prevention.38
D. Sustainable Development
Co-benefits:
Compliance: Co-benefits are not explicitly stated or specified in the regulation. However, ICC eligibility criteria do include a “no net harm” provision requiring that the carbon emissions reduction or removal activities not violate any laws, regulatory requirements, or international obligations.39
VCM: The guidance does not explicitly address co-benefits, but it states that voluntary credit use is not bound by Article 6 or the ICC Framework, though the ICC integrity principles are presented as a guide to high-quality credit attributes.40
Net-Zero Compatibility:
Compliance: Net-zero compatibility is not explicitly stated in the ICC Framework. However, thus far, all of Singapore’s CCPs are concurrently labeled as Integrity Council for the Voluntary Carbon Market’s (ICVCM) core carbon principle–eligible programs, which are assessed against its 10 Core Carbon Principles, including net-zero compatibility.41
VCM: Net-zero compatibility and avoidance of carbon lock-in are not explicitly addressed in the guidance, and while voluntary credit use is not bound by Article 6 or the ICC Framework, the ICC integrity principles are offered as a guide to high-quality credit attributes.42
II. Demand-Side Regulations
A. Use Authorization Framework
Applications Allowed:
Voluntary claims: The guidance for voluntary use by corporates sets out nonbinding expectations for credible voluntary use of carbon credits, anchored on three principles: abatement, quality, and transparency. It requires companies to prioritize all feasible emissions reductions across their operations and value chains, using carbon credits only as a complementary tool for residual, hard-to-abate emissions. The guidance specifies that credits should demonstrate high environmental integrity, including being real, additional, permanent, independently verified, and free from double counting, and it calls for transparent public disclosure of credit use, including volumes, project information, registry details, and the purpose of the claim.43
Compliance integration: The ICC Framework states that companies may voluntarily use it to offset up to 5 percent of their carbon tax liability.44
NDC alignment: While not stated in regulations, the official press releases state that Article 6 bilateral carbon credit partnerships are designed to “support the achievement of Singapore’s NDC and enable partner countries to meet their own NDCs.” This linkage positions Article 6 cooperation not as a stand-alone trading mechanism, but as an integrated tool for advancing nationally determined climate targets while maintaining environmental integrity and avoiding double counting.45
Regulatory Status: The issued ICC Framework and VCM guidance, as well as voluntary environmental or carbon-related claims, are subject to mandatory anti-greenwashing rulesunder theConsumer Protection (Fair Trading) Act 2003 (CPFTA), which is enforced by the Competition and Consumer Commission of Singapore (CCS).46 Additionally, the Singapore Code of Advertising Practice (SCAP), administered by the Advertising Standards Authority of Singapore (ASAS), establishes quasi-mandatory standards for advertisements that make environmental claims. These standards demand that any claim be clear, substantiated, and not misleading—especially when the claim involves terms like “eco-friendly” or “carbon-neutral.” Although the SCAP itself is not legislation, ASAS has the authority to require the withdrawal or amendment of noncompliant advertisements, and breaches of SCAP may indicate unfair practices under the CPFTA.47
Oversight Bodies:
Compliance: The same oversight bodies as the supply-side regulations. The NEA serves as the administrator of the ICC Framework under the CPA. The NEA manages processes including the Eligibility List of host-country programs and methodologies, verification of credits used to offset carbon tax liabilities, and operation of the Carbon Credits Registry.48 The MSE, which oversees NEA, provides strategic climate policy direction and co-issues the ICC eligibility criteria and related guidance, but does not handle credit registry or surrender procedures.49 The MSE’s own policy mandate covers the development and coordination of Singapore’s broader climate and sustainability policies, including the Carbon Pricing Act and the Singapore Green Plan 2030.50
VCM: The NCCS, together with MTI and EnterpriseSG, leads Singapore’s work on the voluntary carbon market. These agencies jointly issued the October 2025 Guidance on the Role of Carbon Credits in Corporate Decarbonisation, which sets out integrity principles and policy expectations for credible voluntary credit use. MTI and EnterpriseSG also support the development of Singapore’s carbon services and trading ecosystem, including project developers, traders, advisory firms, and MRV providers.51
Overall:
CCS: Oversees enforcement of the CPFTA, which covers misleading environmental claims, including carbon-offset claims. It can investigate unfair trade practices, issue injunctions, and impose court orders for persistent offenders.52
ASAS: Administers the Singapore Code of Advertising Practice, which requires that environmental or carbon-related claims in advertisements be clear, substantiated, and not misleading; ASAS can mandate amendment or withdrawal of noncompliant advertisements.53
Standards Integration:
Compliance: The ICC Framework only allows approved carbon programs, which reference other standards.54
VCM: The guidance states that companies should reference global meta standards, such as the Paris Agreement Crediting Mechanism, ICVCM’s Core Carbon Principles, and CORSIA, as benchmarks for credit quality.55
Enforcement Mechanisms:
Compliance: The ICC Framework’s enforcement is through the NEA, which requires preapproval before carbon tax offset use.56 No other penalties are indicated.
VCM: The guidance only provides guidelines and does not stipulate any sanctions.
B. Corporate Use Requirements
Mitigation Hierarchy:
Compliance: The ICC Framework does not explicitly mention mitigation hierarchy.
VCM: The guidance encourages companies to prioritize internal decarbonization before using carbon credits.57
Scope Coverage:
Compliance: The ICC Framework does not provide explicit specifications on Scopes 1, 2, and 3 reductions.
VCM: The guidance encourages companies to prioritize emissions reductions across all emission scopes, particularly those that are technically, scientifically, and economically feasible.58
Quality Standards:
Compliance: The ICC Framework sets seven integrity principles (not double counted; additional; real; quantified and verified; permanent; no net harm; no leakage).59
VCM: The guidance encourages the adoption of high-quality carbon credit criteria, referencing the ICC Framework.60
Accounting Treatment:
Compliance: The regulation designates a national registry that manages registration, transfers, and cancellations of every carbon-emission trading product, and states that cancellation is the official ledger entry for compliance surrender.61
VCM: Accounting treatment is not explicitly mentioned in the guidance.
C. Transparency and Assurance
Public Reporting:
Compliance: The ICC Framework states that transparency is needed in calculating emission reductions and removals. It also states that it accepts credits from NEA-approved programs, all of which publish project documentation, methodologies, and issuance or retirement records in publicly accessible registries.62 There will also be a publicly available national registry called the Overall Project Register for the ICCs. It is unclear how much detail will be in the registry, as it is still being developed.63
VCM: Companies are encouraged to transparently disclose their use of carbon credits, including the type of credits used, volumes, project location, registry where the credits are held, purpose of use, and any third-party ratings, where available, in the guidance.64
Third-Party Verification:
Compliance: The demand-side requirements in the ICC Framework are to acquire credits that meet the criteria for high-quality carbon credits in the compliance regulations, including credits that have been quantified and third-party verified. The use of the credits does not require third-party verification, as they are used for carbon tax offsets.
VCM: Companies on the demand side are encouraged to consider disclosing their use of carbon credits and third-party ratings.65 The guidance encourages acquiring credits that meet the criteria for high-quality carbon credits in the compliance regulations, including credits that have been quantified and third-party verified.66
Science-Based Targets: Not explicitly stated either in the compliance regulations or in the VCM guidance.
Policy Advocacy:
Compliance: The ICC Framework requires alignment with Article 6 of the Paris Agreement.67
VCM: The guidance encourages companies to have a credible decarbonization plan, including best practices, that outlines their contribution to the Paris Agreement temperature goals. However, it says voluntary use is not bound by Article 6 of the Paris Agreement, as it does not contribute toward the country’s NDCs.68
D. Market Integrity Protection
Anti-Greenwashing:
Compliance: Greenwashing risks are controlled through the usage of high-quality credits, but are not explicitly addressed in regulations. This is managed through other forms of consumer protection laws.
VCM: The guidance encourages companies to have a credible decarbonization plan, including best practices, and to use high-quality credits, as defined in the compliance regulations, but it does not explicitly address greenwashing. This is managed through other forms of consumer protection laws.69
Co-Benefits Delivery: There is no requirement in the compliance regulations or the VCM guidance that buyers must demonstrate delivery of community, biodiversity, or sustainable development co-benefits as part of credit use.
III. Market-Side Regulations
A. Infrastructure Framework
Market Structure: There are four active carbon exchanges in Singapore—AirCarbon Exchange (ACX), Climate Impact X (CIX), European Energy Exchange, and Intercontinental Exchange. These exchanges form part of Singapore’s broader effort to position itself as a regional hub for high-integrity carbon trading, with over 150 carbon services and trading firms already operating across origination, verification, and brokerage functions.70
Registry Operations: First, facilities must submit a “Notice of ICC Use” to NEA for acceptance, identifying the quantity and source of eligible ICCs that meet the government’s environmental-integrity criteria. Once approved, the facility may procure the approved ICCs on an authorized CCP registry, if it does not already own them. Following procurement, the company must retire (cancel) the ICCs within the registry to ensure they cannot be traded or claimed again. Finally, the company must submit the Evidence of Retirement (EOR) through the Emissions Data Monitoring and Analysis system to NEA, which serves as the official ledger entry for accounting and compliance purposes under the CPA.71
Data Standards: The announcement about a new platform, the CAD Trust, launched in Singapore, indicates a push for interoperability across registries and traceability of credits, but it is a global initiative rather than a binding Singapore regulation.72
B. Trading and Participation
Eligibility Rules: None are clearly stated in legislation other than the process to use the credits to offset the carbon tax.
Trading Mechanisms: Carbon market infrastructure is built around a set of core market-side trading mechanisms rather than detailed statutory trading rules. Trading takes place primarily through exchange-based, order-book platforms such as CIX and ACX, where carbon credits are sold using standardized contracts that define eligible credit types, vintages, methodologies, and minimum lot sizes. These include standardized instruments, combined with transparent bid-ask order books, that create price discovery, liquidity, and fungibility, distinguishing Singapore from purely over-the-counter (OTC) voluntary markets.73
Settlement Systems: Singapore’s leading carbon market trading platforms rely on delivery-versus-payment (DvP) settlement systems to ensure that carbon credits and cash move simultaneously, reducing counterparty risk and aligning carbon trading with established commodity market standards. CIX uses its dedicated CIX Clear service to verify credit availability and execute DvP settlement linked to underlying registries. Meanwhile, ACX uses digital or tokenized contracts that enable near-real-time atomic settlement. Both systems integrate directly with Verra, Gold Standard, and other registries to confirm ownership, transfer, and retirement, forming the core of Singapore’s market-side integrity framework.74
Price Discovery: Price discovery occurs primarily through exchange-based, order-book trading on CIX and ACX. Both platforms publish live bid-ask quotes, enabling transparent, market-driven pricing rather than opaque OTC negotiation. CIX provides price signals for standardized spot contracts (initially nature-based baskets), while ACX offers continuous two-way pricing for its digital carbon contracts. Early CIX trades (e.g., ~US$5–US$6/tCO₂e for nature-based credits) demonstrate the creation of benchmark reference prices in Asia. Together, these mechanisms shift Singapore’s carbon market toward transparent, liquid, and standardized price formation.75
Oversight Authority: Market-side activity in Singapore is overseen primarily by NEA, which governs credit integrity and retirement under the carbon-tax regime. Meanwhile, the Monetary Authority of Singapore (MAS) oversees carbon-trading platforms only if their activities trigger financial market regulations. Since carbon credits are not classified as financial instruments in Singapore, exchanges like CIX and ACX operate largely under self-regulatory market standards, not a dedicated carbon-market authority.76
Legal Classification: This is not explicitly addressed in regulations. However, a report by the International Swaps and Derivatives Association (ISDA) states that under Singapore law, whether a carbon credit is considered intangible property or simply a contractual right depends on the specific terms attached to it. If the credit grants clear, transferable, and enforceable rights, it is likely to be treated as intangible property. Singapore courts generally apply a property-rights test developed in an English case and affirmed in local decisions, which requires the right to be definable, recognizable by third parties, transferable, and sufficiently stable.77
C. Market Integrity Safeguards
Anti-Manipulation and Fraud Prevention: Singapore does not have carbon market–specific anti-manipulation and fraud prevention laws. Spot trading of voluntary carbon credits is not regulated under Singapore’s Securities and Futures Act (SFA), meaning general financial market manipulation rules only apply if the product is a regulated financial instrument (e.g., a derivative). For carbon credits used in Singapore’s carbon tax regime, NEA enforces integrity through eligibility rules, registry-linked verification, mandatory retirement, and safeguards against double counting. Carbon credit exchanges operating in Singapore—such as CIX—may apply internal risk controls, but there is no public evidence of government-mandated anti-manipulation rules for voluntary spot trading. These exchanges have their own governance rules to manage manipulation and fraud.78
Transparency and Reporting Requirements: Relies on registry-based transparency and exchange-level disclosure, rather than a dedicated market-side reporting statute. All carbon credit transfers, ownership changes, and retirements must be recorded in the underlying credit registry (e.g., Verra, Gold Standard, ART), which provides serial-number traceability and public visibility into issuance, transfer history, and retirement status. For credits used under Singapore’s carbon tax, the NEA requires entities to submit an EOR and verify that credits meet integrity and eligibility rules, creating an auditable reporting chain. On the market side, exchanges such as CIX and ACX provide order-book transparency, displaying live bids, offers, and executed trades for standardized contracts. They also maintain audit trails, transaction logs, and credit-specific attributes (e.g., vintage, project type, methodology, crediting program), which must be disclosed to participants. While MAS does not mandate carbon-market reporting unless financial instruments are involved, general financial market conduct rules on disclosure and fair dealing apply if a platform triggers securities regulation. Overall, transparency is ensured through registry disclosure, exchange-level trade visibility, and NEA reporting requirements, rather than a stand-alone carbon-market reporting framework.79
D. Financial and Cross-Border Integration
Financial Regulation Integration: There is no dedicated carbon market financial regulation, but integration occurs through the MAS when carbon market activities intersect with existing financial market laws. Carbon credits themselves are not classified as capital-market products under the SFA,80 so spot carbon credit trading on platforms like CIX or ACX is not regulated as a financial instrument. However, if an exchange lists derivatives, futures, tokenized financial instruments, or structured products referencing carbon credits, those activities could fall under MAS oversight as regulated market operators or capital-markets intermediaries. MAS has recently released a statement of support for energy transition credits and describes exploratory work and stakeholder consultation on it, but not on regulating the credits themselves.81
Cross-Border Trading Framework: Thecross-border carbon credit trading framework is anchored in its participation under the Paris Agreement’s Article 6. Through legally binding IAs with host countries (e.g., Bhutan, Peru, Rwanda, Thailand, Vietnam), Singapore establishes the bilateral mechanisms to transfer credits in compliance with Article 6.2 standards, including corresponding adjustments, integrity safeguards, and eligibility under the Carbon Pricing (Carbon Tax and Carbon Credits Registry; Amendment) Regulations 2023. On the market side, this framework enables Singapore-based buyers and trading platforms to access projects abroad and secure credits that are eligible for use under Singapore’s market (e.g., offsetting up to 5 percent of taxable emissions) while ensuring transparency and traceability across borders.
E. Regulatory Advancement Development Road Map
Infrastructure Plans: Singapore’s carbon-market development efforts focus on strengthening data, transparency, and registry connectivity to support high-integrity international carbon trading, including through the CAD Trust, which enhances life cycle traceability and now covers about 85 percent of all carbon credits issued globally.82 Voluntary market infrastructure in Singapore is also expanding through exchanges such as CIX and ACX, which currently operate spot and auction-based voluntary carbon credit platforms.83 Simultaneously, the government is expanding its Article 6.2 Implementation Agreements to support cross-border carbon-market cooperation and has announced new nature-based carbon credit projects in partner countries, reflecting Singapore’s growing use of Article 6 pathways.84 These measures support Singapore’s wider ambition—anchored by NEA, NCCS, and EnterpriseSG, among other government bodies—to position the country as a regional hub for carbon services and international carbon-market activity,85 although fully regulated derivatives, clearing, or cross-exchange carbon-trading infrastructure have not yet been publicly established.
International Cooperation: Singapore actively pursues international cooperation under Paris Agreement Article 6 via binding bilateral IAs with host countries (e.g., Ghana, Peru, Paraguay, Thailand, Vietnam) to enable the transfer of mitigation outcomes (carbon credits) into Singapore’s market.86
Regulatory Evolution: Singapore is progressively developing the institutional and data infrastructure around carbon markets, though spot carbon credit trading itself remains outside the regulated financial market framework. While carbon credits remain nonfinancial instruments, ISDA has reported that carbon-related derivatives or tokenized capital-market products fall under the Securities and Futures Act, bringing those products into regulated oversight.87 In parallel, Singapore is strengthening digital traceability and registry connectivity through initiatives such as the CAD Trust and expanding Article 6 cooperation, supporting a gradual shift toward a more transparent and internationally interoperable carbon-market ecosystem.88
Enforcement Enhancement: Enforcement is partially supported by MAS’s market conduct, anti-manipulation, anti-money laundering, and countering the financing of terrorism rules whenever carbon-related activities involve regulated financial products such as derivatives or tokenized capital-market instruments. Once a carbon-market activity falls within the scope of the SFA, MAS’s surveillance frameworks for misconduct, manipulation, and unfair trading apply.89 At the same time, Singapore is strengthening the integrity of carbon market transactions through digital traceability initiatives such as the CAD Trust.90
References
Based on the FX conversion rate as of December 2025. ↩
Competition and Consumer Commission of Singapore (CCS), Guide on Quality-Related Claims, Government of Singapore, October 2025, https://isomer-user-content.by.gov.sg/45/5709854d-71the ,2c-45be-b547-8d0bc77445a4/CCS%20Guide%20on%20Quality-Related%20Claims.pdf. ↩
Advertising Standards Authority of Singapore (ASAS), “Singapore Code of Advertising Practice 3rd Edition,” IV.L, Government of Singapore, August 2008, https://asas.org.sg/Portals/0/SCAP%202008_1.pdf.↩
Government of Singapore, “Securities and Futures Act (Cap. 289)–Division 1—Establishment of Organised Markets,” Singapore Statutes Online, accessed November 19, 2025, https://sso.agc.gov.sg/Act/SFA2001?ProvIds=pr4A-.↩
