Carbon market policy and Article 6 compliance
Carbon Markets & PolicyApril 2026·9 min read

Article 6.4 After COP29: What Corresponding Adjustments Mean for African Project Developers

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Virginia Njeri

Lead, Project Development, Validation & Verification

Baku's breakthrough on Article 6.4 finalised the mechanism's rulebook, but corresponding adjustments are creating a two-tier credit market that African developers cannot afford to ignore.

COP29 in Baku delivered the rulebook that Article 6.4 had been waiting for. After three years of technical negotiations, the Supervisory Body reached consensus on authorisation procedures, corresponding adjustment methodology, and the transition pathway for pre-existing recognised carbon standard frameworks credits. For African project developers, the implications are immediate, and the pricing consequences are already visible in the forward market.

What 'Corresponding Adjustments' Actually Require

A corresponding adjustment (CA) is the accounting entry a host country makes when a carbon credit is used toward another country's Nationally Determined Contribution (NDC). When a Kenyan forestry project issues a credit and a European corporate uses it to meet its net-zero target, Kenya must increase its own reported emissions by one tonne, reflecting that it has 'exported' a climate benefit rather than counting it domestically.

This sounds technical, but the market consequence is stark. Credits sold with a corresponding adjustment are internationally transferable mitigation outcomes (ITMOs), they satisfy Article 6.2 and 6.4 and can be used by sovereign buyers toward their NDC commitments. Credits sold without a CA remain 'domestic' in character, usable by voluntary market buyers but not by sovereign or compliance-grade buyers.

A credit with a verified corresponding adjustment now commands a 35–70% premium over a standard voluntary credit in the same underlying project, and that spread is widening.

, Supacare Solutions, Carbon Markets Analysis, Q1 2026

The Two-Tier Market Taking Shape

The market is bifurcating rapidly. Tier 1 credits, those with host-country authorisation and corresponding adjustments, are being absorbed by sovereign buyers (Japan's Joint Crediting Mechanism, Swiss bilateral agreements, Singapore's Article 6 frameworks) at prices ranging from $25 to $85 per tonne depending on methodology and vintage. Tier 2 credits, voluntary market issuances without corresponding adjustments, face continued pressure on pricing as corporate buyers assess reputational risk around 'double counting' concerns.

Key Dates

Host countries must submit Article 6 authorisation letters to the UNFCCC Secretariat by June 30, 2026 for projects seeking Tier 1 status in the 2026 issuance cycle. Kenya's Climate Change Directorate opened the CA application window in March 2026.

What This Means for African Project Developers

If you have an active project with existing offtake agreements, your first question should be: does my buyer require a corresponding adjustment? If the buyer is a European corporate buying for voluntary net-zero claims, they likely do not, yet. But if your offtake is with a government programme, a JCM-designated entity, or any buyer making Article 6.2 claims, the CA is non-negotiable. Check your offtake language immediately.

Practical actions for African developers in 2026:

  • Engage your host country's national designated authority immediately, CA processing pipelines are already building in Kenya, Ghana, and Rwanda
  • Audit your existing offtake agreements for CA language, ambiguity will become a dispute as buyers become more sophisticated
  • For new projects, negotiate Article 6 authorisation as a condition precedent in your development agreement, not an afterthought
  • Model both pricing scenarios (Tier 1 with CA and Tier 2 without) in your project financial model
  • Assess your national NDC ambition, host countries with aggressive NDCs may restrict the volume of credits eligible for CAs

Kenya's Emerging Position

Kenya's Climate Change Act 2023 and the subsequent Carbon Markets Regulations 2024 established a clear domestic framework for Article 6 authorisation. The National Designated Authority, housed within the Climate Change Directorate, has begun processing CA applications, with an announced target of 60-day processing for projects with complete submissions. Kenya has taken a more pragmatic position than some peer countries, opting to allow CAs on credits beyond its NDC mitigation pathway rather than restricting exports entirely.

This positions Kenya as one of the more Article 6-friendly hosts in sub-Saharan Africa, a meaningful competitive advantage for project developers who structure their authorisation correctly from project inception. Our team holds active advisory relationships with the Climate Change Directorate and can guide clients through the CA application process from documentation to approval.

Article 6COP29VCMCorresponding AdjustmentsITMO

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