Ghana has recently enacted legislation to create a Carbon Markets Office and is seeking to finance a large portion of its NDC implementation with carbon credit revenue. While the country positions itself as a regional trailblazer in climate finance through carbon markets, a lack of transparency and a narrow policy focus could undermine its quest to mobilise it.
Notwithstanding disappointment about the insufficiency of COP29’s agreed climate finance target, some observers have been upbeat about the agreement reached on Article 6.2 and Article 6.4, which are both expected to become operational this year. These provisions respectively enable one country to trade credits with another to meet its climate targets, and to develop carbon credits under Article 6.4’s Paris Agreement Credit Mechanism (PACM). The adopted texts bring some clarity to the operationalisation of these trades and project developments, and by extension provide a lifeline for the further development of carbon markets, particularly for countries in Africa in dire need of mitigation finance.
The strategic path to carbon market success and mitigation action in Ghana
Ghana is one of several countries in the Global South that have struggled to effectively mobilise climate finance. It needs to raise in excess of half a trillion dollars for its Just Energy Transition, and US$9.3billion for the mitigation actions in its Nationally Determined Contribution (NDC). A sizeable chunk of what is needed for the NDC, some U$4.9billion, is expected to be generated from internal cooperation, including carbon markets.
Alongside Tanzania and South Africa, Ghana is considered to have some of the most mature regulatory frameworks for finance from mitigation activities in the region. Its government has capitalised on this by launching a framework on international carbon markets and non-market approaches in 2022. The framework prioritises mitigation activities in solar, wind, energy efficiency, biogas and reduction in flaring in oil and gas production among others. Reports from November last year, suggest that the country has earned approximately US$800million through carbon credit trades mainly with Sweden and Switzerland.
The Carbon Markets Office currently has 54 mitigation project activities under development, with four cooperative approaches (credit trades) with Switzerland, Sweden, Singapore, and South Korea and two voluntary carbon market projects under development. The office reports 12 completed projects across a range of sectors, five in energy, three in waste, two in transport, and single projects in agriculture, waste and forestry and industrial processes and products use, respectively. Although relatively low in number, some are high in value, with the agreement between local waste management company Jospong Group and Indian based EKI Energy estimated to generate US$1billion in carbon credit revenue. Further efforts through an integrated waste recycling and compost initiative are also expected to generate US$20million by 2030.
Institutionalising carbon market development through the new Environmental Protection Act.
Ghana has enshrined the operation of its carbon market office in law, insulating initiatives and projects from the cycle of political influence that historically has undermined efficient implementation. The recent passage of the Environmental Protection Act, 2025 (AC T1124) in January establishes the Carbon Markets Office, hosted by the Environmental Protection Agency. The Act endows it with expansive supervisory, regulatory, enforcement and administrative powers. The novelty of the law is its mandate to spearhead the country’s climate change response and to mainstream programmes at the national and sub-national level, in a governance context that is often centralised and national. The Carbon Registry – which collects, verifies and tracks emissions data and carbon market transactions at the project and company levels – also has the full force of law, in line with Constitutional requirements.
The scaling of mitigation finance for Ghana will largely depend on the sustained implementation of the initiatives under the carbon markets framework and its subsequent expansion and development. The country cannot afford to continue the practices it has adopted to date, where a change in government generally results in either a review of or cancellation of carbon credit projects and programmes for market development. The newly inaugurated government had very limited policy propositions on how to expand the carbon market. One initiative, among others, was a commitment to integrate agroforestry practices in new cocoa plantings to enhance soil microbial life and accrue soil organic carbon. This activity has the potential to be registered as a carbon offset project. Its other initiative was to augment the current power generation mix with more renewable energy and nuclear to reduce carbon footprints from the power sector. Beyond these, however, it has not explored or encouraged project development across other sectors.
The need for broader commitment and greater transparency to unlock the full potential of the carbon market.
The orientation of the new government towards carbon market expansion is unduly narrow, viz-a-viz the developments, programme scope, and initiatives currently underway. It is in the interest of the country for the government to fully operationalise all the functions of the Carbon Market Office including the registry as contemplated by the new EPA law, the carbon markets framework, and the international carbon markets framework; and to provide ample support and attention to its existing obligations under the cooperative agreements it has concluded. However, the limited transparency of the Carbon Market Office and its operations may undermine this, as acknowledged by Dr. Daniel Tutu Benefoh, who leads it. The office currently only discloses estimate figures on its activities without any details of projects. The registry itself has no project updates, and it lacks a meaningful support system for businesses. It does not provide any updates, for example fee schedules, and only discloses the project activity and authorisation process and project eligibility criteria.
Ghana’s carbon markets framework has positioned the country as a regional leader in mobilising climate finance, with notable progress in carbon credit trading and mitigation activities across diverse sectors. However, sustaining and scaling these achievements requires unwavering government commitment, operational transparency, and adherence to the robust regulatory framework established under the new Environmental Protection Act. The narrow policy focus of the new government on cocoa-related initiatives will likely undermine the broader potential of Ghana’s carbon markets to attract significant mitigation finance across sectors like energy, transport, and waste. To fully leverage its first-mover advantage and secure long-term gains, the country must prioritise comprehensive implementation, transparency, and support for all carbon market initiatives while aligning with international frameworks and cooperative agreements.
