净零碳市场监管路线图

Injy Johnstone, Sindi Kuci, Thomas Hale, Bhavya Gupta,Varnika Chawla & Kenneth Nicholas October 2025 Acknowledgements •Injy Johnstone| Smith School of Enterprise and the Environment; Oxford Net Zero, School ofGeography and the Environment: University of Oxford•Sindi Kuci| Smith School of Enterprise and the Environment: University of Oxford•Thomas Hale| Oxford Net Zero, School of Geography and the Environment; Blavatnik Schoolof Government; Oxford Martin School: University of Oxford•Bhavya Gupta| Blavatnik School of Government: University of Oxford•Varnika Chawla| Climate Asset Management•Kenneth Nicholas| Blavatnik School of Government: University of Oxford With thanks to stakeholders who participated in the April 2025 co-design Workshop on theRoadmap to Net-Zero Aligned Regulation. Thanks also to participants in workshops and sideevents convened in Islamabad, Pakistan and Addis Ababa, Ethiopia in September 2025 as well asto Eleonore Soubeyran for their review. Suggested citation Johnstone, I., Kuci, S., Hale, T., Gupta, B., Chawla, V. and Nicholas, K. (2025). Roadmap to Net-Zero Aligned Carbon Market Regulation. University of Oxford. The views expressed in this working paper represent those of the authors and do notnecessarily represent the authors’ institutions or other institutions or funders. The paper isintended to promote discussion and to provide public access to results emerging from ourresearch. It may have been submitted for publication in academic journals. The Chancellor,Masters and Scholars of the University of Oxford make no representations and provide nowarranties in relation to any aspect of this publication, including regarding the advisabilityof investing in any particular company or investment fund or other vehicle. While we haveobtained information believed to be reliable, neither the University, nor any of its employees,students, or appointees, shall be liable for any claims or losses of any nature in connectionwith information contained in this document, including but not limited to, lost profits orpunitive or consequential damages. Contents Executive summary4Abstract51.Introduction62.The Existing Carbon Market Regulatory Ecosystem102.1 What is Carbon Market Regulation?102.2 Carbon Market Regulation across Jurisdictions122.3 Notable Trends and Gaps in Carbon Market Regulation133.Roadmap to Net-Zero Aligned Carbon Market Regulation173.1 Pillar One: Efficient and Effective Financing183.2 Pillar Two: End-state of Net-Zero203.3 Pillar Three: Ecosystem Integrity213.4 Pillar Four: Equitable Responsibilities and Outcomes223.5 Pillar Five: Enforcement and Oversight233.6 Pillar Six: Ease of Use244Operationalising the Roadmap to Net-Zero Aligned Carbon Market Regulation264.1 Advanced Economies274.2 Developing Economies314.3 Emerging Economies355.Conclusion40 Executive summary •Carbon markets can be a critical tool on the path toward and beyond net-zero, with potentialto unlock finance for mitigation and adaptation activities and bring additional benefits forsustainable development and just transition goals. •To realise this potential, carbon markets must be effectively regulated. In recent years, therehas been a rise in such regulation globally, ranging from voluntary guidance to nationalpolicy. Such regulation has varied in scope and design, creating a patchwork of carbonmarket regulation that often lacks consistency with the wider domestic and internationalregulatory ecosystems it is embedded in. •More consistent and integrated approaches to designing carbon market regulation areneeded. Such approaches can ensure that governments utilise different types of carbonmarkets effectively, bringing them closer to rather than further away from domestic andglobal net-zero targets. To facilitate the design and operationalisation of carbon marketregulatory frameworks across jurisdictional contexts, we offer a ‘Roadmap to Net-ZeroAligned Carbon Market Regulation’. •This Roadmap identifies and builds on existing trends and gaps in the regulation ofcarbon markets and establishes six key pillars for its design or reform. It suggests thatgovernments seeking to regulate their approach to carbon markets should first beginwith identifying a clear role for carbon markets to ensure they provide (1) an efficientand effective financing framework and (2) align with an end state of domestic and globalnet-zero. Next, they should create or reform substantive regulation to ensure that themitigation outcomes derived from engagement with carbon markets uphold (3) ecosystem(environmental and social) integrity, while delivering and respecting (4) equitable outcomesand responsibilities across relevant stakeholders. Lastly, governments should rigorouslyimplement and oversee such regulation, establishing effective provisions for carbon market(5) enforcement and oversight, and promoting their (6) ease of use. •Implementing such a Roadmap is an iterative and reflexive process that should reflectdevelopments in the