Kenya’s E-Motorcycle Shift Is Real. The Carbon Case Is More Complicated.

A battery-swapping station can look like an obvious carbon project: electric motorcycles replace petrol bikes, riders keep moving, and the batteries are charged away from the road. Under Verra’s revised VM0038, that setup is worth examining. But the methodology does not turn every swap, charger or electric motorcycle into an eligible carbon activity.

VM0038 v1.1 became active on 19 August 2026. The public consultation ran from 18 March to 17 April 2026. The final text makes two things clear: two- and three-wheelers are within the methodology’s vehicle definitions, and battery swapping can form part of the associated charging infrastructure. The separate positive-list module, VMD0049 v1.1, does not include two- and three-wheelers on its positive list. Those points need to be read together.

Start with the project’s actual operating model

VM0038 describes a charging network as open when it is not restricted to a specific identified subset of electric vehicles. A closed network serves only a defined subset, such as a company’s own fleet. This is about which vehicles can use the network, not simply who owns the station. A privately owned network may still be open; a public-facing site may still be restricted.

That distinction matters because VM0038’s applicability conditions provide an alternative market-penetration route for open networks. They set separate stock-share and three-year sales-share thresholds for AC chargers and DC fast chargers, using the most recent official data available at validation. The text does not give the same alternative for closed networks: those need to meet the relevant VMD0049 positive-list condition.

For a two-wheeler battery-swap network, the project team should therefore document who can access it, which vehicle models can use it, whether the service is limited to a named fleet, and how those vehicles are classified under Kenya’s regulatory definitions. Do not assume that “battery swapping” makes the network open, or that the broad EV definition resolves every positive-list question.

The positive-list point is not the whole answer

VMD0049 v1.1 states that two- and three-wheelers are not included in its positive list. That is important, but it is not the same as saying that every two-wheeler activity is automatically outside VM0038. The methodology also allows a project method for additionality: regulatory surplus must be shown, followed by investment or barrier analysis and a common-practice assessment. The proponent still has to satisfy VM0038’s applicability conditions. A project-method additionality case does not cure a separate failure to meet applicability.

The consultation record shows why care is needed. In response to a comment about two- and three-wheelers, Verra said its revised positive list used car data as a proxy for general EV transport and clarified that the positive list excludes two- and three-wheelers. It noted that battery swapping could be differentiated in a later revision. That response is useful context, not a substitute for the final methodology and module.

Battery swapping makes the evidence chain more important

VM0038 treats EV batteries and battery swapping as part of associated infrastructure. It also requires the project’s metering system to trace electricity delivered to and received from associated infrastructure. A swap count alone is not an electricity record.

Before a pilot, agree how the operator will connect each swap and battery identifier to charging-session data, metered electricity, battery movements and the relevant vehicle fleet. Keep records for energy drawn from the grid, on-site renewable supply and storage where used. The project must also quantify electricity-related project emissions; charging activity is not automatically zero-emission.

The baseline comparison needs attention too. VM0038 requires project and baseline vehicles to be in the same vehicle category and to have comparable passenger or load capacity. For a closed network, the new electric vehicles and baseline vehicles must be identified, with their operating characteristics documented. A project should be able to show which petrol motorcycle service is being displaced, rather than relying on the number of batteries exchanged as a proxy for avoided fuel use.

What to settle before equipment is ordered

For a Kenya e-motorcycle concept, the first decision file should answer four questions:

Then test the project’s baseline, regulatory surplus, additionality, ownership of reductions and monitoring plan against the current VCS requirements. If the open/closed classification or treatment of two-wheelers under the relevant applicability route remains uncertain, resolve it with the validation and registry pathway before procurement or a credit-revenue commitment.

The practical takeaway is modest but useful: VM0038 v1.1 gives developers a methodology to examine for electric motorcycles and battery swapping. It does not guarantee that a particular Kenyan network qualifies, that reductions will be issued, or that carbon revenue will make the investment viable. The strongest next step is to test the specific operating model and its evidence before scaling it.