Aksyon Klima Pilipinas

Aksyon Klima Pilipinas expresses its concern regarding the Philippines’ Readiness in the Voluntary Forest Carbon Market (VCM): Roadmap (2026-2030), as recently adopted under an Administrative Order by the Department of Environment and Natural Resources (DENR).

While we understand the intent of this roadmap to secure more investments and other forms of support in aid of strengthening the protection and restoration of the country’s remaining forests and also achieving climate and economic targets, we regard some of the provisions stated in the Roadmap as indicative of weak environmental and social safeguards, leaving a large portion of the country’s remaining forests prone to greenwashing and potential degradation, and climate-vulnerable communities to further socioeconomic marginalization.

We raise the following major concerns regarding the Roadmap:

• Risk of incoherent policy development. While the Roadmap lists policy instruments that are relevant to its implementation for both the executive and legislative branches, neither their respective timelines of finalization nor alignment among implementing agencies are fully clear. Its alignment with other pending strategies such as the Long-Term Low Emission Development Strategies (LT-LEDS) is also unclear. Furthermore, the Blue Carbon Roadmap is under the Biodiversity Management Bureau, while forestry-related matters would be under the Forestry Management Bureau. It is vital for the Philippine government, led by the DENR in this workstream, to avoid a “piecewise” progression in the development of forest VCM-relevant instruments that could result in an incoherent overall framework and create gaps and loopholes that hinder the effectiveness of these policies and induce harm to stakeholders. Establishing clear 1.5°C-aligned decarbonization pathways, as part of LT-LEDS, would also set the targets for carbon sequestration by forests and subsequently quantitative targets for the forest VCM system.
• Definition of carbon rights. Defining carbon rights should be done through legislation, given its potential ramifications on issues related to land rights, human rights, biodiversity and ecosystems protection, and Indigenous Peoples. While the Roadmap references the Low Carbon Economy Investment Bill currently under consideration in Congress, it also omits the Carbon Rights Bill. With existing laws such as the Indigenous Peoples Rights Act containing provisions that may be interpreted to refer to carbon rights, the DENR must clarify this critical component of forest carbon market activities in the Philippines.
• Limited technical capacity in implementation. As the Philippine government appears to intend to speed up the finalization of carbon market-relevant policies and mechanisms and given the highly-technical and complex nature of carbon markets and their management, there must be a higher prioritization and a clearer strategy on capacity-building for relevant officials under the DENR, other national government agencies, potential participants in VCMs, and representatives from non-government sectors. This is to ensure the proper implementation of the Roadmap, including all the listed policies and programs. The rollout of capacity-building programs must be conducted such that it not only enables the pending national carbon market system to meet the demand from prospective participants, but also responds to the needs of all groups covered, especially those representing local communities and vulnerable sectors.
• Weak mechanisms for just benefit-sharing. The lack of a strong commitment by the Philippine government to ensure equitable benefit-sharing schemes that would protect the interest of local communities is concerning. Relying only on soft policy instruments, even in the short-term, could lead to amplified threats to local communities without hard policy instruments such as laws and regulations to ensure equity, transparency, and justice. Deferring to specifications of crediting agencies, many of whom have historically-poor track records on efficacy and transparency of benefit-sharing agreements, also risk placing local communities at a disadvantage. This risk is also heightened if other concerns with VCMs, such as over-crediting and failing to timely respond to flagged projects or complaints from stakeholders, are not addressed. This Roadmap must prioritize establishing mechanisms, even in the short-term, to ensure that local communities get to decide what counts as fair and equitable to them in participating in projects relevant to the country’s pending forest VCM system.
• More urgent formulation of a robust grievance mechanism. The formulation of a robust rights-based grievance mechanism is necessary for an ethical, credible, and high-integrity forest VCM in the Philippine context, while also being aligned with Article 6.4 of the Paris Agreement. It must be accessible to all affected stakeholders, with procedures to ensure timely resolutions of conflicts, transparency of proceedings, and the security and safety of complainants, especially from vulnerable communities. The establishment of such a mechanism is an indicator of the degree of involvement local communities would have under this framework, which should not just be limited to seeking grievance or defining benefit-sharing. The mechanism must be overseen by an independent body with authority to deliver concrete results (i.e., recognition of land ownership, compensation), while being rooted in international human rights standards and respecting land rights, land tenure, and the rights of Indigenous Peoples, especially the right to Free, Prior, and Informed Consent.

We urge the DENR to address these issues in the Roadmap and the other pending policy instruments that would define the country’s forest VCM framework. This is to prevent such framework from reflecting the same flaws that have long placed serious doubt on the credibility of carbon markets to deliver genuine, effective, and equitable benefits for our climate, economy, and society.