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12 May 2026

New Forestry And Energy Sector Regulations: The Push To Make The Philippines An Investor Destination Of Choice For High-Quality Carbon Credit Projects

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SyCip Salazar Hernandez & Gatmaitan

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SyCip Salazar Hernandez & Gatmaitan was founded in 1945 and is a leading full-service law firm in the Philippines. Its principal office is in Makati City, with branch offices in Cebu City, Davao City and the Subic Bay Freeport Zone. The firm offers a broad and integrated range of legal services, with departments in the following fields: banking, finance and securities; special projects; corporate services; litigation and dispute resolution; employment law and immigration; intellectual property; and tax.
The Philippines lacks comprehensive carbon rights legislation and carbon trading laws, yet carbon projects continue to develop across the country. In response to this regulatory gap and aligned with international climate commitments, Philippine regulators have recently issued new regulations establishing frameworks for carbon project implementation in the forestry and energy sectors.
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At present, the Philippines does not have carbon rights legislation which provides a comprehensive legal framework for carbon rights, including the recognition, transfer and benefits-sharing of carbon credits derived from emission reduction and emission removal activities. Likewise, it does not have a law governing carbon trading. Notwithstanding these gaps, a number of carbon projects have been carried out in the country over the years and more are currently under development.

In recognition of this reality and pursuant to the Philippines’ international commitments and national policy to promote climate change mitigation, regulators recently issued a series of regulations that seek to provide a framework for the implementation of carbon projects in the Philippines, particularly in the forestry sector and the energy sector.

Forestry Sector

On January 20, 2026, the Philippine Department of Environment and Natural Resources (“DENR”) issued DENR Administrative Order No. 2026-02 (Subject: Adoption of the Philippines’ Readiness in the Voluntary Forest Carbon Market: Roadmap (2026-2030)) (“Philippines VCM Roadmap”). The Philippines VCM Roadmap establishes the strategic framework for policy development, data analytics, institutional mechanisms, and sustainable financing for forest carbon. It is a five-year strategic plan to enhance the country’s capacity to develop and benefit from forest carbon projects under the Voluntary Carbon Market. The Philippines VCM Roadmap aims to establish, by 2028, a fully operational framework for forest carbon initiatives and, ultimately, to make the Philippines a desirable investment destination for high-quality, high-integrity forest carbon removal projects, grounded on internationally recognized best-practices.

This was followed, on February 24, 2026, by the issuance of DENR Administrative Order No. 2026-05 (the “Forest Carbon Credit Projects Guidelines”). The Forest Carbon Credit Projects Guidelines intend to provide a clear, coherent and effective set of procedures for establishing, registering and monitoring Forest Carbon Credit Projects in forest lands, protected areas under the National Integrated Protected Areas System (NIPAS), and ancestral lands and domains.

Energy Sector

On September 23, 2025, Department of Energy Department Circular No. DC 2025-09-0018 (General Framework for Carbon Credits in the Energy Sector). One of the Framework’s objectives is ensure alignment with the operationalization of engagements under Article 6 of the Paris Agreement, the exploratory implementation of carbon pricing instruments and participation in voluntary carbon markets. It provides for, among others: principles governing carbon credit certificates; mitigation activities that are eligible to generate carbon credits; allocation of carbon rights (i.e., legal entitlement to the benefits derived from emission reductions or emission removals); and recognition of various carbon trading markets (i.e., international compliance market; domestic compliance market; and voluntary carbon market).

Conclusion

The measures described above provide a level of transparency, credibility and stability not previously afforded to carbon projects in the Philippines. They evidence recognition by the Philippine government of the need to provide a clear and stable regulatory framework in order to promote the Philippines as desirable investment destination for carbon projects. While key components of a fully operational framework are still under development, the above-mentioned measures demonstrate the Philippine government’s commitment towards, and support for, carbon emissions reduction and removal projects and carbon trading.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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