The Portuguese Voluntary Carbon Market (“VCM”) aims to achieve carbon neutrality by reducing Greenhouse Gas (“GHG”) emissions and sequestering carbon. The rules governing the management of this new market’s online platform have been published in three ministerial orders, complementing the guidelines outlined in Decree-Law n. º 4/2024, establishing the VCM, enacted in January of this year.

Ministerial Order n. º 241/2024/1, sets the general requirements for the online platform, allowing promoters—individuals and public and private organizations developing GHG emission reduction or carbon sequestration projects in Portugal—to submit their proposals.

The platform will enable market participants to register by creating an account. Initial and periodic validation of projects or programs will occur through reports submitted by the promoter. In a later phase, the platform will include functions for issuing, transferring, and cancelling carbon credits. Promoters will have these credits stored in their accounts, to convert Future Carbon Credits (“FCC”) into Verified Carbon Credits (“VCC”).

Ministerial Order n. º 239/2024/1 establishes the fees to be charged under the VCM by the supervisory and management entities of the registration platform. These fees include a one-time opening fee (€500 for companies and €50 for individuals) and an account maintenance fee (€120 for companies and €10 for individuals). Additional fees apply for registering carbon programs and projects (€0.2 per transaction) and for approving methodologies proposed by market participants, which can reach up to €3,000.

Ministerial Order n. º 240/2024/1, effective at the beginning of next year, defines the qualification criteria for independent verifiers of GHG emissions mitigation projects. ADENE, the Portuguese energy agency, under the supervision of the Portuguese Environment Agency, I.P., will be responsible for determining the qualifications of these verifiers, which will vary by sector—energy, industry, agriculture, land use, wetlands, marine areas, and waste.

This complementary regulation was essential for operationalising the MVC in Portugal, although there is still no date set for the new platform to go live.

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