Carbon: the new frontier in the scramble for land in Kenya

Around the world, the carbon offset industry is discreetly taking hold of vast stretches of land. Under the banner of fighting climate change, corporations and investors are striking deals that transform forests, grasslands, and agricultural fields into so-called “carbon sinks” in order to produce one thing: tradable carbon credits. Sold mainly to major polluters, carbon credits give corporations a licence to leave their business models untouched while claiming to be “net zero”.

Kenya sits at the heart of this scramble. At COP27 in 2022, Kenya’s President William Ruto declared carbon credits the cornerstone of the country’s economic future(opens in new window) , even envisioning them as Kenya’s primary export. Yet by attaching property rights to carbon, offsetting fuels an industry that further intensifies pressure on and encloses vast areas of land.

In 2025, land-based projects registered around the world under Verra – the largest carbon credit supplier in the voluntary carbon market – cover 24 million hectares(opens in new window) , an area roughly the size of Guinea(opens in new window) . About 80 per cent of these projects focus on conservation or activities related to tree plantations, and more than one-third are located in Africa, where land tenure rights are often insecure and customary systems lack legal recognition(opens in new window) .

In this context, offsetting schemes risk displacing communities and eroding communal control over their land. This raises urgent questions about who truly benefits from carbon offset projects, and at whose expense.

Pushed by industry, sold as development

The Kenyan government’s embrace of carbon markets is not happening in a vacuum. The country’s public debt has surged(opens in new window) past EUR 76 billion (KES 11.5 trillion), with interest payments alone swallowing almost 50 per cent of government revenue. In 2023/2024, the cost of servicing debt was more than twice(opens in new window) what the state spent on long-term projects – like building roads, schools, and hospitals.

At the same time, the country faces mounting climate impacts, while promised climate finance from countries in the Global North has largely failed to materialise. The database Climate Funds Update(opens in new window) , which monitors flows from major international climate funds, shows that Kenya secured only USD 146 million in climate finance between 2003 and 2025, far short of its estimated requirement of USD 62 billion(opens in new window) for 2020 to 2030.

Against this backdrop, the offset industry is being presented as a cure-all, promising to fund both climate mitigation and adaptation at the national and local levels. In practice, however, most money circulates among private industry actors in the Global North, diverting resources away(opens in new window) from communities’ urgent needs.

In 2022, Kenya’s President Ruto, alongside other African heads of state, launched the African Carbon Markets Initiative (ACMI), designed with the help of(opens in new window) US consultancy giant McKinsey. Despite its continental scope, no civil society representatives sit on the ACMI’s steering committee. Instead, the committee includes several industry figures(opens in new window) , such as Annette Nazareth of the Integrity Council for the Voluntary Carbon Market, a private, multi-stakeholder initiative whose executives are linked to(opens in new window) some of the world’s largest fossil-fuel and financial companies. Other members include key figures from the voluntary carbon market – such as David Antonioli and M. Sanjayan, former CEOs of Verra – and the US NGO Conservation International, which is directly involved in managing offset projects(opens in new window) worldwide, respectively.

Though the ACMI frames itself as a development opportunity, its leadership reveals a strong influence of industry actors. It promises to unlock USD 6 billion in annual revenues by 2030(opens in new window) and to “scale [Africa’s] carbon credit market 19-fold by 2030” compared to 2020. In doing so, it sells the idea that Africa can profit by selling its “carbon sequestration potential” to the very countries and corporations most responsible for the climate crisis.

Carbon offsets and land in Kenya

To assess the impact of the offset industry on land in Kenya, SOMO created a database of land-based offset projects in the voluntary carbon market operating in the country, identifying 36 active projects (see the methodological appendix). Altogether, these projects span more than 5.4 million hectares – nearly as much as Kenya’s total arable land.(opens in new window) The three largest projects, each spanning between 650,000 and 1.9 million hectares, collectively account for more than 65 per cent of the total area under carbon offsets.

The scale of land control exercised by the carbon offsetting industry in Kenya is striking. Of the 36 projects in our database, 11 are on smallholder land, yet the total size of these projects is anything but small. One example is the nine TIST (The International Small Group and Tree Planting Program) projects run by the US-based company Clean Air Action Corporation (CAAC). Promoted(opens in new window) as benefiting “small-scale subsistence farmers”, these projects involve more than 20,000 farmers and cover around 40,000 hectares, an area larger than Mombasa.

Although participants formally own the trees, project documents state that farmers must transfer all rights(opens in new window) to the carbon “stored” in those trees to CAAC. With project durations ranging from 29 to 60 years, documents also state that farmers must plant at least 1,000 trees, replant any that die, and refrain from cutting down trees except under “best practices” defined by TIST.

Arrangements like these risk dismissing farmers’ autonomy over planting, harvesting, crop choice, and other land-use decisions to safeguard carbon that is sold as credits, raising concerns about who ultimately controls the land.

These issues echo long-standing struggles over land in Kenya, where carbon offsetting now unfolds within deeply unequal and historically contested land tenure systems. Even where customary rights are formally recognised – which in Kenya is often not the case(opens in new window) – underlying land tenure systems remain profoundly unequal(opens in new window) . These dynamics are rooted in a long and violent history of land dispossession, contested authority, and power struggles over land and resources.

During British colonial rule, vast areas of Kenya were expropriated from communities(opens in new window) , often declared “Crown land” or turned into protected areas, severing Indigenous Peoples from their territories. Post-independence governments often upheld these structures, prioritising foreign investment (agribusiness, mining, conservation, infrastructure) over community land rights.

Carbon offset industry players in Kenya deepen the inequalities shaped by (neo)colonial land dispossession, elite capture, and weak protections for community tenure. This historical and policy context provides them with a favourable environment to secure land for offset projects, repackaging them in the language of climate action.

Legal reforms that enable, not restrain, exploitation

Building on the already corporate-friendly land tenure context, Kenya also introduced legal reforms to enhance the carbon market. The Climate Change (Carbon Markets) Regulations 2024(opens in new window) introduced new instruments, including a national carbon registry, mandatory environmental impact assessments for offset projects, and formal community development agreements requiring developers to share at least 25 per cent of revenues.

On paper, these measures appear to promote participation and benefit-sharing. In practice, however, a critical gap remains: the law fails to define carbon rights(opens in new window) – the ownership of the carbon “stored” in trees and soils. Without this clarity, communities risk losing control and autonomy over their territories. Trees, soils and vegetation, once sources of life and sustenance, are transformed into collateral for carbon credits.

As with the ACMI, Kenya’s national carbon registry has also been designed under the influence of external actors, among them the US consultancy giant S&P Global, the UK government, and Conservation International. In its white paper Unlocking the potential of carbon markets(opens in new window) , S&P presents carbon primarily as a “valuable national asset” to attract investment and accelerate economic growth – notably without mentioning land or community rights.

With enforcement capacity still developing and legal frameworks only emerging between 2023 and 2024, these foreign interests risk prioritising investor interests over protections for Kenyan communities. Verification standards, methodologies, and monitoring systems may reflect investor goals rather than community needs, thereby locking Kenya into a system in which foreign profit outweighs local equity.

Paper realities: FPIC, benefit-sharing, and grievance mechanisms

SOMO compiled its database from the project design documents of Kenya’s 36 land-based offset projects under Verra’s registry. Written by project developers, these documents outline intended consent processes, benefit-sharing arrangements, and grievance mechanisms. However, their framing reveals not only significant gaps but also the underlying power dynamics that shape how project proponents view communities and expect them to engage with these projects. Further research is needed to assess whether the already problematic claims in the design documents have, in fact, materialised.

Community consent and consultation process

Free, prior, and informed consent (FPIC) is a fundamental principle that requires that communities be meaningfully consulted, fully informed in advance, and able to freely accept or reject a project that affects their lands, livelihoods, and cultures. Despite FPIC being enshrined in the United Nations Declaration on the Rights of Indigenous Peoples(opens in new window) since 2007, only in 2024 did Verra’s Nature Framework incorporate a dedicated process for consultation and learning with Indigenous Peoples. Even so, the (lack of) implementation of FPIC in offset projects often raises serious concerns(opens in new window) .

Nineteen of the 36 project design documents in our database mention FPIC. However, only six provide any detail on how FPIC is to be implemented. Strikingly, two of the largest projects(opens in new window) – the Northern Kenya Grassland Carbon Project (see Box 1) and the Kajiado Rangelands Carbon Project – together spanning nearly 3 million hectares, have faced accusations from community members of failing to follow proper consent procedures.

The Northern Kenya Grassland Carbon Project was among the few that described its FPIC process. Yet a court ruling(opens in new window) found “no evidence that public participation was facilitated” in relation to the establishment of the project activities in unregistered community lands. This directly contradicts the project’s claims in its documentation that it has secured FPIC. In the Kajiado project, community consent appears to be even more dubious, as the FPIC process is described(opens in new window) merely as “circulat[ing] an email address and phone number to communities”, a sign of a deeper, structural problem(opens in new window) .

Further, communities often sign contracts waiving their rights to the carbon stored in their lands, ultimately waiving control over their land. This is especially troubling given that 89 per cent of the projects are designed to last between 20 and 100 years, locking communities into arrangements that will shape land use, access, and control for generations. On top of that, these contracts are sometimes “irrevocable”(opens in new window) , preventing communities from withdrawing or renegotiating their terms, even when promises are broken or circumstances such as climate impacts change.

Benefit-sharing?

The project documents reveal a wide range of ways in which developers describe the benefits of their initiatives. These benefits can take the form of financial returns as well as non-economic gains such as job creation, training, or community development, or a mix of both. In some cases, these non-economic benefits are framed in ways that expose the stark power imbalances between project developers and local people.

The Kasigau Corridor REDD Project(opens in new window) (see Box 2), for instance, explicitly ties community livelihoods to compliance with project goals: “A pact with the community exists: if they value the jobs, they agree to stop clearing the forest and damaging biodiversity, or we will not be able to sell products, and they will lose their jobs.” Such framing risks creating conflicts within communities, between those who have secured jobs and those who still depend on the land for their survival.

Grievance mechanisms

Grievance mechanisms are meant to provide communities with a formal and accessible way to raise concerns, contest harms, and seek remedies when projects affect their rights, resources, or livelihoods. All major carbon standards now formally require them. For instance, Verra has a grievance redress policy(opens in new window) that applies to all its programmes. Yet, in practice, the majority of projects in our database did not reference grievance mechanisms, despite being approved by auditors and accepted by the registry that issued the credits.

Where grievance mechanisms were mentioned, they often lacked independence. In several cases, communities were instructed to bring complaints without ensuring anonymity. For instance, the Komaza Smallholder Farmer Forestry project(opens in new window) , which involves 25,000 farmers, states: “Farmers […] can report feedback, concerns, and complaints directly by calling a hotline. All feedback is received, registered, documented, and reviewed by Komaza [the company].”

Similarly, the Hongera project(opens in new window) directs complainants to contact the project staff, investors, or the Ministry of Environment and Forestry. In Kajiado(opens in new window) , people are asked to approach local leaders, a course that risks reinforcing existing hierarchies and power imbalances, or even creating new divisions within communities. Such arrangements fall short of providing independent and trustworthy avenues for redress, leaving communities with little real control or recourse.

From land in Kenya to foreign profits

The carbon offset industry comprises a complex network of actors with significant financial stakes. This includes those who establish and oversee standards, those who monitor project compliance, and the project developers themselves – all of them with incentives to approve projects and generate the most credits. While financial flows in this industry often remain opaque(opens in new window) , profits primarily accrue to project developers, auditing firms, brokers, standard-setting bodies, and other intermediaries, while communities are left with vague promises tied to the uncertain sale of a highly unstable commodity.

Of the 36 carbon offset projects in SOMO’s dataset, 30 were developed by companies based in the Global North. Only six had roots in Kenya, either fully Kenyan or part of a consortia involving proponents from both Kenya and the United States. The pattern is unmistakable: those reaping the profits from Kenya’s land-based carbon offsets are mainly based outside the African continent.

A similar dynamic emerges among the industry’s auditors. These entities pay standard-setting bodies such as Verra, which are also the registries, to become accredited, and are then contracted and paid by project developers to carry out auditing reports. Across the 36 projects, SOMO identified 92 audits conducted between 2004 and 2024 (49 verifications and 43 validations). Three-quarters of the auditors are headquartered in the Global North, with the remainder located in India (see map below).

At the other end of the chain are the buyers of carbon credits, among them major corporations such as Shell, Delta Airlines, Apple, and Netflix. These companies purchase credits to compensate for their emissions and to claim progress towards voluntary climate targets like “net zero” or “climate neutrality”. Yet after two decades of carbon offsetting, global emissions continue to rise. As SOMO’s earlier research shows, companies relying on offsets have not decarbonised faster; on the contrary, offsets have enabled them to expand their business operations, effectively turning land into corporate profit and continued pollution elsewhere.

Together, these findings reveal a broader truth: wealth and control in the carbon offset industry remain concentrated far from the countries and communities whose land and lives are reshaped by these projects.

Commodifying the climate and shifting the burden onto Kenya

In an expanding global carbon market, the government of Kenya is positioning itself to profit from opening this new market domestically. Yet carbon markets are shaped by long-standing patterns of power, ownership, and control, often building on historically unequal land tenure systems that have excluded communities from secure land access. Rather than resolving these issues, the expansion of carbon markets risks deepening land conflicts.

Climate justice requires confronting the structural inequalities that drive the crisis. Forests, rangelands, and community territories cannot be reduced to carbon accounts for foreign polluters; nor should vulnerable countries, least responsible for the crisis, be pressured to commodify their territories to finance survival. Real solutions must prioritise land rights, ecological integrity, and systemic emission reductions over the financial interests of corporations. Instead of imposing new markets that entrench dependency, measures such as debt cancellation could give countries like Kenya the space to pursue their own paths towards resilience and justice.

The research for the database was carried out by Juliet Kariuki.