In January, roughly 700 people lost their jobs when KOKO Networks closed its doors. The company had built its business on a simple bargain with Kenyan households: supply bioethanol cooking fuel cheaply, then recover part of that subsidy through carbon revenues. When the government declined to issue the letter of authorisation KOKO needed to sell its clean-cooking credits under CORSIA and Article 6, the revenues underpinning that bargain could no longer be relied upon. By October, administrators were struggling to find a meaningful buyer for the credits left in the company’s estate. The people affected were cooks and workers in Kenyan homes and businesses, not delegates in negotiation rooms, and their story frames a question African governments can no longer avoid.
That question surfaced, awkwardly, at the Carbon Markets Africa Summit in Kigali this October. The summit’s language was one of delivery: investment-ready projects, credible credits, willing buyers, transactions at scale. COP31 was a month away, and climate finance remained scarce. Yet a week before the gathering, Kenya had announced a cumulative ceiling of 10 million tonnes of CO2-equivalent for international transfers between 2025 and 2030, a measure designed to safeguard its own climate commitments. Kigali was asking how Africa might export more carbon. Nairobi was asking how much carbon it could afford to export at all. The human cost of that contradiction, and of the uncertainty surrounding sovereign authorisation, had already been paid in Kenya by KOKO’s employees and the households its fuel served.
The deeper tension is accounting-based, but its consequences land on ordinary people. Under the Kyoto-era model, African carbon markets were organised to produce inexpensive emissions reductions for buyers elsewhere. The Paris Agreement changed the basic transaction. When a country authorises credits for international transfer, corresponding adjustments ensure that a reduction counted abroad cannot also count towards the host country’s nationally determined contribution. What leaves the country is the accounting entitlement to the reduction itself. A government that transfers a cheap reduction may later have to find a costlier one to meet its own pledge. In my November 2025 APRI essay, available at https://afripoli.org/reforming-african-carbon-markets, I described this persistence of a Kyoto reflex in a system whose treaty obligations have moved on.
Kenya’s ceiling and KOKO’s collapse reveal the same problem from opposite directions. Developers may create and hold credits, but their use in particular international markets depends on a sovereign decision. KOKO’s model relied on selling about 6 million credits a year. Against a national ceiling of 10 million tonnes for 2025 to 2030, one company would have exhausted the entire allowance in under two years. When a private business treats such a decision as routine paperwork, it may discover that the state’s carbon budget is neither its property nor an inexhaustible export licence. Equally uncomfortable is the flip side: withholding permission does not automatically create a domestic buyer. Protecting national headroom without building a market at home can strand commercial value, jobs and the mitigation activity itself, which is precisely what KOKO’s workforce experienced.
By contrast, Asian economies have confronted the same dilemma with different outcomes. Indonesia paused international carbon trading in 2021 by making foreign sales conditional on meeting sectoral NDC targets. With domestic trading still thin, it reopened in October 2025 under Presidential Regulation 110/2025, which allows international trading to proceed before those targets are met. In December 2022, India declared that credits would be used first towards its own NDC, with selective external sales possible. Vietnam’s April 2026 decree established differentiated ceilings on international transfers, including limits tied to the mitigation activity concerned. The policies differ, but India and Vietnam both make the export market answer to the domestic climate balance sheet. Indonesia applied that rule before it had domestic demand to absorb what it held back, and had to relax it.
None of this renders international trading futile, and Indonesia’s reopening shows governments still want the foreign capital it brings. What changes is that permission to trade becomes more valuable, and more politically contested, once governments understand what surrendering it means. Africa is approaching that moment with an export industry already under construction and domestic markets still thin. The Africa Carbon Markets Initiative, launched at COP27, aspired to 300 million credits a year, USD 6 billion in revenues and 30 million jobs by 2030. Those remain ambitions, not outcomes, and producing credits is not the same as holding permission to export them, just as permission is not the same as a viable price.
An indiscriminate export ban would be the wrong answer, since it could extinguish the foreign finance on which many existing projects depend before domestic demand has emerged. Reform requires sequencing: credible national emissions accounts, published eligibility criteria, approval deadlines and review procedures for authorisation and corresponding adjustments, registries able to track both domestic retirement and international transfer, and domestic compliance obligations or purchasing arrangements that give locally retained reductions a price. Community benefits and financing must attach to actual projects, not merely to expectations of a future foreign buyer.
Meanwhile, at COP31 in Antalya, African governments should seek support for national emissions accounting, carbon registries and domestic purchasing mechanisms, and the measure of progress should change. Some credits will properly be sold abroad, once national mitigation budgets identify a credible surplus after domestic commitments and a prudential reserve. Others will be worth more retained at home. That distinction should arise from sovereign accounting and domestic value, not the accident of where the first buyer happens to sit. Africa’s success cannot begin with how much raw carbon it exports. It must begin with how much value its carbon reductions create at home, for the households, workers and communities the market is meant to serve.