Executive Summary
While Brazil does not currently host mangrove projects in the Voluntary Carbon Market (VCM), it has over 100 nature-based carbon credit projects, including 138 under Verra's Standard and one under the Gold Standard. However, recent legal challenges have raised concerns over Indigenous land rights and project transparency. The Public Prosecutor's Office of Amazonas has called for the suspension of all carbon credit activities involving Indigenous and traditional communities, citing a lack of consultation and potential rights violations. The government has addressed these regulatory and governance challenges through recent legislative changes.
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The Brazilian government has established a regulatory framework for its National Carbon Market, requiring all carbon credit projects—including those in the VCM—to comply with strict guidelines. Project developers must adhere to methodologies accredited by the Brazilian Greenhouse Gas Emissions Trading System (SBCE) and register credits in a central registry. Federal authorization is required for the international transfer of credits, though specific procedures are still under development. Additionally, Brazil mandates benefit sharing agreements for projects on Indigenous and traditional lands, ensuring these communities receive a significant portion of revenues. Free, Prior, and Informed Consent (FPIC) is a legal requirement, with developers funding the consultation process. The government has also introduced Monitoring, Reporting, and Verification (MRV) requirements, although detailed implementation rules are still being defined.

Land tenure complexities present both opportunities and challenges for blue carbon projects. While mangroves are classified as Permanent Preservation Areas (APPs), they exist under a mix of public and private ownership, with Indigenous and Quilombola communities holding specific rights. Brazil allows forest concessions in public mangroves, enabling private and community-led carbon credit projects. However, land governance issues, including unclear property rights, land grabbing, and bureaucratic delays, create obstacles to project implementation. Carbon rights in Brazil align with land tenure, allowing landowners, communities, and concession holders to generate and trade credits. The National Carbon Market explicitly recognizes various stakeholders—including Indigenous Peoples, settlers, and extractivist communities—as eligible carbon rights holders, reinforcing their ability to engage in the carbon market.
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Overall, Brazil has favorable enabling conditions for blue carbon projects. While the country has a structured regulatory framework, uncertainties persist due to legal disputes and evolving government policies. The recent legal actions against nature-based carbon projects underscore the need for more precise guidelines, stronger governance, and improved consultation processes to support the sustainable development of blue carbon initiatives.
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