The Green Economy and Climate Change (Carbon Market) Regulations, 2026 establish Zambia’s comprehensive legal and institutional framework for carbon credit generation, authorization, issuance, and trading. Published on 9 January 2026, the regulation operationalizes Zambia’s participation in both international carbon markets (Article 6 of the Paris Agreement) and the voluntary carbon market, while ensuring environmental integrity, transparency, and alignment with national development priorities.
Institutional Framework
• Zambia Environmental Management Agency (ZEMA): Acts as the central implementing authority and registry administrator; oversees monitoring, verification, and issuance of credits .
• Director (Government authority): Grants authorizations and oversees approvals.
• Technical Committee: Evaluates project concept notes and proposals
• Integration with the National Carbon Registry under the MRV system.
Project Eligibility and Exclusions
Ineligible activities include:
• Fossil fuel lock-in projects
• Certain industrial gas projects (e.g., HFC-23, adipic acid N₂O)
• Nuclear energy
• Large-scale hydropower (20 MW)
Projects need to ensure alignment with environmental integrity principles
Project Development Cycle
1. Concept Note Stage
• Project developer submits a concept note to the Director, with applicable fee.
• Content requirements:
- Demonstrate additionality, regulatory surplus, and financial viability.
- Confirm project is not ineligible.
- Show contribution to SDGs and national development plans.
- Include (where applicable) a community development and benefit-sharing agreement.
• Administrative review timeline: Within 5 days of receipt, the Director must notify the developer whether the concept note is duly completed.
• Referral timeline: If complete, within 5 days, the Director refers the concept note to the Technical Committee.
• Technical evaluation outcome: If approved, the Technical Committee issues a letter of no objection (for projects requesting corresponding adjustment), or a letter of endorsement (for projects not requesting it)
2. Project Proposal Stage
• Submission deadline: Project developer must submit a project proposal within 90 days of receiving z letter of no objection.
• Validation requirement: Proposal must be validated by an accredited verifier before submission.
• Completeness check timeline: Within 5 days of receipt, the Director notifies whether the proposal is duly completed.
• Evaluation timeline: If complete, within 10 days, the Director submits the proposal to the Technical Committee.
• If approved, the Technical Committee issues a formal project approval
3. Post-Approval Notification
• Start of activity notification: Within 10 days of commencing the carbon credit generation activity, the project developer must inform ZEMA of:
- Project start date
- Intended verification process
4. Monitoring and Verification Cycle
• Monitoring: Ongoing obligation by project developer, including the preparation of monitoring reports.
• Verification: Independent verifier issues a verification statement confirming emission reductions achieved, credits to be issued, and SDG contributions.
• Submission to ZEMA: Developer submits the verification statement and monitoring report.
• ZEMA assessment timeline: Within 30 days of receipt, ZEMA must conduct quality assurance and completeness checks.
- If satisfactory, ZEMA informs the Director to proceed with issuance
- If not satisfactory, ZEMA conducts a ground inspection and submits findings within 10 working days. The Director then notifies developer within 5 days, requesting corrections
- Resubmission: Developer submits revised documents following notification.
5. Issuance Process
Two pathways:
• Article 6 / Corresponding Adjustment: Issued by ZEMA as mitigation outcomes and requires consistency checks with monitoring and verification data.
• Voluntary Market Credits: Issued through external registries where projects are registered .
Process for Article 6 projects:
• Request submission: Developer requests issuance via the National Carbon Registry.
• ZEMA review timeline: Within 5 days, ZEMA assesses consistency with monitoring and verification.
• Confirmation timeline: Within 1 day of confirmation, ZEMA informs the Director.
• Issuance instruction timeline: Within 3 days, the Director instructs ZEMA to issue credits.
• Final issuance timeline: Within 5 days, ZEMA issues the carbon credits.
Authorization and Market Participation
• Developers must obtain a Certificate of Authorization to trade.
• Two participation routes:
- With corresponding adjustment (Article 6 transactions)
- Without (voluntary carbon market)
• Authorization required: At concept or project proposal stage depending on project type.
Transfer of Carbon Credits
• Transfers conducted via the National Carbon Registry.
• For Article 6, credits become Internationally Transferred Mitigation Outcomes (ITMOs) and they require corresponding adjustments recorded in the registry
• First transfer is conditional on payment of share of proceeds, and will be considered as follows:
- NDC achievement: First international transfer.
- Other International Mitigation Purposes (OIMP): Use or cancellation.
• Voluntary credits: Transferred via voluntary market registries
Share of Proceeds Benefit Sharing
• Article 6 transactions (with corresponding adjustments) require a mandatory payment of share of proceeds to the government through Community development and benefit-sharing agreements
• Not applicable to projects under Paris Agreement mechanisms without corresponding adjustment
Safeguards and Integrity Measures
Strong safeguards include:
• Additionality and baseline requirements
• No double counting (registry-based tracking)
• Leakage and non-permanence risk management
• Alignment with IPCC methodologies
• Mandatory stakeholder consultations
Registry and Transparency
• Establishes a National Carbon Registry for tracking all carbon credit generation activities and recording issuance, transfers, and corresponding adjustments.
• Integrated within the national MRV system.
Compliance, Enforcement, and Penalties
• Existing projects must comply with new regulations within one year of entry into force.
• The Director may issue compliance orders for violations.
• Penalties include fines and imprisonment (up to 5 years).
Validation and Verification Body:
A Verifier (which corresponds to a Validation and Verification Body or VVB) must be registered with the government and hold active international accreditation, rather than a specific national accreditation.
Recognition of methodologies by regulation:
The regulation recognizes the Verra, Gold Standard (GS) as a framework and its methodologies as valid tools for project development and impact assessment.
Registration of the PD or project with the national registry for VCM and Article 6:
The regulations requires the project for VCM with Corresponding Adjustment and Article 6 to be registered in the national registry.
Approval for listing, issuance, trade, authorisation and corresponding adjustment:
The regulations establish a strict hierarchy of approvals required at various stages of a project's lifecycle, from initial concept to final trade and corresponding adjustment (CA). Before a project can be officially recognized or proceed to full development, it must receive preliminary approval. Issuance of carbon credits requires a multi-step verification and government affirmation process. Trading is contingent upon holding a specific legal permit and authorization and corresponding adjustment involves explicit government declarations.
Annexes
First Schedule (templates and forms)
• Concept Note (MAIN)
• Community Development and Benefit Sharing Agreement
• Letter of No Objection: Concept Note
• Letter of Endorsement: Concept Note
• Project Proposal
• Approval: Project Proposal
• Application to Trade in Carbon Credits
• Certificate of Authorisation to Trade In Carbon Credits
• Request for Issuance of Carbon Credits as Mitigation Outcomes
• Application for Registration as a Verifier
• Declaration for Registration as a Verifier
• Certificate of Registration as a Verifier
• List of National Experts
• Compliance Order
Second Schedule
• Prescribed Fees
Third Schedule
• Share of Proceeds
Fourth Schedule
• List of indicators
