October 2025 Table of contents Executive Summary Introduction 1What are Carbon Markets?5 1.1Compliance Markets1.1.1Cap-and-trade1.1.2Main markets 1.2Voluntary Carbon Markets1.2.1Voluntary and international1.2.2Standards and integrity 2Interaction between compliance and voluntary markets2.1.1Carbon offsets acceptance in national and regional compliance markets2.1.2Compliance Offset Markets 3Growth and internationalisation drivers3.1.1Article 6 of the Paris Agreement 3.1.2The EU CBAM3.1.3Carbon offset recognition 4The opportunity for sustainable finance and the wider market4.1.1Limited recognition of carbon offsets for transition targets 4.1.2Innovation in sustainable bonds4.1.3Risk management and secondary trading in carbon markets 121213 Conclusion14 Annex 115 ICMA Authors: Enquiries to:info@icmagroup.orgPress enquiries to:pressoffice@icmagroup.org This publication is an ICMA staff paper benefitting from the input of ICMA committees and members but does not necessarily represent their views. This paper is provided for information purposes only and should not be relied upon as legal, financial, or other professional advice. While the informationcontained herein is taken from sources believed to be reliable, ICMA does not represent or warrant that it is accurate or complete and neither ICMAnor its employees shall have any liability arising from or relating to the use of this publication or its contents. Likewise, data providers who providedinformation used in this report do not represent or warrant that such data is accurate or complete and no data provider shall have any liability arisingfrom or relating to the use of this publication or its contents © International Capital Market Association (ICMA), Zurich, 2025. All rights reserved. No part of this publication may be reproduced or transmitted in anyform or by any means without permission from ICMA. Executive Summary Carbon markets contribute significantly to the reduction of global greenhouse gas emissions. These markets incorporateregulatory-driven national and regional compliance markets which trade carbon allowances alongside internationalvoluntary markets that involve carbon offsets. Both have created opportunities for the financial markets in trading and riskmanagement, and represent a nascent opportunity for sustainable finance, particularly in the sustainable bond market. Compliance carbon markets (CCMs) are the dominant force with near USD 950 billion of traded allowances in 2024,covering over a quarter of global emissions. These regulated systems—primarily structured around cap-and-trade—areexpanding globally, led by the European Union Emissions Trading System (EU ETS), North American systems, and China’sETS, with additional markets under development notably in India, Japan and Turkey. The EU’s Carbon Border AdjustmentMechanism (CBAM) is expected to accelerate international adoption of compliance systems by incentivising EU tradingpartners to introduce them. Voluntary carbon markets (VCMs), though much smaller (USD 535 million of traded carbon offsets in 2024), offer globalreach and flexibility but face persistent credibility challenges. Initiatives such as the Integrity Council for the VoluntaryCarbon Market (ICVCM), the Voluntary Carbon Markets Integrity Initiative (VCMI), and IOSCO’s Good Practices areworking to strengthen integrity and standardisation. It is, however, hybrid markets, mainly the Carbon Offsetting andReduction Scheme for International Aviation (CORSIA) implemented by the International Civil Aviation Organisation (ICAO),a United Nations agency, that largely provide the demand for carbon offsets. For sustainable finance, the recognition and role of carbon offsets remain limited. International standards such as theScience Based Targets initiative (SBTi), as well as ICMA’s Climate Transition Finance Handbook, restrict offsets primarily toresidual emissions, limiting their use in transition targets. Nonetheless, innovative structures are emerging, such as WorldBank “outcome bonds” that link returns to the value of generated carbon credits. The most significant near-term financial opportunity lies in risk management and secondary trading within compliancemarkets. The EU ETS alone generated EUR 648 billion in secondary trading in 2023, largely through derivatives. As morejurisdictions establish compliance markets, carbon derivatives and trading platforms are poised for substantial growth,attracting banks, investors, and other financial institutions. In conclusion, voluntary markets may benefit from further progress on integrity and recognition to grow, but in the nearto medium term they will remain dependent on whether CORSIA moves to its planned second and mandatory phase.The intersection with sustainable finance represented by outcome bonds is innovative but may not be scalable. From afinancial market perspective, it is therefore compliance markets and their international expansion that represent the realopp