Five Things the Philippine Carbon Market Needs Next
Executive Order 127 puts one regulator in charge. That settles who decides. It does not yet settle what a buyer, an investor or a community can rely on. Five things close that gap, read from the global buyer down to the people’s organisation on the land — and most of them are field work, not law.
Exhibit 1 · At a glance
Five gaps between a named regulator and a market that clears
| Level | The gap today | What closes it |
|---|---|---|
| 1The buyer | Supply is sized before anyone asks buyers what they will pay for | Structured market sounding before a pipeline is built |
| 2The nation | No published clock, fee or answer on which nature credits can be exported | Time-limited authorization steps and an early list by activity type |
| 3The ledger | Up to three registries can hold the same hectare | One national registry that mirrors the others and publishes what it holds |
| 4The landscape | Community share and consent timelines still unset; no standard route onto state land | A published minimum share and a standard carbon concession |
| 5The community | Local governments and people’s organisations rarely have the capacity to hold up their end | Blended finance that pays for local capacity before the deal |
What the order sets up
On 13 October 2026 President Marcos signed Executive Order 127. It names the Department of Environment and Natural Resources the country’s national authority for carbon markets — in Paris Agreement terms, its Designated National Authority. It creates an Inter-Agency Committee on Carbon Markets, chaired by the Climate Change Commission with Finance as vice-chair, and orders a Philippine National Carbon Registry to track every credit. DENR has 30 days from the order taking effect to put a Philippine Carbon Market Policy Framework to the committee (Power Philippines). The Palace has said the order sets up a market and imposes no new carbon tax (GMA News).
Exhibit 2 · The new structure, and the clock
One authority, one committee, one registry — and a framework due within weeks
Members: DENR, Energy, Agriculture, Transportation, Trade and Industry, SEC
- 13 OctOrder signed
- 15 OctAnnounced by the Palace
- PublicationOrder takes effect
- +30 daysDENR submits draft framework
- 9–20 NovCOP31, Antalya
This is the step the market was waiting for. Until now, carbon authority was spread across agencies: DENR registering forest projects under DAO 2026-05, Energy writing its own credit rules, Article 6 deals negotiated one at a time. One designated authority is what a buyer of authorized credits needs to see, and the first thing an investment committee asks about. It is also only the start: if the order is published this month, DENR’s draft falls due around the time COP31 meets.
We see what comes next from the ground. Our team works on early-stage project development across all three island groups — Luzon, the Visayas and Mindanao — from upland grassland to coastal mangrove: feasibility, tenure, consent and the first conversations with buyers. From there, five things matter most. We start at the widest view and zoom in.
1 The buyer: demand on the record before supply is built
Size the pipeline to what buyers will actually pay for, not to the hectares available.
Policy can make credits legitimate; only buyers make them worth something. The Philippine market has rarely asked buyers, in a structured way, what they would pay for. Market sounding does that — putting a defined opportunity in front of buyers, developers and investors before it is built, and writing down what they say. It is routine work for our team, and the answers are usually more specific than market commentary suggests.
Exhibit 3 · What a sounding has to pin down
Four choices that set the price of a nature credit
2 The nation: a clock on authorization, and an early answer on what leaves
Publish a time limit and a fee for every step, and say early which nature credits can be exported.
Buyers of Article 6 credits do not pay for a policy. They pay for a letter. A Singapore company using credits against its carbon tax, an airline under CORSIA, a government buying toward its target: each needs to know when a letter of authorization arrives, what it costs, and whether it can be withdrawn. The Philippines–Singapore implementation agreement signed in Manila on 30 April 2026 already fixes some terms — 5% of Singapore’s share of proceeds to Philippine adaptation, and 2% of authorized credits cancelled at issuance — but leaves the authorization process and eligible methodologies to follow (Argus Media; Rajah & Tann).
Exhibit 4 · The path a buyer has to see
Every step needs a published time limit and fee
- No-objectionHost country agrees in principle
- AuthorizationActivity approved for export
- IssuanceCredits verified and issued
- First transferCorresponding adjustment applied
The Nationally Determined Contribution submitted in September brings forestry and other land use inside the national target for the first time (Eco-Business), so every forestry or blue carbon credit authorized for export is a tonne the country cannot count for itself. The government may choose to keep many of those tonnes. What developers cannot price is not knowing. Say, by activity type — reforestation, agroforestry, mangrove restoration, avoided conversion — which are open to authorization, which are voluntary-market only, and on what terms. Capital can plan around a rule; it cannot plan around silence.
3 The ledger: one registry that talks to the others
Mirror existing records, use one project identifier, and publish.
Most Philippine nature projects in development already sit on an international registry, usually Verra’s. DAO 2026-05 added a DENR forest carbon credit database; EO 127 adds a national registry over everything. Three ledgers for one hectare is how double counting happens, and why a buyer’s diligence takes months.
Exhibit 5 · Three ledgers, one hectare
Three records should reconcile into one public ledger
Public registry data is what lets a market check itself. We read Southeast Asia’s registries every day through Carbon.Supply, the registry tracker built by our sister company Wovoka; a Philippine registry that publishes the same way would be the first source a buyer checks, not the last.
4 The landscape: tenure a credit committee can read
Make the community’s share a published term, and give state land a standard route into the market.
Most of the country’s best nature carbon sits on land the developer does not own. DAO 2026-05 already sets who may propose a project and requires a benefit-sharing plan; the minimum community share is still to be set by the Forest Management Bureau and the NCIP (our note on DAO 2026-05).
Exhibit 6 · Who holds the land
Each tenure type needs a different answer before a lender will sign
| Tenure | Held by | What a lender needs to see |
|---|---|---|
| Ancestral domain (CADT) | Indigenous cultural communities | Free, prior and informed consent with NCIP certification; an agreed benefit share |
| Community-based forest management agreement | People’s organisations | An agreement with term to cover the crediting period; PO governance that will outlast it |
| Protected area | State, under its management board | Board approval and a zoning plan that allows the activity |
| Abandoned fishponds and coastline | State | A standard concession or lease: term, revenue split, monitoring duty |
Two moves would de-risk this faster than any other rule. First, publish the minimum share and the consent timelines, so the community’s share is a known term rather than a negotiation. Second, give government-held land a standard route into the market: a carbon concession or lease that a developer can bid for and a lender can read. Abandoned fishponds, which the Fisheries Code returns to mangrove, are the obvious first case for blue carbon — provided each concession is screened hectare by hectare, because restorable land is usually a fraction of what is mapped.
5 The community: local governments and people’s organisations that can hold up their end
Fund local capacity with grant and public money before the deal, not after the dispute.
Every carbon project in the Philippines ends at a barangay hall and a people’s organisation. A national framework can be perfect on paper and still stall if the local government has never seen a carbon project and the people’s organisation does not know what its land rights are worth.
Exhibit 7 · Where projects succeed or stall
Three local actors, three kinds of capacity — paid for by blended finance
This is the part of the market least likely to be funded by the people who profit from it, which is why it needs blended finance. NGOs such as Inclusive Forests do this work with communities — securing land rights, building governance and financial literacy, and helping them understand what their land is worth before a developer arrives. A market that skips this step gets projects that look good at registration and fail at the first benefit-sharing dispute.
What happens next
The order settles who decides. The next 60 days settle what they decide. A framework with real demand behind it, a clock on authorization, one open registry, tenure a lender can read and communities able to hold up their end would give the Philippines a carbon story at COP31 that buyers can underwrite. Very little on that list is law-writing. Most of it is field, tenure, community and market work done before a project exists — which is the work we do.
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