Thank you for taking the time to fill in what is quite a comprehensive survey.

Given the technical nature of some of the areas, you do not need to answer all questions.

When you submit this form, it will not automatically collect your details like name and email address unless you provide it yourself.

1. Name(feel free to leave blank if you prefer to remain anonymous)

2. Organisation(optional)

3. Email Address(not required, but will be used to keep you up-to-date on further developments)

4. How would you classify your role in the carbon markets value chain? *Please selectProject DeveloperVerifiers and ValidatorStandards and RegistryCredit Buyers / UserMarket Infrastructure and AggregatorGovernment and RegulatorFinancial and Legal InstitutionInternational / Multilateral InstitutionResearch InstitutionLocal StakeholdersOther

5. I am broadly positive about the direction that carbon markets are going in South Africa. Feel free to pick one and elaborate. *Please selectYesNoOther

6. Pain Points*: The paper identifies seven "pain points". Do you agree these are indeed the most pressing issues facing South Africa’s carbon market? Are there other critical issues that should be prioritised? **Pain Points:
- Policy uncertainty on Carbon Tax post-2026,
- Lack of clarity on Article 6 approach,
- High certification costs,
- Exclusion of project types,
- Registry bottlenecks,
- Regulatory capital treatment, and
- Unclear legal nature of carbon credits

7. Pain Points: Of the seven identified pain points, please rank them *

8. Legal Nature (Unlisted Securities): To better support broader engagement of banks and asset managers in financing carbon offset projects, the document proposes classifying carbon offsets as as unlisted securities under the Financial Markets Act or as commodities, noting that the latter is relatively difficult to do in South African law. The third option is to create a formal framework recognising them as equivalent to commodity derivatives. The final option is to keep the status quo. In your view which would work best to support the financing of carbon projects, or is there another option in your view? *Please selectUnlisted securityCommodityCommodity derivativesRetain status quoOther

9. Have you experienced any challenges with legal status of carbon credits or offsets, and if so, please describe. *

10. Would it be useful to introduce a new type of carbon credit in the regulations that does not qualify for offset? (A non tax eligible tax credit). Some stakeholders have highlighted that this may develop the net zero market (e.g., where customers are looking for carbon credits but do not necessarily want to use them for tax purposes) *

11. Accounting treatment: To what extent would the legal nature affect the accounting treatment? What other considerations need to be included to ensure that carbon credits are appropriately treated – please be as specific as possible, including reference IFRS and emerging international best practice. *

12. Tax treatment: Is there uncertainty around the VAT treatment of carbon credits / offsets themselves? (As opposed to the services relating to credits / offsets) *Please selectYesNoOther

13. Tax treatment: Do you have any other concerns about the tax treatment? *

14. Capital Treatment of Carbon Credits: The document suggests engaging with international standard setters regarding the capital treatment of carbon credits. Other than those specified in the document, what specific changes to capital requirements would best support financial institutions’ participation in carbon markets? *

15. COAS as ITMO/Article 6 Repository: What are your views on the recommendation to transform the Carbon Offset Administration System (COAS) into a focused ITMO/Article 6 repository while allowing carbon credit trading to occur through regulated financial market infrastructure? *

16. Local Certification Standards: Do you support the development of credible local certification standards to complement international standards (such as Verra and Gold Standard)? *Please selectYesNo

17. Local Certification Standards: What specific considerations should be addressed in developing these local standards? *

18. Increased Offset Allowance: How would the proposed increase in the carbon offset allowance (to 10% for fugitive and process emissions and 15% for combustion emissions from January 2026) impact your organisation’s approach to carbon markets? *

19. Carbon Tax Trajectory Beyond 2030: What specific legislative clarity would you need regarding the Carbon Tax trajectory beyond 2030 to facilitate long-term investment in carbon reduction projects? *

20. Market Architecture Amendments: What amendments to the carbon market’s architecture (including registries and trading venues) would be most valuable for improving market integrity, credibility, and liquidity? *

21. Certification Costs and Timelines: How can the proposed financial framework improvements help address the high costs and long timelines associated with project certification and carbon credit issuance? *

22. Inclusion of Grid-Tied Renewable Projects: For stakeholders in renewable energy projects: how would the potential inclusion of grid-tied renewable energy projects in eligible standards impact your investment decisions and project development? *

23. Exchange Control Treatment: What is the most appropriate exchange control treatment of carbon credits, given the need to develop the market? How would bringing-in different legal structures (e.g., treating credits as commodities versus financial instruments) affect exchange control treatment of different instruments? *

24. Reducing Certification Costs (Smaller Projects): How can the market address the high costs associated with certifying carbon credits, particularly for smaller projects that may face barriers to entry? *

25. Local Validation and Verification Capacity: What steps should be taken to develop local validation and verification capacity to reduce the time and costs involved in certifying carbon credits? *

26. Adapting International Methodologies: How can methodologies applied by international carbon crediting mechanisms be adapted to better account for the South African context? Are there specific proposals regarding grid-connected renewable generation projects? *

27. Clearing and Settlement: What mechanisms would best facilitate clearing and settlement of carbon credits within the existing financial market infrastructure, and how do you see this unfolding in practice? *

28. Regulatory Uncertainty, Price Transparency, and Standardisation: What measures would address the current challenges in the carbon market—specifically regarding regulatory uncertainty, pricing transparency, and market standardisation—to foster greater trust among participants? *

29. Developing Registry Functions: How can South Africa develop appropriate registry functions that align with both carbon market needs and the requirements of the Financial Markets Act (including potential interoperability with international standards)? *

30. Thank you for taking the time to respond to this comprehensive consultation. Are there any other suggestions that you may have? *

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