Executive Summary
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Mexico has an active presence in the Voluntary Carbon Market (VCM) with over 200 nature based carbon credit projects, including nine mangrove projects certified under Verra and Plan Vivo. The country has a long history in the VCM, as demonstrated by Scolel'te, the world's first voluntary carbon credit project. However, despite this strong precedent, regulatory clarity remains a challenge. While trading carbon credits internationally is legal under Mexico's Climate Change Law, specific requirements for VCM transactions are still under development. Draft regulations propose a national voluntary carbon registry, a price
index, and measures to prevent double counting. However, authorization procedures remain unclear, and no laws currently mandate project registration, benefit-sharing agreements, or Free, Prior, and Informed Consent (FPIC) for Indigenous Peoples and Local Communities. Without well-defined authorization processes, projects may struggle with uncertainty in legal compliance, slow development, and deterring investment. Additionally, the absence of benefit-sharing requirements could lead to disputes over revenue distribution, increasing social and financial risks for projects operating on communal or private lands.
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Land tenure laws allow diverse ownership of mangrove forests, including private, communal (ejidos), and state-managed lands. While mangroves are legally protected, private and community entities can obtain concessions for sustainable management and carbon credit projects. As legal entities, Ejidos can engage in carbon credit initiatives with assembly approval, but legal processes for these transactions can be complex, requiring community consensus. In rural areas, land registration and ownership transfer challenges can create legal uncertainties for carbon projects, mainly when incomplete or outdated land records exist. The General Wildlife Law grants landowners the right to sustainable use of flora and fauna. Additionally, while carbon rights are implicitly recognized through multiple legal instruments, Mexico lacks a specific law defining them and transparent mechanisms for their transfer or enforcement. This gap leaves project developers without legal certainty regarding ownership of emission reductions, complicating carbon credit transactions and increasing the risk of legal disputes.
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Overall, Mexico has ambiguous enabling conditions for blue carbon projects. Its strong VCM presence and diverse land tenure models support project development, but unclear regulations, authorization procedures, and carbon rights create uncertainty for investors. Project risks rise without defined ownership structures and oversight, deterring long-term investment. Clarifying the national carbon registry, carbon rights, authorization processes, and securing land tenure and benefit-sharing mechanisms is crucial to strengthening Mexico's blue carbon market and promoting sustainable mangrove conservation.

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