Everyone Wants in on Brazil’s Rare Earths
But is Brasília ready to meet the moment?
This project examines the evolving regulatory landscapes of project-based carbon credit markets (PCCMs) across G20 countries and Singapore to help policymakers close integrity gaps and scale up the markets.
Authors: Dr. Gautam Jain, Preetha Jenarthan, Victoria Prado & Shubham Deshmukh • June 17, 2026
Project-based carbon credits let companies—especially those with net-zero targets—finance emissions reductions beyond their own operations, channeling capital to decarbonization efforts that might otherwise struggle to attract investment. Many projects deliver co-benefits as well—from protecting forests and biodiversity to safeguarding land and water.
But these markets have fallen short of that potential. An inability to self-regulate has led to controversies, scandals, and in some cases fraud, leaving the market stagnant—prices have weakened and unretired credits have built up. As demand shifts toward higher-integrity credits, credible voluntary standards have emerged, but because they are voluntary, they cannot provide enforceable oversight or recourse on their own. Closing that gap, the paper argues, calls for government regulation—much as regulation underpins trust in other financial markets—though regulation is an enabling condition, not a guarantee, of a scalable market.
This white paper uses the term “project-based carbon credit markets” (PCCMs) deliberately: demand now reaches well beyond voluntary use, spanning compliance markets and international mechanisms such as Article 6 of the Paris Agreement. It examines how regulations across G20 countries and Singapore could help close the market’s integrity gap.
It is accompanied by a series of companion country frameworks that examine how these regulatory dynamics are unfolding in individual jurisdictions—explore them in Country Frameworks below.
Voluntary markets have driven most demand, but a growing number of countries now allow project-based credits within mandatory compliance schemes, under binding rules and limits.
Regulation has focused first on credit generation, where governance is most developed and jurisdictions are converging on integrity criteria—though their stringency still varies.
Rules on how credits are used and disclosed are gaining traction, but inconsistency—especially around assurance—leaves buyers exposed to greenwashing, legal, and reputational risk.
Infrastructure ranges from regulated exchanges to self-regulated platforms, though bilateral trades dominate—shaping transparency, oversight, and price discovery.
Countries are moving to government-supervised registries, using them not just for record-keeping but for authorization, accounting, and oversight.
Efforts to make credits more traceable aim to standardize data and improve interoperability across systems.
Jurisdictions classify credits differently and apply varying legal classifications—affecting ownership, taxation, and cross-border transferability on which the scaling up of markets depends.
Countries are building bilateral authorization frameworks and interoperable registries to operationalize Article 6 of the Paris Agreement, which lets nations cooperate to cut emissions using carbon credits—either by writing it into regulation or moving toward compatibility.
The authors are deeply grateful to Ned Shell, Josh Zoffer, and Luisa Palacios for their guidance, contributions, insights, and encouragement throughout the project. They also thank Josh Zoffer, Noah Deich, and two anonymous referees for their thoughtful and detailed comments on an earlier draft, and Mark Kenber, Chris Canavan, Ben Rattenbury, Nat Keohane, Annette Nazareth, and Lydia Sheldrake for helpful discussions, feedback, and support.
The authors are especially appreciative of the time, effort, and care devoted by the Center on Global Energy Policy (CGEP) publications team to bringing this project to completion. The CGEP events and communications teams also played a critical role across various aspects of the project, particularly in organizing convenings that served as important input to the research.
The authors further express sincere appreciation to the many government officials and subject matter experts who carefully reviewed the stocktake to ensure an accurate representation of their respective countries’ PCCM regulatory frameworks. Any remaining errors are the authors’ own.
Some of the country experts who generously shared their time and insights include the following individuals and department staff.
The Center on Global Energy Policy (CGEP) would like to thank Bloomberg Philanthropies for its gift in support of the research conducted for this white paper. The views expressed in this white paper are solely those of the authors and do not necessarily reflect those of Bloomberg Philanthropies, CGEP, or Columbia University. The piece may be subject to further revision.
To better understand how regulations for PCCMs are evolving across the globe, the Center on Global Energy Policy (CGEP) at Columbia University SIPA conducted a year-long project combining research and stakeholder engagement through multiple convenings. The effort examined regulatory frameworks for PCCMs and emerging trends across countries and regions, and assessed whether such frameworks could help close the integrity gap in carbon credit markets.
The project is intended to inform policymakers and regulators seeking to design or refine regulatory approaches for PCCMs, as well as market participants and other stakeholders for whom these regulations are pertinent.
This white paper provides a comparative analysis of how jurisdictions align and differ across the key dimensions of PCCM regulation, based on an in-depth stocktake of the regulatory landscapes of G20 countries and Singapore, included in the appendix. The parameters studied can help identify gaps within a jurisdiction’s regulations and offer a means to compare efforts—highlighting where approaches align and enable interoperability, and where they differ in ways that could fragment the market.
The United States was excluded from the stocktake and the analysis in this report because it is the subject of a separate study.
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Dr. Gautam Jain is a Senior Research Scholar at the Center on Global Energy Policy (CGEP) of Columbia University’s School of International and Public Affairs (SIPA). He focuses on the role of financial markets and instruments—including thematic bonds, blended finance structures, and carbon markets—in the energy transition, with an emphasis on emerging economies.
Dr. Jain has an extensive background in the financial industry where he covered emerging markets as a portfolio manager and strategist. He has worked at asset management firms and an investment bank, including The Rohatyn Group, Barclays Capital, and Millennium Partners. He has helped manage emerging market local debt and hard-currency bond portfolios, encompassing currencies, interest rate instruments, and sovereign credits. He specialized in portfolio construction and asset allocation incorporating macroeconomic, policy, and political developments in emerging markets.
He holds a Ph.D. in Operations Research from Columbia University. He also has an M.S. in Industrial Engineering from Iowa State University and a B.Tech. in Mechanical Engineering from the Indian Institute of Technology, Bombay. He is a CFA charter holder, a Cornell Emerging Markets Institute Fellow, and an Adjunct Professor at Columbia University’s School of International and Public Affairs. He is a consultant to the Inter-American Development Bank on local currency hedging mechanisms and has previously been one to the United Nations to support a Global Investors for Sustainable Development (GISD) Alliance workstream on “Tackling Local Currency Risk”.
He has co-authored publications in the Journal of Derivatives, the Journal of Banking and Finance, the Journal of Applied Probability, Probability in Engineering and Informational Science, and the International Journal of Production Economics. He has also contributed chapters for the 2020 and 2021 Cornell EMI Annual Reports.
Senior Research Associate
Preetha is a Senior Research Associate at the Center on Global Energy Policy (CGEP) within Columbia University’s School of International and Public Affairs (SIPA), where she focuses her research on mobilizing capital for clean energy and low-carbon infrastructure development. Prior to joining CGEP, she was a climate finance professional with experience in sustainability strategy, including decarbonization pathways for hard-to-abate sectors. At CIMB Group, a leading Southeast Asian bank, she helped develop and operationalize a five-year sustainability roadmap, elevating its Dow Jones Sustainability Index ranking from the bottom to the top quartile within three years.
Her responsibilities included overseeing programs with cross-functional teams across the region, which involved developing sustainable finance sector policies, driving sustainability-linked corporate finance and debt capital market transactions, and advising clients on their transition action plans. She also designed an ESG risk framework to incorporate climate-related risks into credit assessments and the organization’s risk appetite statement. Additionally, she supported regulatory initiatives for the Joint Committee for Climate Change, co-chaired by the Central Bank and Securities Commission of Malaysia, including the Climate Change and Principle-based Taxonomy, the Value-Based Intermediation and Investment Impact Assessment Framework sectoral guides for renewable energy and energy efficiency, and organizing their inaugural climate finance conference. She also played a key role in incubating the CEO Action Network, driving policy advocacy with the public sector, capacity-building efforts, and collective commitments on climate action and social stewardship for over 50 private sector organizations across energy, finance, and other industries. She was also a member of several working groups on climate finance, including the UN Principles of Responsible Banking Impact Reporting and Disclosure task force.
Earlier in her career, Preetha was a Business and Strategy Associate at American International Group (AIG) Malaysia, where her responsibilities included conducting business analytics to optimize profitability and ensure capital adequacy, managing digital partnerships, and leading a new market entry strategy proposal for the Asia Pacific region. She holds a master’s degree in Economic Policy Management with a concentration on Energy and Environment from Columbia University and a bachelor’s degree in Actuarial Science and Finance with a minor in Economics from Drake University.
Research Associate
Victoria Prado is a Research Associate at Columbia University’s Center on Global Energy Policy, where she integrates the Trade and Clean Energy Transition initiative and conducts research on the geopolitics of critical minerals in Latin America. She was the first hire at a successful climate startup in Brazil, where she supported investor rounds, led the business intelligence team, and gained hands-on experience with carbon markets in emerging economies. Victoria also worked at the Rockefeller Foundation, advancing projects to expand energy access, accelerate coal phase-out in Southeast Asia, and deploy clean energy storage solutions in sub-Saharan Africa. Her work lies at the intersection of climate policy, sustainable development, and global energy systems, with a regional focus on Latin America. She holds a Master of Science in Sustainability Management from Columbia University and has experience in advising major players in Brazil’s oil, gas, and mining sectors on long-term sustainability strategy.
Research Assistant
Shubham Deshmukh is a Master’s candidate in Sustainability Management at Columbia University and is researching carbon-market regulatory architecture at the Center on Global Energy Policy at Columbia University SIPA. He is compiling a comparative stock-take across global jurisdictions of project-based carbon-credit regulations and analyzing Article 6 rulemaking from COP 21–29 to evaluate registry interoperability, corresponding adjustments, and share-of-proceeds design. Prior to joining Columbia University, Shubham worked with Indian start-ups, where he helped in structuring high-integrity nature-based carbon projects, guided smallholder farmers in adopting regenerative agriculture, and supported the deployment of IoT-enabled precision agriculture systems that raised horticulture yields and resource eciency. He holds degrees in Rural Management and Electrical Engineering.
This page summarizes the headline findings. The full white paper sets out the complete analysis, the country-by-country regulatory frameworks for the G20 and Singapore, and the evidence behind each finding. Read it online or download the PDF to explore the details.

A carbon credit is generated from a discrete project and can be used to offset emissions or meet climate goals. Each credit represents one metric ton of carbon dioxide equivalent (tCO₂e) removed, reduced, or avoided from the atmosphere relative to an established baseline scenario that enables the assignment of a monetary value to a carbon ton.
PCCMs are markets in which carbon credits—generated from discrete projects that remove, reduce, or avoid greenhouse gas emissions—are created, traded, and retired. They help direct private financing to decarbonization activities that might otherwise struggle to attract investment, with some projects also protecting water, land, forests, and biodiversity.
VCMs are one part of PCCMs. The report uses “project-based carbon credit markets” because demand now extends beyond voluntary use: PCCMs span voluntary credits, compliance-eligible credits used by regulated entities, and credits traded under international mechanisms such as Article 6 of the Paris Agreement and the aviation sector.
A high-integrity credit represents an independently verified reduction in greenhouse gas emissions that is real, additional, quantifiable, unique, and permanent. Demand has shifted toward these high-quality credits.
Because the market has struggled to self-regulate, leading to controversies, scandals, and in some cases fraud. Credible voluntary standards exist, but being voluntary, they can’t provide enforceable safeguards, consistent oversight, or recourse. Regulation can restore confidence, much as it underpins trust in financial markets.
No. Several credible, robust standards have been proposed, but because they are voluntary by design, they cannot, on their own, guarantee enforceable safeguards, consistent oversight, or dependable recourse. The report argues regulation is needed to close this gap.
Article 6 allows countries to cooperate voluntarily to reduce emissions using carbon credits. The report identifies “Article 6 readiness” as a key milestone, with countries building bilateral authorization frameworks and interoperable registries to put its procedures into practice.
Yes. While voluntary buyers have driven most demand, a growing number of countries now permit project-based carbon credits within mandatory compliance schemes, under binding rules and limits.
The market is suffering from stagnation: a growing surplus of unretired credits, weakening prices, and an integrity gap between the high-quality credits that buyers want and the enforceable safeguards available. Fragmented rules across jurisdictions add further uncertainty.
Countries are increasingly using national, government-supervised registries rather than relying solely on international ones—not just for record-keeping but for authorization, accounting, and market oversight, making them core to the regulatory infrastructure.
The report argues that the market is moving toward a more state-anchored, integrity-driven, and interoperable system in which credits form part of broader climate governance. Likely developments include deeper integration into national climate law, stronger but globally aligned integrity rules, more demand-side governance, sovereign registries, and greater financial oversight.
Accompanying the white paper, a series of 20 country frameworks examine how these regulatory dynamics are shaping up in specific jurisdictions—the local approach to address the trends explored above. Select a country to delve into its framework.