PORTUGAL Trends and Developments Contributed by: Assunção Cristas, Catarina Pinto Correia, Carolina Vaza and Mariana Vicenia, VdA
mission emphasised more flexible, cross-sectoral pathways to 2040, moving beyond an exclusive focus on linear emissions cuts and residual “hard-to-abate” compensation. Notably, the Commission signalled for the first time the potential role of high-integrity international carbon credits within the EU’s 2040 goal architecture, subject to strict quality, governance and timing conditions. This represents a tonal shift towards system-wide optimisation, inter-sectoral co-operation and prag- matic use of market mechanisms to accelerate decar- bonisation while managing distributional impacts. This evolution dovetails with the EU’s push on nature finance. The Nature Credits Roadmap complements the CRCF framework by building a credible route to monetise biodiversity and ecosystem outcomes, not only as co- benefits of carbon projects but as standalone results in landscapes where carbon is not the primary lever. Together, the measures reflect convergence between climate and nature finance, greater emphasis on integrity, and a recognition that private capital must be mobilised at scale to bridge investment gaps. Biodiversity Credits and “Nature Credits”: Promise, Pitfalls and the State of Play Biodiversity and “nature” credits are gaining traction globally as voluntary mechanisms to reward measur- able improvements in ecosystem conditions, species outcomes, water regulation, pollinator habitats, soil health and other services. The EU’s Roadmap underlines that these tools are nascent: there is narrative momentum and a strong economic case, but there is not yet EU-level legis- lation establishing a compliance market, and meth- odologies are still being developed. The European Commission’s plan is to pilot, consult and co-develop methodologies and governance with member states, experts and stakeholders, with a view to assessing by 2027 whether dedicated EU legislation is necessary. Integrity risks are real. Lessons from the VCM – on additionality, permanence, leakage, baselines, safe-
guards and claims – must be internalised from the outset. The EU’s two-step certification-and-crediting model, combined with strong governance and transparency, is designed to build trust before scale. At the same time, stakeholders have raised concerns about poten- tial greenwashing, substitution of public with private funding, geographic inequities in project siting, and offsetting by proxy. The Commission’s emphasis on complementarity with public funding, non-offsetting use cases (eg, disclo- sures, procurement, risk management) and strict guardrails is intended to address these critiques. Portugal’s Potential Bridge to Nature Credits: Carbon Credits and Methodology Gaps Portugal’s VCM expressly envisions credits that deliv- er benefits beyond carbon, aligning national priorities such as forest resilience, fire risk reduction and marine ecosystem services with climate mitigation. The Portuguese VCM legislation has referenced the concept of “Carbon Credits+” to denote units with quantified co-benefits for biodiversity and ecosystem services. This conceptual framing could open a pathway to converge with the EU’s emerging nature credit archi- tecture; however, methodologies to quantify and verify biodiversity outcomes within Portugal’s VCM have not yet been adopted. The Technical Monitoring Commit- tee – which will validate methodologies by project type (forestry, agriculture, marine and others) – remains a critical piece of the institutional architecture, and the timing of its appointments and work programme will be pivotal for near-term market development. In practice, two near-term steps would help Portugal translate intent into investable opportunities. First, publishing the insurance and reversal-risk ordinance would unlock forest and other nature-based projects at scale. Second, ensuring that the VCM platform can register and transparently track co-benefits, con- fidentiality requests and linkages to EU methodolo- gies would create a credible interface with the CRCF
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