EXECUTIVE BRIEF: The ASEAN Carbon Credit Dilemma – Navigating Double Counting Risks in Southeast Asia’s Climate Market
Executive Summary
ASEAN faces a critical challenge in its climate transition: the persistent risk of double counting in carbon credit markets. As the region’s economy grows to become the world’s fourth largest by 2030, with CO₂ emissions projected to rise 139% from 2015 to 2040, the integrity of carbon accounting becomes paramount.
The core issue is structural: governments count emission reductions toward their Nationally Determined Contributions (NDCs) while corporations simultaneously claim the same reductions for ESG reporting. This double counting threatens the credibility of both national climate pledges and corporate sustainability commitments, potentially undermining ASEAN’s position in global climate negotiations and limiting access to climate finance.
The Singapore-Thailand landmark carbon credit agreement under Article 6.2 of the Paris Agreement demonstrates a path forward through proper Corresponding Adjustments. However, regional coordination, robust infrastructure, and harmonized regulations remain critical to building a credible carbon market that can unlock billions in climate finance while maintaining integrity.
This report provides actionable recommendations for governments and companies to navigate these challenges and strengthen ASEAN’s carbon market framework.
The Carbon Credit Dilemma: A Growing Challenge
ASEAN’s rapid economic growth presents both opportunities and risks for climate action. The region contributed 6.87% of global greenhouse gas emissions between 1990-2019, with a population expected to exceed 770 million by 2040. Beyond industrialization pressures, ASEAN faces severe climate risks including typhoons, floods, and haze that cause billions in annual damages.
This urgency drives both governments and corporations to pursue aggressive climate targets. However, beneath aligned ambitions lies a fundamental question: who truly owns the carbon claim when the same emission reduction is counted by multiple parties?
The stakes are high. For governments, NDC integrity serves as the currency of global climate diplomacy. For corporations, credibility forms the foundation of ESG commitments increasingly scrutinized by investors and regulators.
Governments vs. Corporates: One Reduction, Two Claims
The double counting issue stems from parallel but separate accounting systems. Governments report progress through NDCs to the United Nations Framework Convention on Climate Change, while corporations disclose climate action through frameworks like the Carbon Disclosure Project, RE100, or Science Based Targets initiative.
Consider Malaysia’s renewable energy sector. When Tenaga Nasional Bhd builds a solar farm, its renewable output counts toward Malaysia’s NDC target. If that project issues Renewable Energy Certificates (RECs) sold to a multinational company, the buyer can claim “100% renewable energy” in ESG disclosures. One unit of clean energy is effectively counted twice.
This creates risks for both parties:
- Governments: Inflated NDC figures damage credibility and limit access to international climate finance
- Corporates: Double-counted claims lose value and create reputational risks amid growing scrutiny of greenwashing
Cross-Border RECs: The Integrity Gap
Cross-border REC transactions amplify double counting risks. When a Singapore-based company purchases RECs from an Indonesian wind farm, Indonesia counts the renewable electricity toward its NDC while the Singaporean company claims clean energy for its operations. Both claims cannot be simultaneously accurate.
The complexity deepens as Singapore serves as a regional trading hub where multinationals consolidate sustainability procurement, even when operations span Vietnam, Indonesia, Thailand, or the Philippines. Without robust transparency and clear accounting rules, this disconnect between renewable generation location and environmental benefit claims creates systemic vulnerability.
Corresponding Adjustments Under the Paris Agreement
Article 6 of the Paris Agreement addresses double counting through Corresponding Adjustments (CAs). The principle is straightforward: any cross-border transfer of emission reductions requires adjustments to ensure only one country claims the reduction in its NDC.
When Indonesia transfers renewable energy credits to Singapore, it must deduct equivalent emissions from its climate target while Singapore adds the transferred amount to its NDC tally. This maintains accounting integrity and prevents double counting.
However, implementation proves complex, requiring:
- Robust national accounting systems
- Clear registry integration
- Legal frameworks aligned with international standards
- Reconciliation between corporate claims and national inventories
Many ASEAN countries face challenges including fragmented energy systems, limited digital infrastructure, and inconsistent reporting protocols.
Singapore-Thailand Carbon Credit Deal: A Regional Blueprint
On August 19, 2025, Singapore and Thailand signed a landmark Implementation Agreement under Article 6.2, enabling formal transfer of Internationally Transferred Mitigation Outcomes (ITMOs) between nations.
For Singapore, this first bilateral carbon credit partnership demonstrates commitment to sourcing high-quality credits within ASEAN while reinforcing its position as a regional hub for carbon services. For Thailand, the agreement provides access to financing opportunities for local carbon projects.
This collaboration serves as a blueprint for regional carbon market development. While Indonesia and Malaysia have explored domestic carbon pricing, regional cooperation has been limited. The Singapore-Thailand deal proves ASEAN countries can collaborate under Article 6.2 to achieve NDCs while attracting international investment.
Skylight’s Opinion
ASEAN ranks among the world’s most climate-vulnerable regions, with millions depending on agriculture, forestry, and coastal ecosystems. A well-structured regional carbon market could unlock billions in climate ffnance, protect critical natural assets, and accelerate low-carbon transition.
However, structural weaknesses persist: regulatory gaps, fragmented frameworks, and double counting risks. Without strong governance and transparency, these issues could erode trust in government climate pledges and corporate ESG commitments, weakening ASEAN’s credibility in global negotiations and limiting climate finance access.
The region stands at a crossroads. ASEAN can lead the global energy transition, but only by addressing these challenges through coordinated action, robust infrastructure, and unwavering commitment to integrity.
Recommendations For Governments
Strengthen Regional Coordination: Establish ASEAN-level guidelines on carbon credit accounting, including clear Corresponding Adjustment rules under Article 6.2 to prevent double counting.
Invest in Infrastructure: Develop robust national and regional registries to track emission reductions, integrate with global systems, and ensure transparency for domestic and international stakeholders.
Harmonize Regulations: Create consistent policies across ASEAN to reduce market fragmentation and facilitate cross-border carbon credit transactions.
Encourage Private Sector Engagement: Introduce incentive schemes including tax benefits and green financing for corporations participating in verified carbon projects aligned with national climate targets.
Recommendations For Companies
Prioritize ESG Integrity: Avoid purchasing RECs or offsets that create double counting issues. Seek credits backed by Corresponding Adjustments or aligned with recognized global standards.
Enhance Transparency: Disclose methodologies and verification processes in sustainability reports to maintain investor confidence and mitigate greenwashing risks.
Diversify Climate Strategies: Combine offset purchases with real decarbonization actions including energy efficiency improvements, renewable energy procurement, and supply chain engagement.
The path forward requires unprecedented collaboration between governments, corporations, and regional institutions. ASEAN’s climate future depends on building a carbon market that balances ambition with integrity, ensuring environmental claims reflect genuine impact while attracting the investment needed for sustainable development.
Latest Update
- PT Godrej Consumer Products Indonesia New Factory in Kendal SEZ
- PT Godrej Consumer Products Indonesia (GCPI), a subsidiary of the Indian multinational conglomerate Godrej Group, has officially commenced construction of its new factory in the Kendal Special Economic Zone (SEZ). Godrej is known for producing popular household brands such as HIT (insecticide), Stella (air freshener), and Mitu (baby care products).
- The new factory represents an investment of IDR 500 billion (approximately US$ 8 million) and spans an area of 5.5 hectares. It is projected to begin operations by June 2026.
- The factory is expected to create significant employment opportunities, adding to Godrej’s existing workforce of approximately 5,000 people in Indonesia, both directly and indirectly.
- Godrej entered the Indonesian market in 2010 through the acquisition of PT Megasari Makmur, a leading home and personal care company, and now operates multiple manufacturing facilities, including in Jakarta and Surabaya.
- Bank Indonesia Launched Cross-border QR Payment System to Japan
- On August 17, 2025, Indonesia and Japan officially launched a cross-border QR payment system, enabling transactions in rupiah or yen without currency exchange.
- The system will first be available at World Expo 2025 in Osaka and Haneda Airport, with plans to expand across Japan.
- This move follows earlier QRIS adoption in Malaysia, Singapore, and Thailand, strengthening Indonesia’s regional payment connectivity.
- Building on this momentum, Bank Indonesia (BI) is advancing partnerships with China and Saudi For Saudi Arabia, BI aims to link QRIS with the Nusuk platform, the official digital service for Umrah and Hajj pilgrims, to support convenient and secure transactions during religious travel.
- Meanwhile, cooperation with China entered the sandbox-testing phase, with operational rollout targeted by the end of 2025. This initiative involves Bank Indonesia, the People’s Bank of China (PBoC), the Indonesian Payment System Association (ASPI), UnionPay International (UPI), and multiple payment service providers.
- Sinarmas Group Strengthens Its Business in the Renewable Energy Sector
- On August 26, 2025, Sinarmas Group, PT Dian Swastatika Sentosa Tbk (DSSA) formed a joint venture with Philippine’s leading producer for renewable energy, and a public company, Energy Development Corporation (EDC).
- This cooperation is carried out through their respective business entities. DSSA through PT DSSR Daya Mas Sakti, while EDC through PT First Gen Geothermal Indonesia.
- Both companies will focus on developing and managing geothermal resources with a combined potential of around 440 megawatts (MW) in six regions, located in West Java, Flores, Jambi, West Sumatra, and Central Sulawesi.
- Geo Energy to acquire 51% stake in two Indonesian shipping companies
- A major Indonesian coal producer, listed on SGX Mainboard since 2012, Geo Energy is proposing to acquire 51% stakes in two Indonesian shipping companies for a US$ 5 million (IDR 2.08 trillion) consideration.
- The proposed acquisition will complement its business model, diversify its revenue stream towards logistics and infrastructure services.
- The two shipping companies are Trans Maritim Pratama and Bahari Segara Maritim, specializing in logistics for commodities, including coal and other non-mining products in Indonesia, with both companies owning a total of 54 vessels, comprising 27 tugboats and 27 barges, where these vessels range between 270 and 330 feet, with transport capacities ranging from 5,000 to 10,000 tonnes, respectively.
- Their capabilities will support Geo Energy’s production at the Triaryani coal mine, as well as its operations at the Marga Bara Jaya jetty enhancing delivery reliability for coal off take and lower transportation cost.
- Salim Group Acquires Nissan Motor Indonesia
- On August 29, 2025, PT Indomobil Sukses Internasional (IMAS), a key automotive arm of the Salim Group, acquired 99.9% of PT Nissan Motor Indonesia (NMI) through its subsidiary, PT National Assemblers. This move strengthens Indomobil’s portfolio in the vehicle assembly business.
- The acquisition aims to enhance Indomobil Group’s business performance and expand its automotive portfolio, which already includes globally recognized brands like Audi, Suzuki, Volkswagen, Volvo, Renault, and more.
- NMI, the brand holder of Nissan in Indonesia, had suspended its assembly operations at the Purwakarta plant since 2020, with Nissan shifting ASEAN production to Thailand. NMI has since focused on sales and after-sales services in Indonesia.
- This acquisition aligns with Indomobil’s decades-long relationship with Nissan and positions the group to potentially revitalize local production while solidifying its presence in Indonesia’s automotive market.
▪ Ministry of Industry’s Pilot Project for Carbon Capture Utilization
- Petrokimia Gresik, an agro-industrial solutions company under the Pupuk Indonesia holding, in collaboration with the Ministry of Industry and Taiwan- based UWin Resource Regeneration , has launched a decarbonization pilot project utilizing Carbon Capture and Utilization (CCU) technology.
- In this partnership, UWin supplies the CCU technology, while Petrokimia Gresik provides the site and supporting infrastructure to facilitate implementation.
- This project not only reduces carbon emissions, but also produces value- added products such as soda ash and baking soda.
- The new CCU facility is capable of absorbing 20,000 tons of CO₂ and has the potential to produce 50,000 tons of soda ash per year.
- Petrokimia Gresik, a major fertilizer and chemical producer, generates up to 2 million tons of CO₂ annually. Existing decarbonization programs have reduced emissions by 400,000 tons, leaving 6 million tons to be addressed through innovative solutions like CCU.
- Indonesia Finalized New Regulation for Waste Management
- The Indonesian government is finalizing a new Presidential Regulation to replace three outdated regulations on waste This regulation aims to accelerate waste-to-energy (WTE) projects as a long-term solution to the national waste problem. The regulation is in its final stages and expected to be issued soon.
- The new regulation will streamline the development of WTE facilities, enabling waste to be converted into both fuel and electricity. The government targets the production of electricity through WTE plants, with facilities processing at least 1,000 tons of waste per day capable of generating up to 20 MW of electricity.
- President Prabowo has emphasized the urgency of waste management and instructed ministries to collaborate for faster implementation. Administrative processes for WTE projects, initially planned for six months, have been shortened to three months to meet an 18-month project completion target.
- The Investment Management Agency (Danantara) will oversee WTE projects, identifying which projects will be handled by private entities and which will be managed directly by The agency is also exploring international partnerships, including learning from advanced WTE facilities in China.
- Rooftop Manufacturer Opens New Facility at Maspion Industrial Estate
- PT Intec Persada, a company known for providing roofing materials, officially opened three new factories in August, simultaneously in 3 places – Maspion Industrial Estate Gresik, Kawasan Industri Medan and Laksana Business Park in Tangerang.
- This expansion is part of the strategy to strengthen its position in the Ecoroof UPVC roofing industry solidifying its role as a leading roofing manufacturer in Indonesia through their brand FibreLux & FibreAlum.
- The company expressed readiness to expand its service coverage to various regions and strengthen its contribution to sustainable development in Indonesia.
- US$ 1.3 Billion Investment Plans Will Pour Into Aceh
- PT Aceh Green Industri (AGI) has announced plans to invest US$ 3 billion (IDR 21.16 trillion) to build a copper and lithium processing and recovery facility in Aceh. This strategic project, located in Aceh, is expected to create 2,000 direct jobs and significantly reduce carbon emissions by up to 2 million tons annually.
- The facility will be a fully eco-friendly recycling plant, focusing on electric vehicle (EV) motor coils and lithium-ion batteries, utilizing AI-driven recovery technology with up to 99% efficiency, along with high-purity material extraction that meets global standards.
- The development will be carried out in two phases: Phase 1 involves building on a 10-hectare site with operations targeted within 10 Phase 2 will expand operations across an additional 90 hectares, significantly scaling the facility’s capacity. The phased approach allows for operational testing and gradual scaling to full production capacity.
- Liaoning Secured 2 Electrolytic Aluminum Projects in Sulawesi and Maluku
- Chinese power technology company Liaoning Rongxin Xingye Electric Power Technology Co., (Liaoning Rongxin), a subsidiary of Bailitjing Co., Ltd., has secured contracts for two major electrolytic aluminum projects in Indonesia, with a combined capacity of 1.15 million tons per year.
- The projects include a 600,000-ton facility at the Morowali Industrial Park in Central Sulawesi and a 550,000-ton facility at the Weda Bay Industrial Park in North Maluku, with a total contract value of approximately RMB 40 million (around US$5.5 million). These projects are part of Xinfa Aluminum’s expansion in Indonesia, leveraging the country’s abundant bauxite resources and favorable energy conditions to create a circular economy cluster integrating nickel and new energy materials operations.
- Liaoning Rongxin will supply high-voltage filtering equipment and technical solutions to ensure stable and efficient operations, minimizing grid disturbances and power outages during With over 20 years of experience, the company’s equipment has been widely used in large-scale electrolytic aluminum projects in China.
- New Import Regulation Threatens Ethanol Industry
- The Indonesian Spirit and Ethanol Producers Association (APSENDO) has urged the government to amend Minister of Trade Regulation 16 of 2025, specifically Article 93, to revoke the HS Code for ethanol. The regulation, aimed at attracting investments in ethanol-dependent industries like biofuels and pharmaceuticals, eased import restrictions and leveraged 0% tariffs on imports from Pakistan and the U.S. to ensure a steady, cost- effective ethanol supply.
- However, this has caused ethanol prices to plunge 56% from IDR 2,500–IDR 3,000 (US$ 0.154–US$ 0.184) per kg to IDR 1,000–IDR 1,400 ($0.061–$0.086) per kg, hurting sugarcane farmers and local producers. With 92.6% of ethanol imports already coming from Pakistan, the regulation risks long- term import dependency and destabilizes domestic production.
- While the government has signaled openness to revisiting the policy, it continues to monitor its impact, balancing investment goals with potential support for local producers through modernization incentives or import quotas.
Latest Update – Japanese Companies Movements in Indonesia
- DIC Establishes New Production Facility for Sustainable Coatings in Indonesia
- DIC Corporation has launched a new production facility for food-contact- compatible functional coatings at its subsidiary, DIC Graphics, in Jakarta. This facility is the first in the global printing inks industry to adopt HACCP standards for food safety management. Targeting markets in Asia and Oceania, DIC aims to produce 1,000 tons annually by 2030 to meet the growing demand for sustainable packaging.
- DIC’s innovative coatings enable recyclable monomaterial packaging by imparting water and oil resistance to substrates like paper and film, reducing reliance on laminated This marks DIC’s first dedicated production site for food-contact coatings in Asia outside Japan.
- Takihyo Expands Southeast Asia Procurement to 30%
- Takihyo, a textile trading company, plans to increase its procurement from Southeast and South Asia—including Indonesia and Bangladesh—from less than 10% to 30% by February This shift aims to reduce its reliance on China, which currently accounts for 90% of its sourcing, amid rising labor costs and geopolitical risks.
- While Southeast Asia offers lower labor costs, challenges include lower garment manufacturing quality, higher defect rates, larger minimum order quantities, and longer lead times compared to China.
- NTT East Japan Targets 10 Million Fiber-Optic Subscribers in Indonesia
- NTT East Japan is expanding its overseas operations by acquiring a 49% stake in Indonesian telecom company Integrasi Jaringan The company aims to provide affordable high-speed fiber-optic internet to 10 million households within 10 years, leveraging Indonesia’s low fiber-optic penetration (15%) and high population growth.
- Integrasi Jaringan has already established 7,000 kilometers of backbone network across Java and serves 200,000 households with low-cost To accelerate deployment, NTT East Japan has set up five training centers on Java and dispatched engineers to train local technicians.
- Japanese Collaboration on Waste Management Pilot in Mojokerto, East Java
- Several Japanese companies, including Yakult Honsha, Ajinomoto, Unicharm, and Panasonic, are partnering with the Mojokerto local government to pilot a household waste management The initiative focuses on improving waste segregation and recycling rates, serving as a model for sustainable urban waste management.
- Ajinomoto Indonesia, in collaboration with startup Rekosistem, is implementing real-time monitoring and optimized resource recovery at the Integrated Temporary Storage (TPST) Magersari facility using advanced digital technology. Other companies contribute under the CLOMA (Clean Ocean Material Alliance) framework to enhance waste processing and recycling.
- The project has achieved a 60% recycling rate, significantly reducing landfill Future plans include expanding the model to other cities in East Java and integrating digital management and Extended Producer Responsibility (EPR) initiatives to support a circular economy in Indonesia.
- Mitsubishi Invests 40 Billion Yen to Reduce Healthcare Costs
- Mitsubishi Corporation has invested approximately 40 billion yen in Fullerton Health Ltd., Southeast Asia’s largest managed care provider, which holds medical records for over four million patients. The investment aims to leverage big data and expertise to reduce healthcare costs and develop new opportunities in the region’s growing healthcare market, driven by an expanding middle class and aging population.
- Fullerton operates in nine Asian countries, including Singapore and the Philippines, partnering with 550 medical institutions and processing 12.5 million medical transactions annually. Mitsubishi plans to dispatch employees to Fullerton, attract Japanese corporate clients, and support subscriber growth in populous markets like Indonesia and Vietnam.
- The collaboration will focus on analyzing Fullerton’s vast database to identify at-risk individuals for lifestyle-related diseases, promote preventive measures, and optimize treatment methods. Fullerton aims to double its revenue by 2030.
- BIOTECHWORKS-H2 Partners with KADIN to Produce Hydrogen from Waste
- BIOTECHWORKS-H2 Inc., a Tokyo and Silicon Valley-based company promoting urban circular economy models, has signed a Memorandum of Understanding (MOU) with the Indonesian Chamber of Commerce and Industry (KADIN) to implement its “ZERO WASTE” model for hydrogen production from waste. This initiative addresses Indonesia’s growing waste management challenges and rising electricity demand, aiming to reduce waste and supply clean energy through hydrogen production.
- Key initiatives under the MOU include:
- Joint surveys and data sharing on waste generation and treatment
- Policy and regulatory analysis and coordination
- Selection of project sites and financing scheme considerations (e.g., PPPs, SPCs)
- Collaboration with government, private companies, and universities
- Technology licensing, human resource development, and public outreach
- The “Zero Waste Project” uses proprietary pre-treatment technology to convert non-recyclable organic waste into high-purity hydrogen without The hydrogen is then utilized as renewable energy within local communities. The system integrates with “REBORN,” an AI- and IoT-based waste sorting platform, to visualize CO₂ reduction and resource circulation.
- With a processing capacity of 200 tons of waste per day, the system can produce up to 20 tons of hydrogen daily, generating approximately 250 MWh of power—enough to supply electricity to 20,000 households. This model has the potential to reduce CO₂ emissions by up to 80%, balancing waste treatment costs with energy revenue.
- Key initiatives under the MOU include:
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