Executive summary

Cuba has no prior experience with mangrove or other nature-based carbon projects on the voluntary carbon market, but it has established a comprehensive national framework governing all initiatives seeking to participate in the VCM. Resolution 106/2025 confirms State ownership of mangroves and the carbon they store and authorizes only state-approved use or management rights for private or community actors. Project developers must obtain government authorization, align proposals with national climate and development priorities, present a full Measuring, Reporting, and Verification (MRV) plan with third-party verification accredited by the National Accreditation Body of Cuba, and often secure an Environmental Impact Assessment (EIA) and an environmental license. Public consultations are mandatory when an EIA is required and are also a prerequisite for carbon-market approval. All projects and credit transactions must be recorded in a national administrative control system that functions as a carbon registry, although the registry is not public. The regulation establishes no standard benefit-sharing mechanism and only partially defines project-level carbon rights in mangroves.

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In mangrove areas, land and carbon governance remain fully centralized. Mangrove forests form part of Cuba’s state-owned natural resources and are inalienable. The State may grant use, management, or usufruct rights over these areas, but it does not transfer ownership of the mangroves or their carbon. Private and community entities can participate only through state-approved arrangements that support conservation and restoration objectives in the coastal public domain. Resolution 106/2025 reiterates that the State owns all carbon captured or retained in ecosystems and empowers the Ministry of Science, Technology and Environment to issue, allocate, register, authorize the use or transfer of, and, if necessary, cancel certified units. In practice, what can be secured, transferred, or revoked are project authorizations, certified units, and contractual benefit rights, not ownership of the underlying carbon stocks. However, the regulation leaves key issues unresolved, including how units are allocated among project partners, how benefit-sharing should be structured, and how risk and liability for reversals are assigned in mangrove projects.

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Overall, Cuba has ambiguous enabling conditions for blue carbon projects: it offers a single, mandatory national framework with clear State ownership of mangroves and carbon, centralized authorization, and compulsory MRV and registration, but lacks practical VCM experience, a public registry, and predictable rules on project-level rights and revenue-sharing. For project development and investment, this means legal security depends on navigating State-controlled land and carbon rights, completing several layers of approval, and negotiating benefit-sharing and credit allocation on a case-by-case basis.

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