Bangladesh’s carbon market frameworks: Ready or being rash?

At COP30 today, Bangladesh pre-launched its carbon credit market framework in partnership with the World Bank and PMI (Partnership for Market Implementation). The aim is to identify how ready we are to implement the unconditional targets of Bangladesh's NDC 3.0. But this raises another question: are we even ready to implement our NDC's unconditional targets? Or are we being too eager, forgetting that "readiness" has often pushed us into launching projects and frameworks that achieved little beyond enriching foreign investors?

For years, carbon markets have been sold as the silver bullet in climate negotiations — a system where countries and companies that reduce emissions beyond their own needs can sell those reductions to others. The idea was simple: climate action where it is cheapest. But the history behind this "simple" idea is anything but simple. From the early days of the Clean Development Mechanism (CDM) under the Kyoto Protocol to today's Article 6 market under the Paris Agreement, carbon markets have walked a tightrope between ambition and exploitation.

The CDM was meant to help developing countries leapfrog polluting pathways; instead, it often turned them into cheap offset factories for the industrialised world. Forests were fenced off from Indigenous communities, waste incinerators were celebrated as green projects, and heavy industries collected credits without changing much at all. The promise was always big; the delivery was always smaller.

Bangladesh now stands at a delicate moment. Our carbon market framework, still in its early form, attempts to map out how mitigation can be authorised, tracked, measured, and eventually sold. On paper, it looks organised. It talks about positive lists, negative lists, methodologies, project cycles, registries, fee structures, corresponding adjustments, and so on. But beneath the well-designed surface lies a story we have seen before: the risk of Bangladesh becoming a supplier of mitigation outcomes to countries that would rather pay us than clean up their own mess.

A closer look at the framework exposes cracks. Our "positive list" includes renewable energy, electric mobility, brick kiln modernisation, methane reduction, rice cultivation changes, afforestation, blue carbon, and even waste-to-energy. These are not side projects; they are pillars of our own NDC, our own energy transition, our own development story. If we sell these reductions to other nations, we cannot count them towards our NDC. This means Bangladesh will have to report higher emissions — higher than the true figure — because the reductions will be exported. In a world where ambition must rise every five years, we would be setting ourselves up for tighter constraints, stricter expectations, and a heavier burden later.

Countries in similar positions — Kenya, Vietnam and Ghana — have learnt this lesson the hard way. Kenya faced backlash for selling ITMOs without proper community consultation. Vietnam paused approvals due to fears of overselling. Ghana had to rewrite parts of its rules after realising that Article 6 authorisation was stripping away national mitigation potential at a speed that threatened its own NDC. Even countries with far stronger institutions have struggled to balance revenue with sovereignty. Yet Bangladesh seems ready to sprint into a market others have approached with caution.

Our flaws fall into three levels.
First, the framework treats our highest-value mitigation opportunities as export goods. Renewable energy, electric mobility and methane capture are the backbone of our future economy. Once sold, they are gone. We cannot reclaim them in future NDC cycles.
Second, the framework leans heavily on foreign crediting standards, foreign verifiers, and foreign methodologies. This means we lose control over what counts as real mitigation, how baselines are set, and how projects are judged. It places our climate future in the hands of institutions that have never lived through floods or cyclones.
Third, the framework says almost nothing about who is protected when things go wrong. There is little mention of community rights, land rights, FPIC, grievance redress or benefit-sharing. This opens the door to the same problems created by the CDM — displaced communities, land grabs, and projects imposed without consent.

The harms will not appear all at once; they will creep in slowly.
We may see foreign companies locking our forests and wetlands into offset contracts.
We may see powerful local actors rushing to secure carbon-rich land.
We may see waste incineration revived under the banner of "mitigation."
We may see our NDC weakened in practice, not on paper, because our actual mitigation potential will be transferred abroad.

And we may see young Bangladeshis — today's climate generation — forced to carry a heavier mitigation load in 2035 and 2040 because too much was sold in 2025.

This does not mean Bangladesh should reject carbon markets outright. But if we are to walk this path, the framework must look very different.

It must begin with a simple principle:

No mitigation essential for Bangladesh's energy transition, food security or climate resilience should be authorised for export.

Second, the framework must be built on public participation, community rights and full transparency. No carbon project should proceed without local consent and local benefit.

Third, Bangladesh must set strict limits on how much mitigation can be sold, and from which sectors. We cannot turn our NDC into a clearance sale.

Fourth, fees, taxes and benefit-sharing mechanisms must be real — not "TBD" boxes on a slide. If revenue comes in, it must go to the people whose land, air or forests are being used.

Fifth, Bangladesh needs independence, not dependence. We should develop our own methodologies, our own MRV systems and our own verification capacity. Otherwise, we remain subcontractors in a global offset supply chain.

And finally, the government must remember that carbon markets are not climate finance. Selling an ITMO does not receive climate finance. It is selling our mitigation to someone who chooses not to act. Bangladesh stands at a crossroads. One road leads to a future where we sell our climate ambition piece by piece. The other leads to a future where we build the systems we need to reach our own goals, negotiating from a place of confidence, not desperation. The framework unveiled today is not destiny. It is only a draft. It can be rewritten. It must be rewritten. Because Bangladesh cannot afford to become a carbon market success story built on the failure of our own climate future.

Amanullah Porag is the South Asia Mobilisations Coordinator at 350.org

Disclaimer: The views and opinions expressed in this article are those of the author and do not necessarily reflect the opinions and views of The Business Standard.