Executive summary
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Brazil does not yet host mangrove carbon projects in the Voluntary Carbon Market (VCM), but it has a well-established nature-based carbon market with more than 200 registered projects. Recent disputes involving some forest carbon projects and Indigenous Peoples and traditional communities have increased regulatory scrutiny, particularly around consultation processes, transparency, and compliance with social safeguards. These developments highlight the importance of robust community engagement and legal compliance for future carbon project development.

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Brazil has established a comprehensive legal framework for carbon markets through Law No. 15.042/2024, creating the Brazilian Greenhouse Gas Emissions Trading System (SBCE). The framework requires approved methodologies, independent verification, benefit-sharing arrangements, and Free, Prior and Informed Consent (FPIC) for projects involving Indigenous Peoples and traditional communities. Additional safeguards introduced through Resolution No. 19/2025 strengthen transparency, community participation, and protection of traditional livelihoods. However, several core elements of the system, including the Central Registry, detailed MRV procedures, and operational rules for international transfers under Article 6, remain under development. As a result, developers seeking to do international transactions should closely monitor forthcoming regulations, as future registry, authorization, and compliance requirements may affect project implementation and carbon credit transactions.
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Brazil provides a generally supportive framework for land tenure and carbon rights for blue carbon projects. Mangroves are protected as Permanent Preservation Areas, but projects are permitted on public, private, Indigenous, and other community-managed lands where consistent with environmental legislation. Public forests may be managed through private or community concessions, while carbon rights are clearly linked to ownership, concession, or legitimate usufruct and can be transferred through contractual arrangements. Strong legal protections also ensure that Indigenous Peoples and traditional communities retain significant carbon benefits and decision-making authority through mandatory benefit-sharing and FPIC requirements. However, land tenure challenges, including overlapping claims, lengthy land regularization processes, and weak enforcement in some areas, can increase project complexity and investment risk.
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Overall, Brazil has ambiguous enabling conditions for blue carbon projects: the country has a robust legal framework with clear rules on carbon rights, benefit-sharing, FPIC, and project eligibility. However, key operational elements –including the national carbon registry, detailed MRV regulations, and Article 6 authorization procedures –remain under development, creating regulatory uncertainty for projects targeting international carbon markets. At the same time, stronger enforcement of social safeguards reinforces the need for transparent governance and meaningful engagement with Indigenous Peoples and traditional communities. While Brazil presents significant long-term opportunities for blue carbon investment, project developers and investors should closely monitor the implementation of the SBCE before making long-term commitments.