Environmental Law 2025

PORTUGAL Trends and Developments Contributed by: Assunção Cristas, Catarina Pinto Correia, Carolina Vaza and Mariana Vicenia, VdA

framework and, in due course, with any future EU nature credit registry. As the EU brings forward CRCF methodologies for carbon farming with mandatory biodiversity co-bene- fits, Portuguese project developers will be well placed to align designs with EU integrity standards and to attract buyers increasingly seeking nature-positive attributes. Outlook for 2025–2027: From Architecture to Execution For the EU, 2025–2027 is the build-and-test phase. The European Commission will convene the expert group on nature credits, run pilots, assess supply and demand, develop CRCF methodologies for carbon farming with biodiversity co-benefits, and consider whether to legislate a dedicated nature credits frame- work. These steps aim to ensure integrity from the outset, reduce transaction costs, and define credible use cases that do not undermine environmental law or public funding.

For Portugal, 2025 or 2026 could become a first issu- ance year if the registration platform launches and the initial forestry methodology is approved following public consultation. Fee incentives for methodolo- gies filed by the end of 2026 are designed to catalyse developer action, and the verifier qualification regime provides a pathway to scale assurance capacity. The strategic opportunity is to position Portuguese carbon credits projects at the forefront of EU-aligned climate- and-nature finance, while addressing open issues on trading mechanics, confidentiality safeguards, super- vision and reversal insurance. Voluntary markets are moving towards higher-integ- rity units that deliver quantifiable climate outcomes with verified nature co-benefits – soon to be comple- mented by standalone nature credits built on rigorous certification. With the remaining ordinances, appointments and platform operations in place, the market can mature into a credible channel for private investment across terrestrial and marine ecosystems, supporting nation- al climate neutrality ambitions and Europe’s emerging nature-positive economy.

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