Approving a Carbon Market Framework is the beginning of sovereignty, not the end of it
President Tinubu signed a Carbon Market Framework in January that claims sovereignty over Nigeria’s climate assets. Five months later, a case in Zimbabwe has exposed exactly the legal gap that puts that sovereignty at risk – and named the international body that can fix it.
The language of that framework is strong. It speaks of Nigeria controlling its own carbon accounting, ensuring that revenues flow back to the country, and participating in international markets on its own terms. What the framework does not yet resolve – and what a dispute 3,000 kilometres south in Zimbabwe has now made visible – is whether the international carbon compliance market is structured to recognise that sovereignty when a government actually exercises it.
The short answer, based on Zimbabwe’s experience, is that it is not. And Nigeria needs to understand why before its own pipeline deepens.
The Paris Agreement says one thing. CORSIA does another.
The Paris Agreement is unambiguous about carbon sovereignty. Under Article 6, host countries must issue a Letter of Authorisation and apply a Corresponding Adjustment before carbon credit can be considered Paris Agreement-compliant for international use. These documents are not bureaucratic formalities. They are the mechanism by which a sovereign government confirms that the credit counts toward its own national climate targets, that it controls how the asset is used internationally, and that it has a stake in the revenue it generates.
CORSIA – the Carbon Offsetting and Reduction Scheme for International Aviation, managed by ICAO, the UN’s aviation body – is supposed to align with this architecture. In practice however, a structural contradiction has emerged. Under rules shaped by ICAO’s Technical Advisory Body, eligible credits must flow through a small number of approved private standard registries. Credits that pass through sovereign national registries – even after receiving full Paris Agreement authorisation – currently find no qualifying pathway exists within CORSIA’s eligibility rules.
A credit that completed every step the Paris Agreement requires is currently worth approximately $3 in the CORSIA market. A credit that skipped those steps, backed instead by insurance, trades at approximately $17. This is what it costs to follow the rules.
In May 2026, Zimbabwe’s Ministry of Environment published a formal press statement raising concerns about Gold Standard Foundation — a Switzerland-based private carbon registry – after finding that 1.6 million tonnes of credits from a cookstoves projectdid not meet CORSIA’s current eligibility rules. Zimbabwe had issued a Letter of Authorisation, applied a Corresponding Adjustment through its national carbon registry, and transferred the credits back to Gold Standard’s system for trading. Every Paris Agreement requirement had been met.
Those credits were subsequently ruled ineligible for CORSIA use. Gold Standard attributed the decision to ICAO’s own rules rather than to any unilateral decision of its own. Zimbabwe’s Minister of Environment, Dr Evelyn Ndlovu, described the outcome as an “open affront to the objectives of CORSIA” that “risks causing significant financial harm to innocent Zimbabwean communities.” She called it “deeply inappropriate – and legally questionable – for a foreign NGO to substitute its own judgement for the multilateral processes in which Africa has fought dearly to preserve its rights and interests.”
What Zimbabwe’s experience demonstrates is that the Paris Agreement’s sovereignty architecture and CORSIA’s eligibility architecture are currently misaligned. A country that does exactly what the Paris Agreement asks can find that doing so makes its credits less valuable in the compliance market, not more.
Nigeria has 57 registered voluntary carbon projects, spanning clean cooking, renewable energy, and forestry. Many of those projects are registered with private international standard bodies without formal authorisation from the Federal Government under the Paris Agreement’s Article 6 framework. Nigeria’s new Carbon Market Framework mandates a national registry and alignment with Article 6, but the infrastructure to enforce that mandate, and the international rules to recognise it, are not yet in place.
As CORSIA Phase II begins in 2027 – when all international flights become subject to offsetting requirements, not just those between volunteering states – the demand for CORSIA-eligible credits will increase substantially. If Nigeria’s government asserts its Article 6 rights at that point, requiring that credits pass through its national registry and receive formal authorisation before they enter international markets, it may encounter the same gap in the current rules that Zimbabwe is now navigating. The market, as currently designed, does not have a clear pathway for sovereign national registries to participate.
The CORSIA framework does not explicitly prohibit national registries from participating. It discourages certain inter-registry transfer pathways, but the rules do not say no. That legal ambiguity is important: it means the private crediting programmes currently acting as gatekeepers – Gold Standard, Verra, and others — have discretionary space, within existing rules, to approve fully authorised credits from sovereign national registries today.
If they approve and ICAO objects, a formal dispute is created that must be resolved on the record. If they approve and ICAO stays silent, silence in the face of a documented, compliant transaction is legally interpretable as consent. Either way, there is movement. Nigeria’s government should be asking crediting programmes directly why they are not using that space.
The longer-term fix is a framework update at ICAO – specifically, a formal request that ICAO codify a qualifying pathway for sovereign national registries, subject to strict, publicly defined technical conditions.
That submission will carry more weight the more African governments are behind it. Nigeria’s diplomatic standing within ECOWAS and the African Union, and the scale of its carbon market ambitions, make it one of the voices that would be hardest for ICAO to ignore. The question is whether Nigeria will position itself at the front of that effort – or wait until others have already shaped the terms.
One company already doing this work for African governments is TerraViva. Founded by Felix Giordano, who serves as Zimbabwe’s Carbon Market Coordinator and represented the country at the IETA CORSIA roundtable in Singapore in May 2026, TerraViva works with African governments on the technical and policy architecture that bridges the gap between a signed carbon market framework and an enforceable one – specifically, connecting national registries to international compliance systems in a way that is both Paris Agreement-aligned and commercially viable. For Nigeria, which has just approved the policy framework but has not yet built the operational infrastructure behind it, that gap is exactly where the next phase of work lies.
Approving a Carbon Market Framework is the beginning of sovereignty, not the end of it. The next steps are institutional and diplomatic simultaneously. Nigeria must operationalise its national registry as the mandatory authorisation point for credits entering international markets. It must require Letters of Authorisation and Corresponding Adjustments for all projects marketed as CORSIA-eligible or Paris Agreement-aligned. And it must join the coalition formally asking ICAO to update its rules to honour the sovereignty it has just committed to in writing.
The $3 billion annual opportunity that President Tinubu’s framework promises depends on Nigeria being able to transact as a sovereign actor in international carbon markets – not not as a territory whose assets are processed and priced by rules it did not help shape. Zimbabwe has navigated that distinction the hard way. Nigeria still has the opportunity to define its position before the pipeline scales and the structural dependencies deepen.
EDITORIAL NOTE: This article references President Tinubu’s approval of the Carbon Market Framework on 13 January 2026 (confirmed by NCCC Director-General Tenioye Majekodunmi), the Zimbabwe government press statement of 6 May 2026, and the Quantum Commodity Intelligence market report of 9 May 2026. The $3 billion revenue projection is the Federal Government’s own figure. The $3 vs $17 price differential is from Quantum market reporting. No unconfirmed Nigerian credit volumes are stated. Quotes from Minister Ndlovu are from the published government press statement of 6 May 2026.
