On May 2, 2025, the Minister responsible for Climate Change Management officially introduced the Carbon Trading (General) Regulations, Statutory Instrument 48 of 2025, effectively repealing Statutory Instrument 150 of 2023, which previously governed carbon trading in Zimbabwe. As carbon trading has emerged as a critical tool for reducing greenhouse gas emissions while fostering sustainable economic growth, Zimbabwe joins the global community in intensifying efforts to combat climate change through the promulgation of these regulations. This article provides an exposition of Zimbabwe’s new carbon trading regulations, focusing on their scope, structure, and key provisions as set out in the legal framework.
Key Highlights
- Expanded Interpretation clause including new terms integral to the new regulations.
- Establishment of the Zimbabwe Carbon Markets Authority (ZiCMA) and the National Grievance and Redress Mechanism (NGRM).
- Creation of a National Carbon Registry.
- Mandatory Registration for All Participants.
- New Revenue-Sharing Model.
- Alignment with Global Standards.
- Tighter Control on Carbon Credit Trading.
- Transition Rules for Existing Projects.
- Community Protection and Participation.
- Monitoring and Enforcement.
- Repeal of S. I. 150 of 2023.
- Comprehensive Schedules to provide for substantive, procedural, and documentary requirements.
Objectives of the New Regulations
- The objectives of the regulations as provided for in Section 3, are centred on establishing a robust framework for managing Zimbabwe’s carbon market. They aim to ensure proper oversight of carbon credit trading, uphold environmental integrity, and promote transparency in emissions accounting.
- A significant focus is placed on ensuring that carbon projects contribute meaningfully to sustainable development and Zimbabwe’s broader climate goals (as highlighted in paragraph (c)). The regulations also emphasize the importance of real, measurable, and additional emissions reductions, safeguarding both environmental and social outcomes. Furthermore, they ensure that carbon credits represent emissions that are not only accurately accounted for but also effectively kept out of the atmosphere for a scientifically reasonable duration, as outlined in paragraph (i).
Establishment of the Zimbabwe Carbon Markets Authority (Zicma) (ZICMA)
- Section 5(1) of the Regulations establishes the ZiCMA to serve as Zimbabwe’s Designated National Authority within the Climate Change Department, as specified by Article 6 of the Paris Agreement. Subsection (2) (a) to (z) outlines the Authority’s functions.
Establishment of the National Grievance and Redress Mechanism (Ngrm) (NGRM)
Section 6 (1) provides for the NGRM, wherein the Minister, his employee or other person designated through General Notice in the Gazette, shall be the recipient of any grievance by any aggrieved community or stakeholder in relation to any specific aspect of the operation or carbon market activities.
- An aggrieved person must submit a sworn affidavit detailing their grievance and send it to the Minister or relevant authority for processing.
- The Minister or relevant authority must promptly refer the grievance to an Advisory Grievance Redress Committee made up of experts in carbon market disputes.
- The functions of the Advisory Grievance Redress Committee are to:
- (a) receive and investigate carbon market grievances in a timely, confidential, independent, and transparent manner;
- (b) recommend resolutions to the Minister after completing investigations; and
- (c) refer cases involving sanctions to the Authority if the Minister accepts the recommendation.
Establishment of Zimbabwe Carbon Registry
- Section 7 of the regulations establish the Zimbabwe Carbon Registry (ZCR), which is managed by the Authority. It shall operate primarily as a virtual platform using advanced technology and is designed to fully comply with Article 6 of the Paris Agreement.
- Its core functions include recording all carbon projects, market participants, and licensed Designated Operational Entities; tracking the issuance and use of carbon credits and mitigation outcomes; and serving as the national registry for authorised international transfers.
- The ZCR also manages credit transfers, retirements, and fees, ensures regulatory compliance, prevents double counting, and supports integration with other approved registries. Carbon credits registered through the ZCR are treated as proprietary assets and may be freely transacted by their holders.
Eligibility Requirements for Participation in Carbon Market Activities
- Section 8 of the regulations sets out stringent eligibility requirements to ensure that only credible and capable participants engage in Zimbabwe’s carbon market. Project developers—whether local or foreign—must register with the Authority, meet financial and technical capacity standards, and disclose key project data. Foreign developers must also establish a local legal presence. Developers must be certified under a recognized carbon crediting standard or the Article 6.4 mechanism and must not have recent serious convictions or revoked registrations.
- All projects must be approved, registered on the Zimbabwe Carbon Registry, and demonstrate sustainable development, environmental integrity, and social safeguards. Projects must avoid ineligible areas or activities and align with national climate goals.
- Additionally, Designated Operational Entities (DOEs)—tasked with validation and verification—must be accredited by the Authority, demonstrate institutional capacity, maintain impartiality, and have no history of misconduct or revoked accreditation.
- These provisions collectively ensure the integrity, transparency, and credibility of Zimbabwe’s carbon market framework
Carbon Trading
- Under Section 9, any carbon credits or mitigation outcomes issued after August 18, 2023, are strictly prohibited from being used in commercial transactions unless they meet specific government-sanctioned criteria. These include formal recognition by the government, registration through the Zimbabwe Carbon Registry, issuance under the Article 6.4 Mechanism Registry, or transfer into the Zimbabwe Carbon Registry following payment of the designated Share of Proceeds. The regulations make clear that any unauthorized commercial dealings involving such credits—whether for monetary or non-monetary gain—constitute a criminal offence.
- Violators face severe penalties, including a fine at level 14, imprisonment of up to 12 months, or both, unless the credits are backed by a valid Certificate of Registration or Letter of Authorisation from the Government of Zimbabwe. This provision underscores the state’s commitment to controlling and legitimizing carbon market activities while safeguarding the integrity of its national climate strategy.
Mandatory Application and Registration Procedure
- Section 10 of the Regulations outlines the mandatory procedure for the application and registration of carbon credit projects in Zimbabwe. Individuals or entities must register with the Zimbabwe Carbon Markets Authority as Project Developers, General Account Holders, or Auditors, depending on their intended role, and meet all eligibility and fee requirements. Project Developers must first obtain a Developer Identification Number and submit a Project Idea Note (PIN) along with preliminary documentation, including environmental, social, and financial assessments.
- The Authority then reviews the PIN for compliance and classifies the project by type and scale, issuing either a Letter of No Objection or a Letter of Objection. If approved, the Proponent must conduct feasibility studies and submit a comprehensive Project Design Document (PDD) within 18 months. The Authority assesses the PDD for conformity with legal, environmental, and social standards, and may either issue a Letter of Rejection or, upon approval, a Certificate of Registration. This certificate formalises the project’s implementation rights and requires project commencement within 180 days, with continued compliance to monitoring and registry obligations. Failure to comply with timelines may result in lapsing or cancellation, though future applications remain permitted.
Monitoring, Reporting and Verification
Monitoring, Reporting, and Verification (MRV) are critical components for ensuring transparency, accountability, and environmental integrity in carbon market activities. Section 11 of the Regulations provides as follows:
- Proponents must maintain records of all activities/events affecting carbon sequestration or emissions reductions throughout the Certificate of Registration’s validity.
- In addition to project-specific requirements, proponents must:
- Report any significant reversals (over 5% of expected annual credit issuance) to the Authority within 14 working days of detection.
- Make all reasonable efforts to detect and report such reversals within 7 working days of occurrence.
- Submit a Regular Monitoring Report (RMR) and a Sustainable Development Report (SDR) within 180 working days of project implementation.
- Submit updated RMR and SDR annually by 31st December for each valid year of the Certificate of Registration.
- The Authority may conduct project monitoring with at least 48 hours’ notice, or without notice in urgent situations.
- Emission reductions must be authenticated per the approved measurement, reporting, and verification (MRV) schedule.
- All emissions reductions must be verified and authenticated by a licensed Designated Operational Entity (DOE).
Carbon Credit Issuance and Recognition
- Section 12 of the Regulations details the conditions for the issuance, recognition, and registration of carbon credits and mitigation outcomes in Zimbabwe, anchored in the Zimbabwe Carbon Registry (ZCR) and aligned with Article 6 of the Paris Agreement.
- Only Registered Proponents of approved projects may be issued credits, which must be verified by a licensed DOE and uniquely identified. Credits may be issued via the ZCR, an approved international registry, or transferred to the ZCR, subject to procedural and verification requirements. Proponents must submit a formal Request for Credit Issuance with all supporting documentation and fees, after which, if compliant, the Authority will issue a Certificate of Credit Issuance (CCI) within 14 days.
- Re-issued or transferred credits must preserve their traceability and be supported by documentation and cancellation on the original registry. The Authority ensures consistency, prevents double counting, and updates records in response to changes by original issuers. Incomplete or non-compliant requests may lead to a Letter of Refusal, without barring future submissions. Issued credits are subject to mandatory deductions—1% for the NDC, 2% to the National Buffer, and 30% to the National Transaction Account—before the remainder is credited to the Proponent’s ZCR account.
Authorisation of Internationally Transferrable Mitigation Outcomes
- Section 13 sets out the procedures for authorising the international use and transfer of verified mitigation outcomes in alignment with Article 6 of the Paris Agreement and decisions of the CMA. The Zimbabwe Carbon Market Authority may authorise mitigation outcomes only from approved projects with valid Certificates of Registration and Letters of Authorisation, and only if the outcomes are registered on the Zimbabwe Carbon Registry or the Article 6.4 Mechanism Registry. Authorisation, formalised through a Letter of Authorisation (LOA), is granted upon issuance, re-issuance, or transfer to the Zimbabwe Registry, specifying permitted uses—such as for another country’s NDC, for Other International Mitigation Purposes (OIMP), or both.
- Authorised outcomes must be used strictly within LOA terms, and a corresponding adjustment is applied at issuance or transfer. All LOAs are made public and may be revised or revoked if they compromise Zimbabwe’s climate objectives, provided the credits have not been used or transferred. Authorisations are reported to the UNFCCC, and any post-report authorisations must be included in Zimbabwe’s updated Initial Report before international transfer. All authorised mitigation outcomes are published on the Zimbabwe Carbon Registry.
Special Procedure for Participation in Article 6.4 of Paris Agreement
- This section establishes the procedural framework for legal and natural persons in Zimbabwe seeking to participate in the Article 6.4 Mechanism under the Paris Agreement. It requires participants to comply with local regulations and relevant CMA decisions. Following issuance of a Letter of No Objection, Proponents must notify the UNFCCC through a Prior Consideration Notification (PCN), after which the Authority submits a Statement of No Objection. Proponents must then conduct feasibility studies, submit a validated Project Design Document (PDD) within 18 months (with a possible 6-month extension), and include all necessary supporting documents and fees.
- The Authority reviews the PDD for environmental, legal, and safeguarding compliance. If non-compliant, the project is rejected and the UNFCCC is informed; reapplication remains an option. If approved, the Authority registers the project, issues a Certificate of Registration (CR) and a Letter of Authorisation, and submits the letter to the UNFCCC. The CR, valid for up to 15 years, authorises implementation, reserves the project area, and requires the Proponent to begin implementation within 180 days, maintain compliance, and operate through approved registries. Failure to commence may lead to CR cancellation. The Authority may also revoke approval if the project compromises national interests, without affecting previously used or transferred ITMOs.
Amendment of Registration
- Section 18 provides that the Zimbabwe Carbon Market Authority may amend a project’s registration either at the request of the Project Proponent or on its own initiative. Proponents may request amendments through the ZiCMA portal and pay the applicable fee, provided the changes do not undermine environmental integrity, sustainable development, or safeguards.
- The Authority may also initiate amendments to correct its own errors or in the public or environmental interest. In both cases, stakeholders must be notified and allowed to comment—14 days for Proponent-initiated changes and 7 days for Authority-initiated ones. Final amendments are made only after stakeholder input has been reviewed and responded to in writing.
Suspension or Cancellation of Registration and D.O.E Licenses
- The Minister is empowered, under Sections 19 and 20 of the regulations, to suspend or cancel either the registration of a carbon project or the licence of a Designated Operational Entity, respectively, where there is evidence of non-compliance or commission of specified offences as outlined in the regulations. Both sections grant project proponents a seven-day window to submit representations to the Minister for reconsideration of the decision.
General Provisions
Section 21 provides the overarching responsibilities and restrictions applicable to all participants in Zimbabwe’s carbon market. It establishes accountability for environmental and social impacts and sets conditions under which project-related rights, certifications, and accreditations may be transferred. This section stipulates that:
- Project Proponents are responsible for any social or environmental harm caused by their carbon projects.
- Letters, certificates, or accreditations issued under the carbon market may only be transferred if:
- The transfer is due to a change in control or full ownership transfer of the project/entity;
- The new owner complies with regulatory requirements;
- The new owner is a registered developer with a valid Developer Identification Number;
- The Authority approves the transfer.
Schedules to the Regulations
- The Schedules to these regulations provide the essential technical, procedural, and documentary framework necessary to ensure transparency, environmental and social integrity, and alignment with national and international climate goals. They include requirements for sustainable development, social and environmental safeguards, and stakeholder engagement (Schedules 1–4, 6). Project planning and documentation are guided by templates for the Project Idea Note, Design Document, and various assessment and reporting tools (Schedules 9–16). Environmental integrity and risk management are addressed through specific schedules (5, 11, 12), while financial procedures and obligations are covered in the schedules on fees and mandatory deductions (Schedules 7–8). Together, these schedules ensure transparency, accountability, and alignment with national and international standards.
The Carbon Trading (General) Regulations, 2025 outlined above establish a clear, transparent, and accountable system for carbon market participation in Zimbabwe. It sets rigorous standards for project registration, validation, issuance, and authorisation of mitigation outcomes in alignment with national priorities and international obligations under the Paris Agreement. Through comprehensive procedural requirements, institutional oversight, and adherence to sustainable development and environmental integrity principles, the framework ensures that carbon projects contribute meaningfully to climate action while safeguarding social and ecological interests. This system positions Zimbabwe to actively participate in global carbon markets while advancing its own development and climate goals.
If you are involved or interested in carbon trading, our firm offers comprehensive legal support and advisory services in navigating the regulatory and commercial aspects of carbon markets, including project registration, compliance, and benefit-sharing agreements. For assistance or more information, please contact info@mmmlawfirm.co.zw
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