Business as usual? Article 6 carbon markets and land conflicts

Land-intensive projects linked to the carbon markets under Article 6 of the Paris Agreement can put customary land rights and rural livelihoods at risk. Land Matrix evidence shows why stronger safeguards must accompany climate investment under Article 6 and beyond.

Climate mitigation urgently needs investment. But the land required for reforestation, forest conservation, and large renewable energy projects is rarely an empty space: it often already sustains livelihoods and deeply rooted cultural practices. The question is not only how much carbon these projects can reduce, but also whose land they use, who benefits, and who bears the costs of implementation.

While the already ceased Clean Development Mechanisms (CDM) and the decentralised Voluntary Carbon Markets (VCM) have long been the primary mechanism to offset emissions, Article 6 of the Paris Agreement has created new opportunities for cross-country cooperation on climate mitigation in recent years. Article 6.2 provides a framework for countries to transfer mitigation outcomes, while Article 6.4 establishes the UN-supervised Paris Agreement Crediting Mechanism. These frameworks provide the chance to strengthen safeguards for carbon offset projects, in particular as the carbon standards of the VCM are likely to align to some extent. But they also raise the risks for target regions and affected communities as the demand for carbon offsetting could accelerate.

Land-intensive projects are already in the pipeline

The need to establish robust safeguards early on, in particular for land rights of affected communities, is motivated by the presence of land-intensive projects that are in the Article 6 pipeline. An analysis of projects in Africa, Latin America, and Southeast Asia, where land governance and protection of customary land rights is often weak in key regions, identifies potentially land-intensive activities across three groups:

• 73 of 352 projects (20.7%) among CDM projects with host-party approval for transition to Article 6.4.
• 62 of 426 projects (14.55%) among projects with prior consideration notifications under Article 6.4.
• 12 of 222 projects (5.4%) among projects associated with Article 6.2.

There are, however, some caveats to this analysis. First, the number of projects alone obscures the importance of scale: three of the five largest projects in the Article 6.2 pipeline, measured by planned emission reductions, can be classified as land-intensive. Second, the classification only identifies potentially land-intensive activities; it does not measure actual land requirements or establish harm. Nevertheless, at the current stage, these figures present risks rather than actual impacts. The projects are at different stages and not only fully registered or operating Article 6 activities. A prior consideration notification, for example, signals an intention to seek registration; it is not registration itself. Still, if projects move forward there could be severe implications for the land rights and livelihoods of the affected communities.

Land access arrangements and associated governance risks within Article 6 projects

How land-intensive projects secure land matters as much as their potential footprint. Land acquisitions have been identified in Land Matrix reports as creating substantial risks for affected communities in cases where their land rights are not recognised. In a preliminary land-access analysis of a subset of land-intensive projects under Article 6, land acquisitions are identified for 24 CDM-transition projects and 23 Article 6.4 prior-consideration projects. The risks associated with carbon offset projects extend, however, beyond formal land acquisitions, as projects may establish control over land and natural resources without transferring ownership. This is particularly relevant for projects under Article 6 of the Paris Agreement involving state land or legally recognised Indigenous Peoples’ territories, where specific land use and management rights can change through contractual arrangements that could also affect land rights and local livelihoods. Yet, for many projects, information on how land is accessed and what arrangements govern its use remains incomplete or unclear. This lack of transparency is itself a governance risk.

Land acquisition remains the primary means of securing land for carbon offset projects in the Global South

While more comprehensive data on other forms of land access for carbon offsetting remain scarce, the Land Matrix provides robust evidence on the scale and evolution of land acquisitions associated with carbon projects. Across many carbon-market mechanisms, not Article 6 alone, the Land Matrix data record more than 250 intended and concluded large-scale land acquisitions associated with carbon offset projects, totalling 11 million hectares. A substantial share remains registered exclusively under Verra's Verified Carbon Standard (VCS), although an increasing number are linked to Article 6 through CDM transition, prior consideration notifications, or cooperative approaches between countries. Importantly, many of the associated land acquisitions took place years ago, suggesting that emerging Article 6 mechanisms are not only driving new investments, but also creating opportunities to repurpose ongoing land investments for carbon offsetting.

The risks of carbon offset projects are not theoretical; they lead to actual impacts on the ground

Our 2025 analytical report, Large-scale land acquisitions for carbon offsetting: Green grabbing or just transition?, places the reported pressures in a wider context. It highlights both the potential benefits of land-based offset projects and the adverse impacts to smallholders, pastoralists, Indigenous Peoples, and local communities when investments proceed without robust safeguards and meaningful local decision-making.

Several Land Matrix reports highlight more specific concerns surrounding carbon markets as well.

Our Deal Narrative on two carbon offset projects in Laos shows that companies’ production processes and contract arrangements can conflict with local perceptions of what is fair and just, often leading to severe conflict. The prevalence of conflicts and associated damages, such as frequent fires and ensuing carbon emissions, also threaten to upend the sustainability of the projects.

The Deal Narrative on Indonesia's rainforest carbon projects finds contrasting levels of community benefit from two otherwise similar projects. Although the communities studied reported no immediate adverse impacts, interviews revealed gaps in information, consultation, and access to grievance procedures. The findings also highlight the substantial degree of discretion project developers have when it comes to distributing co-benefits to adjacent communities.

The Deal Narrative on Argentina’s Selva de Urundel REDD+ project reveals gaps between project objectives and local communities’ experiences, particularly regarding access to natural resources, consultation, and benefit-sharing. The findings again highlight how carbon standards focused on formal land ownership and project boundaries can overlook customary land-use practices, diminish negotiated co-benefits to handouts that happen at the discretion of the project developers, and exclude communities from decision-making.

What Article 6 safeguards need to deliver

The priority is not simply more consultation; greater decision-making authority for people whose land and livelihoods are at stake is imperative too.

Recognise rights before approving projects. Safeguards should uphold international human rights standards where national law is weak or exclusionary, and protect Indigenous Peoples, local communities, and other customary rights-holders. Robust tenure clarification must identify overlapping claims and unresolved disputes before project approval, rather than treating formal land records as the whole picture.

Make consent an ongoing requirement. Free, prior and informed consent (FPIC) and consent-based safeguards should extend throughout the project lifecycle and cover all land-related impacts, including economic displacement. Losing access to livelihood resources matters even when people are not physically relocated.

Move from consultation to participation. Communities need a meaningful role in decisions, accountability for commitments, and accessible grievance mechanisms. Benefit-sharing arrangements should be transparent and responsive to local priorities, rather than substituting promised benefits for rights and participation.

The involvement of the UN should be used as an opportunity to improve the governance of climate investment and limit offsetting to projects with high environmental and social integrity. Standards and processes also need to be urgently improved. A recent analysis of the Sustainable Development Tool that governs social safeguards under Article 6.4, Trading carbon credits for human rights: Does Article 6.4 of the Paris Agreement protect Indigenous Peoples and local communities?, underlines that current safeguards are insufficient in many circumstances .A just transition must be judged not only by the carbon credited, but also by whether the people who depend on the land can shape its future.