Bangladesh’s Carbon market Frameworks- Ready or Being Rash?

Bangladesh pre-launched its carbon credit market framework in partnership with the World Bank and PMI (Partnership for Market Implementation) at COP30. The idea of the framework is to identify how ready we are to implement the unconditional targets of Bangladesh’s NDC 3.0. But this creates another question, are we even ready to implement our NDCs unconditional targets? Or are we being too greedy to forget that readiness has always been a word that cornered us into launching projects and frameworks that didn’t really do much except fill the pockets of foreign investors?

For years, carbon markets have been marketed 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 enough: climate action where it’s 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. We saw forests fenced off from Indigenous people, waste incinerators celebrated as green projects, and heavy industries collecting credits without changing much of anything. The promise was always big; the delivery was always smaller.

Bangladesh now stands at a very delicate moment. Our carbon market framework, still in its early shape, tries 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 underneath that well-designed surface is a story we’ve 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 close look at the framework exposes the cracks. Our “positive list” includes renewable energy, electric mobility, brick kiln modernisation, methane reduction, rice cultivation changes, afforestation, blue carbon, even waste-to-energy. These aren’t side projects; these 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. That means Bangladesh will have to report higher emissions, higher than the reality, 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, Ghana, have learned this lesson the hard way. Kenya has already faced backlash for selling ITMOs that communities were not consulted about. Vietnam paused approvals because of 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 than ours have struggled to balance revenue with sovereignty. Yet, Bangladesh seems ready to sprint into a market that others have approached with caution.

Our flaws sit at three levels.

First, the framework treats our highest-value mitigation opportunities as export goods. Renewable energy, electric mobility, methane capture, these 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, foreign methodologies. This means we lose control over what counts as real mitigation, how baselines are set, and how projects are judged. It puts our climate future in the hands of institutions that have never lived through floods or cyclones.

Third, the framework is almost silent on who is protected when things go wrong. There is nothing meaningful about community rights, land rights, FPIC, grievance redress, or benefit sharing. It opens the door to the same problems the CDM created, displaced communities, land grabs, and projects imposed without consent.

The harms will not appear all at once. They will creep in slowly.

We will see foreign companies locking our forests and wetlands into offset contracts. We will see powerful local actors rushing for carbon-rich land. We will see waste incineration revived under the banner of “mitigation.” We will see our NDC weakened not on paper, but in practice, because our actual mitigation potential will be transferred abroad. And we will 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 entirely. But if we are to walk this path, the framework must look very different.

It must start with a simple principle:

No mitigation that is 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 move 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, our own verification capacity. Otherwise, we are nothing but subcontractors in a global offset supply chain.

And finally, the government must remember that carbon markets are not climate finance. Selling an ITMO is not receiving 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, while 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,
Founder and Executive Director,
Youth for NDCs