Who Owns the Carbon? Nigeria’s Carbon Market Needs a Public Register Before It Needs More Projects

In early October, CSR Reporters published an explainer on why Nigerians should care about carbon credits. This article takes the next step. If carbon credits matter, the harder question is who is checking them: which projects exist, who approved them, and what the communities hosting them were promised.

Nigeria has built an impressive policy structure for carbon markets. The evidence suggests the market on the ground is moving faster than the public record of it.

What Nigeria has built on paper

Nigeria finalised its Carbon Market Activation Policy in April 2025, which aims to unlock up to US$2.5 billion in climate investment by 2030 through high-integrity carbon credits. President Bola Tinubu has since approved a National Carbon Market Framework, which commentators say could generate between US$2.5 billion and US$3 billion a year by 2030. The framework is described as establishing a national carbon registry, requiring emissions reporting, and setting phased compliance measures aligned with Nigeria’s net-zero commitment for 2060.

The National Council on Climate Change (NCCC) leads implementation and oversees registration, monitoring and verification of projects against international standards, including those under Article 6 of the Paris Agreement. The policy also promises guidelines for fair and equitable benefit sharing, and some analyses describe the framework as requiring free, prior and informed consent and documented benefit arrangements before credits are registered.

On paper, that is a serious architecture. The question is how much of it works today.

What is happening on the ground

A June 2026 Guardian Nigeria analysis reported an estimated 350 carbon projects at various stages of development in the country. Its central finding is that neither communities nor investors can reliably say which of them are authorised, because no public registry of authorisation status exists.

The same report says that while the NCCC has begun issuing authorisations, the pipeline is long and institutional capacity limited. In the meantime, according to the report, some projects generate and sell credits on private standards without sovereign authorisation. Those credits, it says, trade at lower prices, carry no formal community benefit obligation under Nigerian law, and return nothing to the state in fiscal terms.

We have not independently verified the project count or the proportion operating without authorisation, and the Guardian itself attributes some figures to reports. But the central point does not depend on the exact number. A market of this size with no public list of what is in it is a market that communities cannot hold to account.

The rules themselves are not yet legible

The gap is not only about registries. Sources describing Nigeria’s framework disagree on basic points.

One legal analysis says that developers need a No-Objection Certificate from the NCCC before credits can be issued or transferred. Another, a law firm Q&A, reports that under the NCCC’s regulatory guidance, a No-Objection is not compulsory for the issuance and trading of credits. The same Q&A notes that the Climate Change Act does not currently contain explicit provisions on participation in the voluntary carbon market.

We are not in a position to say which reading is correct, and that is the point. If lawyers, developers and journalists cannot agree on what is required, a community in the path of a project has little chance of knowing its rights. A transparent system would answer these questions in a single published instrument.

Why communities carry the risk

A carbon project generates revenue from land, forests, cooking fuels, waste or energy that often sits in or around real communities. The questions CSR Reporters’ explainer raised remain unresolved in practice.

• Who owns the carbon rights, the community, the landholder, the developer or the state?
• Was consent genuine? Were people consulted in a language and format they understood, before the project began?
• Who receives the revenue, and how much, and how often?
• What happens when the project ends or the developer leaves?

Without a registry that records benefit arrangements, none of these can be checked from outside. Some commentators have proposed holding credit-sale proceeds in escrow until community benefits are verified. That proposal is still only an idea, but it reflects a real fear: that benefit-sharing without enforcement becomes performance.

A fair word for developers and government

It would be wrong to cast this as a story of bad actors. The Guardian analysis itself observes that developers working without authorisation are not necessarily circumventing the state. They may be working within the only functional structure available while the sovereign pathway exists in law and not yet in practice. Regulators, for their part, are building an institution from scratch with limited capacity.

An illustrative warning comes from elsewhere on the continent. The same report cites Kenya’s Koko Networks, a clean-cooking enterprise backed by a US$180 million World Bank guarantee, which collapsed when its letter of authorisation did not arrive in time. The lesson is that regulatory delay carries costs for everyone, including projects that were doing good work.

What a credible register would contain

The fix is not complicated, and it does not require waiting for every other piece of the framework. A public register maintained by the NCCC would let communities, investors and journalists see what exists. The Guardian analysis notes that Ghana and Kenya publish such registries.

What this means for business

For companies that buy credits, the registry gap is a due diligence problem. A credit bought from a project with no verifiable authorisation or community agreement can become a reputational liability, particularly for firms making public net-zero or sustainability claims. The National Carbon Market Activation Policy also contemplates entities using voluntary credits to meet carbon tax obligations, which raises the stakes on credit quality as that mechanism develops.

Sensible questions for any buyer to ask before purchase include:

• Is the project registered with the NCCC and, where relevant, authorised?
• Is there a signed, documented community benefit agreement, and can it be inspected?
• Who verified the emission reductions, and against which standard?
• Has anyone independently confirmed what the community received?

For developers, publishing this information voluntarily is a competitive advantage. It differentiates serious projects from speculative ones.

What to watch

• A delivery date for the public registry, which Nigeria’s framework commits to but, according to the Guardian, has not scheduled.
• Clarity on the No-Objection requirement, so that developers and communities work from the same rules.
• Published benefit-sharing guidelines, with enforcement mechanisms.
• Alignment of Nigerian credits with international schemes, including whether sovereign registries are recognised by aviation and other compliance markets.
• Community-level reporting, from independent organisations, on what projects have actually delivered.

The takeaway

Nigeria’s carbon market has real potential, and the government has built a framework to match. But a market in a country’s carbon assets should not be invisible to the people who live where those assets are. Before Nigeria adds more projects, it needs to show the ones it already has.

A carbon credit measures tonnes. A credible carbon market measures whether the people who host the project can see it, understand it and share in what it earns.