PORTUGAL Trends and Developments Contributed by: Assunção Cristas, Catarina Pinto Correia, Carolina Vaza and Mariana Vicenia, VdA
VdA Rua Dom Luis I, 28 1200-151 Lisboa Portugal Tel: +351 2131 13400 Email: fvda@vda.pt Web: www.vda.pt
Portugal’s Voluntary Carbon Market Framework Enters 2025 With Momentum – a New European Push for Biodiversity and Nature Credits Portugal’s Voluntary Carbon Market (VCM) framework, established by Portuguese Decree-Law 4/2024, pub- lished on 5 January 2024, continues to evolve, with key implementing ordinances now in force. On 27 November 2024, the European Union (EU) adopted Regulation (EU) 2024/3012, establishing a Union cer- tification framework for permanent carbon removals, carbon farming, and carbon storage in products. In 2025, the European Commission published a dedi- cated Roadmap towards Nature Credits, signalling the EU’s intention to structure high-integrity, market- based tools for financing biodiversity and broader ecosystem services. In parallel, the Commission’s proposal to amend the European Climate Law to enshrine a net greenhouse gas emissions reduction target of 90% by 2040 has reframed the narrative around flexibility, cross-secto- ral co-operation and the role of market instruments. Together, these developments position Portugal to play an early-mover role as high-quality credits – carbon, biodiversity and broader “nature credits” – converge under more integrated climate-and-nature finance architectures. Portugal’s VCM: Legal Architecture, Implementing Measures and Open Questions Decree-Law 4/2024 created the legal basis for a national VCM designed to support emission reduc- tions and removals while enhancing transparency
and environmental integrity. Building blocks adopted in October 2024 include ordinance-level rules on veri- fier qualification, the registration platform and fees for market operators. The national energy agency ADENE was designated as the qualification management entity for independ- ent verifiers under Ordinance 240/2024, with higher education, relevant experience, audit training, a quali- fying examination and professional association mem- bership (when applicable) among its core criteria. This function is crucial to the market’s monitoring, report- ing and verification integrity. Ordinance 241/2024 defines the operational require- ments for the public registration platform, which is central to market transparency. The platform must support: • account-opening by market agents; • registration of projects and credits; • issuance and cancellation of credits; • submission of monitoring reports by promoters; • initial and periodic verification filings; and • submission and management of proposed meth- odologies. Ordinance 239/2024 sets the fee schedule for open- ing and maintaining accounts, registering projects and programmes, trading credits and submitting method- ologies. A reduced EUR500 fee applies to methodol- ogy approvals submitted by 31 December 2026, with standard fees becoming applicable thereafter. This
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