Carbon Trading (General) Regulations, 2025

These regulations repeal the Carbon Credits Trading (General) Regulations, 2023 (S.I. 150 of 2023) and replace them with a far more detailed regime for carbon projects and trading, made by the Minister responsible for Climate Change Management under the Environmental Management Act.

The Zimbabwe Carbon Markets Authority (ZiCMA) is established within the Climate Change Management Department as Zimbabwe's Designated National Authority under Article 6 of the Paris Agreement. It approves and registers carbon projects, issues letters of approval and authorisation, applies corresponding adjustments to prevent double counting, may declare areas ineligible for carbon projects where they would harm Zimbabwe's Nationally Determined Contribution or the national interest, and monitors and enforces compliance. A National Grievance and Redress Mechanism and the Zimbabwe Carbon Registry sit alongside it.

Trading is closed to anyone outside the system. Credits and mitigation outcomes issued after 18 August 2023 may not be sold, transferred or retired commercially unless formally recognised by Government, transacted through the Zimbabwe Carbon Registry, issued on the Article 6.4 Mechanism Registry, or transferred to a Registry account with the Share of Proceeds paid. Dealing in purported credits outside those routes is an offence carrying a fine of level 14 or 12 months' imprisonment, or both.

Everyone must register before participating: project developers obtain a Developer Identification Number, buyers and users a Registry Identification Number, and auditors an Auditor Identification Number. A project runs through a Project Idea Note, a Project Design Document, a non-permanence risk assessment, an environmental harm management form, a stakeholder and public consultation plan and evidence of free, prior and informed consent, before monitoring, reporting and verification and credit issuance.

The money is substantial. Registry accounts cost US$500 to create for a Zimbabwean general account and US$1 000 for a foreign one, US$2 500 and US$5 000 for local and foreign project developers, and US$2 000 for auditors, with annual maintenance fees of US$250 to US$2 500. A PIN costs US$3 000 to submit and a PDD US$5 000. Project registration costs US$20 000 for Category A, US$15 000 for Category B and US$10 000 for Category C, with interim registration at US$5 000 and amendments at US$5 000. Credit recognition costs 10 US cents a credit for voluntary market credits and 20 cents for authorised mitigation outcomes, issuance 20 cents a credit, internal transfers 1 per cent of transaction value and external transfers 2 per cent. An auditor licence costs US$50 000, renewed at US$20 000, and registration of an independent crediting standard US$20 000, renewed at US$10 000.

At issuance, mandatory deductions bite: 2 per cent of the credit volume goes to the National Buffer Account against reversals and over-crediting, 30 per cent goes to the National Transaction Account as the State's Share of Proceeds, and 1 per cent is automatically retired towards Zimbabwe's NDC. Buffer credits may not be transferred, sold or retired except to cover confirmed reversals or over-crediting.

Existing projects had 60 days from gazetting to comply. Those already operational under an approved independent crediting standard could be classified as Category 1 or Category 2 existing projects, continue provisionally on an Interim Certificate of Registration until 31 December 2025, and submit a Compliance Dossier at no additional cost before 30 June 2025; any existing project not recognised and classified by the Authority is deemed null and void and must cease implementation and credit issuance immediately.

Schedules set sustainable development, social safeguarding, environmental integrity and environmental safeguarding requirements, guidelines for stakeholder and public participation and free, prior and informed consent, and templates for every filing. Notably, a project's investment plan must show that at least 20 per cent of total investment goes directly into local communities — local employment and training, public infrastructure, education, healthcare and sanitation, environmental restoration — with an exit strategy for durability beyond the project's end.