International Comparative Studies - Ghana Briefing

About this briefing:

• Ghana is not designing its forest carbon framework in a vacuum. Other forest 
countries have confronted the same questions , who owns carbon, who may sell it, and how communities share in the proceeds, and their successes and missteps are instructive. 

• Liberia shows the cost of transacting before legislating. A 2023 memorandum of 
understanding granting a foreign company carbon rights over roughly a million 
hectares, signed without community consent or a legal framework, triggered a 
national backlash; Liberia is now building its carbon market policy, registry and 
Carbon Markets Authority after the fact. 

• Kenya shows what statutory benefit sharing looks like. Its 2023 amendment Act and 2024 Carbon Markets Regulations guarantee communities at least 40 per cent of net earnings from land-based projects, secured through mandatory community development agreements. 

• Zambia and Indonesia illustrate state-centred models, with carbon authorisation, verification and registries controlled by central government, administratively strong, but with weaker community entitlements and, in Indonesia’s case, a market that regulation alone has not made liquid. 

• Australia shows the property-law endgame: carbon rights as registrable interests in land, credits as statutory personal property, and consent rights for every interest holder, the model most relevant to the “ecosystem service” pathway proposed in Briefing 1 (Ownership and Attribution of Forest Carbon Rights).