CARBON MARKET · ARTICLE 6
Singapore Expands ITMO Demand: Three Access Routes and What They Mean for Giant Barb
Singapore is developing three channels for international Article 6 carbon credits: central government procurement, a bilateral-agreement-linked offer mechanism, and International Carbon Credit demand from carbon-tax-liable companies. Each route calls for a different approach to supply from Viet Nam.
Three ITMO access routes in Singapore
01
Government procurement
Centralised RFPs suited to portfolios with scale and the ability to meet prequalification requirements.
02
Offers under bilateral arrangements
Linked to ITMO authorisation and a minimum offer obligation to Singapore where a project meets the IA conditions.
03
Corporate ICC demand
Carbon-tax-liable companies can procure ICCs through direct contracts, exchanges or intermediaries.
1. Singapore Government carbon credit procurement
On 31 October 2025, Singapore’s Ministry of Trade and Industry (MTI) opened its second RFP to procure Article 6 credits from both technology and nature-based projects. The RFP has two stages: supplier prequalification, followed by detailed project proposals from the shortlisted suppliers.
On 7 September 2026, MTI opened Stage 2 on GeBIZ with an objective to purchase at least 12 million tCO₂e for its 2030 and 2035 NDCs. Proposals were due by 16:00 Singapore time on 7 October 2026 and had to remain valid for 200 days, until around the end of April 2027.
Each bidder must offer at least 500,000 tCO₂e. Volumes may be aggregated across projects, but each project must deliver an average of at least 25,000 tCO₂e per year. Credits must have issuance years from 2021 to 2030 and meet Article 6 requirements, including host-country authorisation and corresponding adjustment.
This is a selective tender following prequalification. Only bidders on the Stage 1 shortlist may submit a Stage 2 proposal directly.
By volume, the second procurement round is materially larger than the first: Singapore intends to procure at least 12 million ITMOs, while the first RFP awarded contracts for 2.175 million ITMOs with an aggregate value of around S$76 million.
RFP and delivery timeline
No official announcement has been identified for a further Singapore Government carbon-credit procurement beyond these two RFPs.
2. Minimum 30% offer under bilateral arrangements
Alongside centralised RFPs, Singapore has established a procurement channel tied to project approval under an Implementation Agreement (IA). Project proponents must make a binding offer for the Singapore Government to purchase at least 30% of the authorised ITMOs. Singapore may accept or reject the offer and will consider only ITMOs authorised under a Singapore IA and meeting the applicable environmental-integrity requirements at the time of purchase.
If a project proponent does not honour this offer commitment, Singapore may withhold authorisation of subsequent ITMOs, suspend the proponent from IAs for 12–24 months, or pursue civil action for breach of the commitment.
ITMOs authorised under an IA must be sold or first transferred to an eligible entity in Singapore, unless an exemption applies. A non-government eligible entity must be registered, tax resident in Singapore, carry on business there and satisfy the relevant local-personnel requirements.
This mechanism provides an ongoing sales route connected to each ITMO authorisation rather than relying solely on RFP calendars. At the same time, supply remains subject to technical requirements, Article 6 procedures and Viet Nam’s NDC constraints.
3. ICC demand from carbon-tax-liable companies
Since 1 January 2024, carbon-tax-liable facilities in Singapore have been able to use Government-approved International Carbon Credits (ICCs) to offset up to 5% of their taxable emissions each year. This demand may be served through direct purchase contracts, exchange transactions, Singapore-based intermediaries, or project-development and long-term offtake agreements.
-
Identify an ICC source: buyers or service providers check the source country, project, programme and methodology against the Eligibility List and the list of approved projects.
-
Submit a Notice of ICC Use: the carbon-tax-liable facility submits the notice through EDMA with evidence of host-country authorisation or equivalent documentation.
-
Receive confirmation from NEA: acceptance of the Notice confirms that the credit source is from an approved project; the use limit is established in the Notice of Assessment.
-
Purchase, transfer and retire credits: ICCs may be purchased from the project proponent or a third party, then transferred or retired in the appropriate carbon-credit programme registry.
-
Submit Evidence of Retirement: an ICC is regarded as surrendered for tax purposes only after the NEA accepts the retirement evidence.
A third party may help source, purchase or retire credits. Responsibility for the Notice, retirement evidence and tax compliance remains with the registered person of the Singapore carbon-tax-liable facility.
Singapore carbon tax trajectory
ICCs traded under this framework must meet Singapore’s Article 6 criteria for avoiding double counting, additionality, real and quantified mitigation, independent verification, permanence, no net harm and leakage control.
Applicability to projects in Viet Nam
Viet Nam has signed an Article 6 carbon-credit cooperation Implementation Agreement with Singapore and appears on the source-country list for the second RFP. However, Article 18 of the Agreement enters into force on the 60th day after the last notification that the parties have completed their domestic procedures. Public information on the Viet Nam and Singapore portals does not identify the date of that event.
The bilateral framework and key annexes have been made public, but the Viet Nam–Singapore process requires further monitoring to establish when it can operate for ITMO approval, issuance and transfer. Interested parties should monitor updates from the designated authorities in both Viet Nam and Singapore. Giant Barb will continue to provide updates as new information becomes available.
What this means for Giant Barb and Vietnamese businesses
Singapore expects suppliers to manage the complete carbon-credit supply chain: project development, monitoring, validation, verification, authorisation, corresponding adjustment and ITMO transfer. Giant Barb is working towards participation across that chain in Viet Nam, rather than acting solely as a credit-sales intermediary.
Large Singapore Government orders also require scale: a bidder must supply at least 500,000 tCO₂e, while each project within the portfolio needs to average at least 25,000 tCO₂e a year. This underscores the need to develop and add projects to GB’s credit portfolio so that supply capability can be maintained over time.
In the next phase, suppliers need to invest in technical capability, project data and portfolio development while expanding partnerships to reach buyers and compete for large procurements. Giant Barb aims to serve as a trusted advisory and connection point for businesses entering Viet Nam’s carbon market and to participate more deeply in the international carbon-value chain over time.