Germany’s environment agency (UBA) has launched a public tender to purchase up to 1.1 million carbon credits aligned with Article 6.4 of the Paris Agreement, the UN crediting system known as the Paris Agreement Crediting Mechanism (PACM), to compensate for emissions from government travel and other activities, Carbon Pulse reported. The tender matters for developers and market intermediaries because it converts a decade-old government offsetting practice into direct demand for credits transitioning out of the Kyoto-era Clean Development Mechanism (CDM), at a moment when Article 6.4 supply remains scarce.
The Headline Volume and the Official Target
The headline figure is up to 1.1 million credits, per Carbon Pulse. The official tender notice, published on the Federal Government’s carbon-mechanisms portal, sets out the underlying purchase volume more precisely: to offset all related emissions, UBA intends to purchase up to 795,408 emission reduction credits, according to the tender notice.
Bids are due by November 4, 2025, and the credits must be based on emission reductions achieved after December 31, 2020, per the same notice. Because such credits cannot yet be presented, they will be submitted at a later stage, a detail that underlines how early the Article 6.4 pipeline still is. Further participation instructions are hosted on Germany’s public procurement platform, in German only, according to the notice.
Who Can Bid: CDM Projects Seeking Article 6.4 Transition
Eligibility is narrowly defined. Projects must be registered under the CDM or classified as temporary measures by the CDM Executive Board, and must have applied for transition under Article 6.4 of the Paris Agreement with the UNFCCC, per the tender notice.
The procurement mechanics follow the government’s established practice. National and international bidders can offer credits from one or more climate protection projects; the German Emissions Trading Authority (DEHSt) evaluates the offers against quality criteria, purchases the selected project credits and then irrevocably cancels them, according to DEHSt. Cancellation, rather than resale or banking, means the units are permanently removed from circulation once surrendered.
A Decade of Offsetting, Rebuilt for Paris
The programme behind the tender is not new. Since the 18th legislative period (2014-2017), the Federal Government has offset the climate impact of official travel, transportation and events undertaken by the federal administration, covering trips by employees of the supreme and higher federal authorities and directly subordinate agencies using airplanes or government vehicles, per the tender notice. In 2018 the offsetting was extended to business trips such as law enforcement travel by the Federal Police, according to DEHSt.
Historically, the government procured Certified Emission Reductions (CERs) from projects certified under the CDM of the Kyoto Protocol, per DEHSt. The stated operating principle is “first avoid, reduce and then offset”, with remaining emissions neutralised by purchasing and cancelling credits from what the authority describes as ambitious climate protection projects.
The shift of the tender toward Article 6.4 reflects a redesign that began when the Paris Agreement took effect at the start of 2021. DEHSt frames the transition around two requirements: contributing to sustainable development and raising ambition, and avoiding double counting, according to DEHSt. The double counting concern is not theoretical for Berlin: the authority notes it has so far avoided national projects for offsetting, and that under the Paris Agreement the risk now extends to all countries, since credits used for offsetting may not simultaneously count toward a host state’s Nationally Determined Contribution.
Why a Government Tender Matters for the Market
The purchase is small compared with compliance market volumes, but its structure is the story. The government itself describes the measure as a strong signal in support of the voluntary carbon market, per the tender notice. By conditioning eligibility on a pending Article 6.4 transition application, the tender effectively pays for optionality: developers holding CDM projects gain a concrete buyer for credits that do not yet exist in their final form.
DEHSt explicitly frames this as bridge-building. The Article 6.4 rules adopted at COP26 will take time to implement, and the market will take time to deliver corresponding credits, so the authority says it supports projects already compatible with Article 6 to create confidence in future activities, per DEHSt.
What to Watch
The first marker is the tender outcome itself: how many bids arrive by the November 4, 2025 deadline, from which project types, and at what prices. Thin participation would confirm that the CDM-to-PACM transition pipeline is not yet producing bankable supply.
The second marker is delivery. Since credits will be submitted at a later stage, the timeline between award and actual surrender will show how long transition applications take to convert into issuable Article 6.4 units. The third is replication: if other governments or public institutions adopt the same PACM-aligned procurement format, sovereign offsetting programmes could become a steady early demand channel for the new UN mechanism.
