Introduction
Article 6 of the Paris Agreement provides countries with mechanisms to cooperate with each other in reducing greenhouse gas emissions and other climate goals, especially in relation to meeting their Nationally Determined Contributions (NDCs). NDCs are the commitments that each country makes under the Paris Agreement to reduce emissions and adapt to the impacts of climate change. They are “nationally determined” because each country sets its own targets and measures, taking into account its circumstances, development needs, and capabilities.
NDCs can be expressed as unconditional or conditional targets. Unconditional targets are the actions and emission reductions a country commits to achieving using its own resources. On the other hand, conditional targets are the actions and emission reductions a country can achieve only if it receives adequate support from other countries or international institutions, such as climate finance, technology transfer or capacity building. In some cases, a country’s NDC may be entirely conditional, while for others (especially developing or Global South countries), it can be a mix of both conditional and unconditional targets.
The cooperation mechanisms under Article 6 take three main forms: (1) the transfer of mitigation outcomes between countries, (2) participation in a centralised crediting mechanism, and (3) engagement in non-market approaches. The first two form the basis of international carbon credit markets, as they involve the generation, transfer and use of tradable emission reduction units. The third focuses on collaborative action without credit trading. For countries such as Nigeria, all three mechanisms present opportunities to attract climate finance, gain access to technology and develop partnerships to meet its unconditional NDC and other climate goals.
To take part in these arrangements, countries need to have certain domestic systems in place. This usually begins with a national Article 6 framework that explains how the country will work with international carbon markets in support of its NDC. Such a framework can define the scope of cooperation, outline the types of activities and sectors that are eligible, set the rules for authorization and participation, and describe how accounting and reporting will be carried out. It must rest on a clear legal foundation that gives institutions the authority to approve projects, issue Internationally Transferred Mitigation Outcomes (ITMOs), apply corresponding adjustments, and manage cooperation agreements.
Alongside this, there must be institutional and administrative arrangements that set out responsibilities, establish approval processes, and provide for coordination between agencies. The right technical infrastructure is also essential. This includes a national carbon registry to track ITMOs and systems for monitoring, reporting, and verification (MRV), all of which are necessary to ensure environmental integrity and fulfil reporting obligations under the Paris Agreement. Collectively, these elements turn the high-level commitments of the Paris Agreement into a functioning national system capable of delivering real, measurable and verifiable results.
In March 2024, Nigeria released its draft national Article 6 framework, which is titled “Carbon Market Framework for International Carbon Market Participation” (the “Framework”). Although the Framework remains in draft form, a statement credited to the Minister of Environment and Ecological Management in November 2024 indicated that it had been completed and that the Government was in the process of establishing a national carbon registry. Since the final version has not yet been made public, this discussion focuses on the draft Framework.
Given the growing urgency for countries to mobilize climate finance, strengthen their mitigation capacity, and take advantage of international carbon market opportunities, it is important to assess the readiness of Nigeria’s Article 6 framework against practical implementation requirements. This article provides an overview of the Framework, outlines the progress Ghana has made with the implementation of its own national Article 6 framework, and draws lessons from Ghana’s experience to offer recommendations for Nigeria as it finalizes its Framework and moves towards implementation.
Overview of Article 6 of the Paris Agreement
As a background to discussing the Framework, it is useful to begin by expanding on the three cooperation mechanisms outlined in Article 6 of the Paris Agreement.
The Paris Agreement seeks to limit global temperature rise to well below 2°C, with efforts to keep it within 1.5°C. Its main tool for achieving this goal is the system of Nationally Determined Contributions (NDCs), which outline each country’s commitments to reduce emissions and adapt to climate impacts. Countries must progressively strengthen their NDCs through an ambition cycle of regular updates and transparent reporting.
Article 6 of the Paris Agreement provides countries with different options to cooperate internationally in achieving their climate targets, and these are specifically captured under Article 6.2, Article 6.4 and Article 6.8:
Article 6.2 allows countries to cooperate in meeting their climate targets by trading greenhouse gas emission reductions, known as Internationally Transferred Mitigation Outcomes (ITMOs), through bilateral or multilateral agreements. These mitigation outcomes can be generated by public entities or by private companies in the host country, provided the host government authorizes them for transfer. They may also be generated from projects that the acquiring country, or entities from that country, implement within the host country, as long as these projects are authorized by the host government. A host country can transfer these ITMOs to a buyer country, which counts them towards its NDC. Depending on the acquiring country’s domestic rules, authorized private companies may also use ITMOs to meet compliance obligations under national carbon pricing or trading schemes. To prevent double-counting, the host country applies a corresponding adjustment by deducting the transferred amount from the total it can record towards its own NDC, while the buyer country adds the same amount to its account. For example, if a host country achieves 110 million tonnes of emission reductions, including reductions from authorized private sector projects, but transfers 10 million tonnes as ITMOs, it can only count 100 million tonnes towards its NDC, and the buyer country records the 10 million tonnes towards its own target.
Article 6.4 creates a centralized international crediting mechanism under the Paris Agreement, overseen by the Article 6.4 Supervisory Body, which reports to the Conference of the Parties serving as the meeting of the Parties to the Paris Agreement (CMA). The CMA is the decision-making body for the Paris Agreement and is distinct from the Conference of the Parties (COP), which governs the broader UNFCCC. This mechanism allows approved mitigation activities to generate tradable credits, known as Article 6.4 emission reductions (A6.4ERs). These credits can be used by countries towards their NDCs or by authorized private entities for compliance in domestic schemes or voluntary climate commitments, depending on host and acquiring country rules. Private companies can participate directly as project developers, credit buyers, methodology developers, accredited verification bodies, or service providers. Activities must be registered in the Article 6.4 registry, following validation by an accredited entity and approval by the host country. Corresponding adjustments are applied if the credits are used for another country’s NDC.
Article 6.8 supports international cooperation that does not involve carbon trading or the transfer of mitigation outcomes. Instead, it focuses on non-market approaches, which are collaborative actions where the emphasis is on joint implementation, technology cooperation, and capacity support rather than market transactions. While non-market approaches do not produce tradable units, private companies can still participate by providing technology, financing, data services or training as part of government-led or multi-stakeholder programmes. The work programmed under Article 6.8 seeks to coordinate, facilitate, and track such activities so they complement, rather than replace, market-based approaches under Articles 6.2 and 6.4.
Overview of Nigeria’s Draft National Article 6 Framework
Nigeria’s draft Carbon Market Framework for International Carbon Market Participation (the “Framework”) articulates the broad ambition and guide for the country’s engagement in international carbon markets under Article 6 of the Paris Agreement. Among other things, the Framework identifies the main benefits Nigeria seeks from participating in international carbon markets, including enhanced mitigation across sectors, sustainable development, technology transfer, stronger international cooperation, and increased finance for climate action. It also recognizes key risks, such as overselling mitigation outcomes and jeopardizing NDC achievement, double counting, high implementation costs, reputational concerns, and lack of clarity on the role of the voluntary carbon market (VCM) in relation to Article 6 activities.
With these benefits and risks in mind, the Framework aims to position Nigeria to participate effectively in international carbon markets, capturing opportunities while managing potential downsides. It confirms Nigeria’s intention to take part in all three components of Article 6 of the Paris Agreement as highlighted above. Alongside these mechanisms, the Framework also addresses participation in the voluntary carbon market (VCM), recognizing its value in mobilizing finance and driving mitigation efforts beyond the scope of compliance markets.
To provide clarity, the Framework distinguishes between VCM activities that request a corresponding adjustment and those that do not. In the case of a corresponding adjustment, the host country deducts the authorized volume of mitigation outcomes from its own NDC balance, allowing only the buyer country or entity to claim them. This can be requested before a project begins, in which case it must follow the same eligibility, approval, and authorization processes as Article 6.2 activities, or after credits have been verified but not yet issued, in which case a letter of authorization is required.
Projects with a corresponding adjustment are excluded from Nigeria’s NDC accounting and credited to the buyer, which ensures there is no double counting. Such projects tend to appeal to buyers seeking high-integrity credits recognized under the Paris Agreement framework. By contrast, VCM activities without a corresponding adjustment remain outside the NDC accounting framework. In this case, the emission reductions are retained within Nigeria’s own NDC tally, while buyers, often companies meeting climate commitments, can still use the credits to demonstrate environmental benefits in corporate reporting.
Institutional and governance arrangements are central to the Framework, and it sets out a range of institutions and clearly defines the roles they are to perform in supporting Nigeria’s participation in Article 6 mechanisms.
First, there is the Carbon Market Oversight Body (CMOB), whose role is designated/assigned to the Intergovernmental Committee on Carbon Market Activation. It is responsible for providing strategic oversight and policy direction, reviewing and approving standards and methodologies, advising on legislative or regulatory changes, and ensuring that market activities align with Nigeria’s climate and development objectives. The CMOB also serves as a platform for inter-ministerial coordination, bringing together relevant government agencies to address policy and operational matters.
Secondly, there is the Carbon Market Office (CMO), which is a new unit to be established within the Secretariat of the National Council on Climate Change. It serves as the operational arm of the Framework, managing the day-to-day implementation of Article 6 activities. Its functions include receiving and reviewing project proposals, issuing letters of eligibility and authorization, operating and maintaining the national carbon registry, applying corresponding adjustments, and tracking the generation and transfer of ITMOs. The CMO is also responsible for compiling and submitting reports under the Enhanced Transparency Framework, ensuring that all transactions and adjustments are recorded accurately and in line with the requirements of the Paris Agreement.
Further, the Federal Ministry of Industry, Trade and Investment is designated as the official signing entity for cooperative agreements under Article 6.2. This role ensures that all bilateral and multilateral arrangements are entered into on behalf of the Nigerian government and are consistent with national trade and investment policies.
In addition, to strengthen technical capacity, the Framework proposes the establishment of a Technical Committee to provide subject-matter expertise on methodologies, accounting, MRV processes, and sector-specific mitigation opportunities. This committee supports both the CMOB and the CMO in making informed, evidence-based decisions.
The Framework also provides for broader stakeholder participation, including engagement with civil society organizations, private sector actors, research institutions, and financial institutions. These stakeholders can contribute through consultations, advisory roles, and partnerships, helping to ensure that Nigeria’s Article 6 participation is inclusive, credible, and capable of delivering both climate and development benefits.
It is noted that the legal basis for the Framework is the Climate Change Act 2021. The Act, alongside Nigeria’s ratification of the Paris Agreement, provides the legislative foundation for Article 6 participation. The Climate Change Act gives the National Council on Climate Change the power to coordinate all climate change-related activities, issue regulations, oversee market operations, and ensure compliance with international obligations. This statutory authority means that the Framework will operate within a recognized legal mandate, providing certainty to both public and private actors engaging in Article 6 activities.
The Framework envisages the development of a Manual of Procedures, which is intended to set out detailed processes for the full operationalization of Article 6 participation in Nigeria. This Manual will describe, step-by-step, how cooperative approaches will be authorized, including the procedures for issuing eligibility and no-objection letters, approving and verifying activities, issuing and tracking ITMOs, applying corresponding adjustments, and fulfilling Article 6 reporting obligations. It will also outline procedures for stakeholder consultations, the submission and review of project documentation, and the timelines for decision-making. Further, it will address administrative fees, benefit-sharing arrangements, the allocation of revenues from carbon market participation, and required contributions to adaptation funding and overall mitigation. The Manual will serve as the primary operational reference for government agencies, project developers, and other participants, ensuring that processes are transparent, predictable, and in line with both domestic regulations and international standards.
In terms of how the Framework and its supporting instruments will come into effect, the Framework provides that an Executive Order will be issued by the President to give it legal force and direct its implementation. This Executive Order will confirm the mandates of the Carbon Market Oversight Body, the Carbon Market Office, and other designated institutions, and will formally adopt the Manual of Procedures as a binding operational document.
Ghana’s Implementation Progress Under Article 6.2
Ghana released its own national Article 6 framework back in 2022 and has since advanced to full implementation. It has signed bilateral cooperation agreements, built the necessary institutional and technical systems, and started operationalising its international carbon market participation. The framework sets clear eligibility rules for mitigation activities/projects that it covers. If a mitigation activity falls within Ghana’s NDC, it can only be authorized for ITMO transfer if it is part of the conditional targets, with unconditional targets excluded. If a mitigation activity falls outside the NDC, it may still be eligible for ITMO transfer, provided it is included in Ghana’s most recent national greenhouse gas inventory and agreed upon with the partner country.
A recent progress report issued in March 2025 shows that Ghana has made impressive progress in translating its policy into action. A major step forward was the passage of the Environmental Protection Act, Act 1124 of 2025, which provides a firm legal basis for international carbon market participation. The Act formalizes key aspects of the carbon market architecture. These include the legal establishment of the Ghana Carbon Registry, the creation of a greenhouse gas mitigation fund, and the formation of a carbon market committee with defined oversight responsibilities. The legislation also mandates the EPA to issue regulations needed to support operationalization.
On the institutional side, the Carbon Market Office has continued to serve as the focal point for implementation. In 2024, it published its second annual progress report and began work on applying the new provisions under the 2025 Act. The Office has also taken the lead on coordination and outreach, supporting both public and private stakeholders as they engage with the market.
Ghana’s international cooperation portfolio has grown. It now includes agreements with five countries: Switzerland, Sweden, Singapore, South Korea and Liechtenstein. The agreement with Switzerland, signed in 2020, has entered the implementation phase. Twelve projects supported by the KliK Foundation are underway and are expected to generate around 8 million ITMOs by 2030. These projects are projected to mobilize up to 1.1 billion US dollars and create over 5,000 green jobs. Newer agreements with Sweden and Singapore have also advanced. Sweden has begun project procurement, while Singapore has launched a project call and conducted a market mission in Ghana. South Korea has completed technical negotiations and is awaiting cabinet-level clearance. Beyond sovereign partnerships, Ghana is also engaging with private entities such as British Petroleum and Mercuria Energy to generate Article 6-aligned credits. The Carbon Market Office has also received 25 voluntary carbon market projects, 20 of which are seeking authorization for international transfer.
The number of projects in Ghana’s carbon market pipeline now stands at 70, with a combined potential of 402 million tonnes of CO₂ equivalent in mitigation outcomes. Three projects have already been authorized for transfer, amounting to 5.9 million tonnes of ITMOs. These include projects in sustainable rice cultivation, waste-to-compost, and improved cookstoves. The Ghana Carbon Registry, which now has a formal legal basis under Act 1124, has onboarded 17 projects as of the end of 2024. Clean cooking remains the dominant project sector, followed by nature-based solutions and electric mobility.
In terms of infrastructure, the Ghana Carbon Registry has expanded its capabilities. It underwent an assessment by the World Bank to verify readiness for linking with other registries, including the CAD Trust meta-registry. Operational manuals are being developed with support from UNDP, and the target is to increase project listings on the registry to 45 by the third quarter of 2025.
Ghana has also completed its international reporting obligations. It submitted its initial Article 6 report to the UNFCCC in 2023 and followed this with a biennial transparency update in 2024. These submissions demonstrate the country’s technical readiness and commitment to transparency in line with international rules.
The Carbon Market Office has remained active in public outreach and partnership building. In 2024, it participated in 26 outreach engagements, including a series of events focused on clean cookstove technologies. Ghana is also playing a leadership role in international forums, including the Climate Market Club, the Article 6 Implementation Partnership and the West African Alliance on Carbon Markets. It has hosted and supported peer learning, including through a visit by a Tanzanian delegation and continued engagement with international partners such as the KliK Foundation, Singaporean officials and USAID.
Lessons and recommendations for Nigeria
Ghana’s experience offers several practical insights that Nigeria can apply as it finalizes its Article 6 Framework and moves towards implementation. These lessons span legal foundations, institutional arrangements, project pipelines, technical systems and international cooperation.
A foundational key issue Nigeria must address is transparency throughout the process. It does not reflect well that certain documents indicate that the Article 6 Framework has been finalized, yet the text remains inaccessible to the public. Transparency is fundamental to building trust among stakeholders, attracting credible partners and ensuring that domestic and international actors are confident in the country’s carbon market approach. Ensuring timely public access to relevant laws, policies and operational guidance is a basic but important step towards accountability and engagement.
Another key insight is the importance of embedding the Article 6 Framework in legislation. Ghana’s Environmental Protection Act provides a clear legal mandate for carbon market participation. It defines the institutions, procedures, registries and funds that guide implementation. In contrast, Nigeria’s draft Framework is expected to be implemented through a presidential Executive Order. While this approach may offer administrative speed, Executive Orders in Nigeria have often raised questions about legal durability and possible overlap with legislative authority. To address these concerns, Nigeria could consider either amending the Climate Change Act to formally anchor Article 6 implementation or issuing the Framework and its supporting documents as regulations under the Act. Both options would offer a firmer legal foundation and provide greater clarity for stakeholders.
Legal backing alone is not enough. Institutional effectiveness also plays a critical role. Ghana has clearly assigned responsibilities to its Ministry of Environment and the Carbon Market Office within the EPA and these institutions are functioning, adequately staffed, and financially supported. Specialized committees have also been set up to provide review, policy advice and technical oversight. In Nigeria, roles have been identified in the draft Framework, but these need to be matched by real capacity. The institutions charged with implementation must have trained personnel, sufficient funding, and well-developed systems in place. Without this level of readiness, institutional clarity will not lead to effective delivery.
Ghana’s framework also shows the value of detailed operational guidance. Its technical schedules set out the procedures and requirements for key elements such as eligibility, baseline methodologies, registry operations, reporting, and fees. These details remove uncertainty for both domestic and international actors. Nigeria should take a similar approach. The Manual mentioned in the draft Framework should be developed as a comprehensive guide. It should explain in practical terms how authorization will work, how projects will be approved, how activities will be treated if they fall outside the NDC, and how the system will apply to conditional and unconditional NDC targets.
Another important area is technical infrastructure. Ghana has invested in a national registry that is both legally recognized and technically capable of managing Article 6 transactions. It has taken steps to ensure the registry can interact with international systems. Nigeria must give equal attention to its own registry. Operational readiness, secure architecture, data traceability, and international compatibility will all be essential. The registry will not only support domestic processes but will also demonstrate transparency to international buyers and regulators.
Progress also depends on early engagement. Ghana began entering into bilateral agreements and onboarding projects well before completing all legislative steps. It made use of partnerships with countries such as Switzerland and Singapore and with institutions such as UNDP and the World Bank, to build capacity and test its systems. Nigeria should take advantage of similar opportunities. Identifying early partners, supporting pilot projects and using these to refine procedures can help accelerate implementation.
Finally, Nigeria should ensure that its participation in Article 6 supports its development priorities. This means selecting projects that align with national goals, applying safeguards that promote environmental and social outcomes and ensuring that corresponding adjustments and reporting obligations do not undermine the country’s own mitigation targets. Voluntary carbon market activities should be integrated in a way that complements national objectives rather than working in parallel.
Conclusion
Nigeria’s draft Article 6 Framework sets out an approach for engaging in international carbon markets and non-market cooperation in a way that could deliver both climate and development gains. Ghana’s progress shows that translating such a framework into real outcomes depends on firm legal backing, effective institutions, clear operational guidance, robust technical systems, and early international engagement. If Nigeria strengthens these areas and maintains transparency, it will be well placed to attract credible partners, mobilize finance, and advance its unconditional NDC targets while safeguarding environmental integrity.
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Source : Linkedin Page of Wola Joseph-Condotti
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