Executive summary
‍

Bangladesh has early experience with nature-based carbon markets. Currently, the country hosts mangrove projects registered under Verra, alongside other nature-based projects under Verra and Gold Standard. These projects demonstrate that developers can implement and register nature-based carbon activities in the country, despite gaps in the national regulatory framework.
‍

Bangladesh has not yet adopted binding requirements specifically for nature-based projects in the voluntary carbon market. The draft Bangladesh Carbon Market Framework proposes different pathways for projects participating in the Voluntary Carbon Market (VCM), seeking Article 6 authorization, corresponding adjustments, or CORSIA eligibility. It would require national registration, annual reporting, standardized MRV, safeguards, and additional approvals for Article 6 projects. However, the framework remains under review and has no legal effect. In the meantime, projects must obtain environmental clearance and any applicable forestry, water, land-use, or protected-area approvals. Bangladesh lacks a single approval pathway, and requirements vary by location, activity, and land status.
‍

The regulatory framework recognizes the importance of community participation and equitable benefits, but it does not yet establish clear, binding requirements for nature-based carbon projects. The draft framework promotes equitable benefits, livelihoods, employment, gender equality, stakeholder consultation, and accessible grievance procedures, while the Environmental Conservation Rules require public consultation for projects subject to an environmental impact assessment. However, Bangladesh has not set minimum benefit-sharing requirements or established a clear Free, Prior and Informed Consent (FPIC) process for Indigenous Peoples and Local Communities (IPLCs).
In Bangladesh, the State owns and manages most mangroves, particularly the Sundarbans Reserved Forest, although private and community ownership also exists. Different arrangements govern access to and management of forest areas, including social forestry, co-management, and joint management agreements. Communities and private organizations may manage State forests through social forestry, co-management, joint management, or other written agreements. Private owners and communities with valid titles may also develop projects on their land, subject to all applicable environmental, social, land tenure, forestry, and carbon-market requirements. However, Bangladesh does not clearly define carbon rights or identify who owns the carbon stored in mangroves. This gap creates uncertainty when ownership, management, and use rights overlap.
‍

Overall, Bangladesh has ambiguous enabling conditions for blue carbon projects: existing projects demonstrate market potential, but regulatory and ownership gaps increase development and investment risks. Developers should conduct site-specific due diligence, engage government agencies early, and clearly define carbon rights, community participation, benefit sharing, and responsibilities in project agreements. Finalizing the Carbon Market Framework and aligning it with environmental, land, and forest rules would improve regulatory certainty and investment readiness.