TOR: Consultancy to review Nigeria’s Carbon Market Framework for Alignment with Human Rights, Climate Justice and Just Transition Principles

As part of the Strategic Partnership Agreement II (SPA II) that aims at transforming societies to become more just, feminist, green, and resilient, ActionAid is implementing a Global Climate Justice Programme. The project aims at developing, promoting, and shifting resources towards viable local alternatives led by women and youths in affected communities that reduce emissions while promoting resilience and providing inspiring examples of what the just transition looks like.

Nigeria is increasingly positioning carbon markets as a key component of its climate mitigation and green growth agenda. Through emerging policies, regulations and institutional arrangements, Nigeria government has established a national carbon market framework intended to attract climate finance, support emissions reductions and contribute to implementation of Nigeria’s climate commitments. While carbon markets may provide opportunities for climate finance and investment, they also carry significant risks if they are not designed and implemented in a manner that protects the rights and interests of affected communities. Globally, concerns have been raised regarding land rights, displacement, unequal benefit sharing, inadequate participation, labour rights, livelihood loss, gender inequality, and the exclusion of indigenous peoples, women, youth and other vulnerable groups from decision-making processes related to carbon projects.

ActionAid’s climate justice and just transition approach emphasizes that climate action must be rights-based, equitable, participatory and centred on the needs and leadership of frontline communities. Climate policies and market mechanisms should not reinforce existing inequalities or create new forms of exclusion and exploitation.

ActionAid seeks to engage a consultant to undertake an independent review of Nigeria’s Carbon Market Framework and assess the extent to which it aligns with human rights standards and climate justice and just transition principles.

Purpose of the Assignment

The purpose of this consultancy is to:

• Review Nigeria’s carbon market framework, policies and institutional arrangements
• Assess the framework’s alignment with national, regional and international human rights principles and obligations.
• Identify risks, gaps and potential adverse impacts on communities and vulnerable groups
• Provide practical recommendations to strengthen the framework in line with ActionAid’s climate justice and just transition principles.
• Interrogate practitioners on possible innovative solutions that are taking place to protect communities and or the environment. These could serve as good examples, maybe that could be scaled.
• Provide Evidence based Data and information for Carbon Policy reforms and implementation
• Collect photos of detrimental impacts of carbon market implementation – testimonies
• Highlight the Nexus between Carbon Market and Nigeria green growth Agenda.
• Provide concrete example of projects that are taking place right now and how the money could be followed

Objectives

The specific objectives of the assignment are to:

1. Analyse Nigeria’s carbon market framework, including relevant laws, policies, institutional arrangements and implementation mechanisms.
2. Assess whether the framework adequately safeguards:

• Human rights
• Land and resource rights
• Free, prior and informed consent (FPIC)
• Gender equality and women’s rights
• Youth inclusion
• Labour rights and decent work
• Community participation and benefit sharing
• Environmental and social safeguards

3. Examine the extent to which the framework aligns with climate justice and just transition principles, including:

• Equity and fairness
• Polluter pays principle
• Community ownership and participation
• Accountability and transparency
• Inclusion of marginalized groups
• Protection of livelihoods and social protection
• Democratic governance of climate finance
• Identify policy, legal and institutional gaps and provide recommendations for strengthening the framework.

Scope of Work

1. Desk Review

Review relevant documents, including but not limited to:

• Nigeria’s carbon market framework, strategies, policies and regulations
• Relevant provisions of Nigeria’s Climate Change Act, environmental laws, land laws and investment regulations
• Nigeria’s Nationally Determined Contribution (NDC), Energy Transition Plan and Just Transition Guideline and Action Plan
• Relevant African and international human rights frameworks
• Carbon market safeguard standards and best practice guidance
• ActionAid’s climate justice and just transition principles and related policy documents.

2. Assessment and Analysis

The consultant will assess:

• Whether the framework includes adequate provisions for meaningful participation and consent.
• Potential human rights risks and unintended consequences of carbon market implementation.
• Whether benefit-sharing mechanisms are equitable and transparent
• Risks related to land acquisition, displacement, livelihood loss or elite capture
• The extent to which accountability, grievance and redress mechanisms are provided
• Whether the framework adequately protects women, youth and marginalized groups
• Areas where the framework is inconsistent with climate justice and just transition principles.

Key Review Questions

The review should respond to the following questions:

• Who is likely to benefit from the proposed carbon market framework, and who may bear the costs or risks?
• How adequately does Nigeria’s carbon market framework protect community land tenure rights and prevent land acquisition or transfer arrangements that could undermine food security, livelihoods, and long-term community control over land?
• To what extent does Nigeria’s carbon market framework ensure transparency in negotiations and provide for meaningful, inclusive, and early-stage consultation with affected communities regarding carbon market agreements and projects?
• Does Nigeria’s carbon market framework provide accessible, effective, and community-centred grievance and redress mechanisms to address potential harms arising from carbon market projects?
• Are there adequate safeguards to protect the rights of communities and vulnerable groups?
• Does the framework provide for free, prior and informed consent and meaningful participation?
• Are benefit-sharing arrangements clearly defined, transparent and equitable?
• Are there adequate grievance and accountability mechanisms?
• What is the role of women and youth in the Carbon market pathways
• Does the framework contribute to a just transition and equitable climate action?
• What changes are required to ensure the framework is aligned with human rights and climate justice principles?

Methodology

The consultant is expected to apply a desk-based methodology, which should include:

• Comprehensive desk review and document analysis
• Comparative analysis against relevant human rights standards, climate justice principles and best practice frameworks
• Review of relevant international experiences and lessons from other countries
• Gap analysis and development of recommendations.

The review should draw on relevant national, regional and international legal, policy and safeguard frameworks. The consultant should apply a rights-based, gender-responsive and climate justice lens throughout the assignment.

Deliverables

The consultant will be expected to deliver:

• Analysis of the carbon market framework
• Assessment of alignment with human rights, climate justice and just transition principles
• Key findings, risks and gaps
• Practical recommendations
• Policy Brief for Advocacy (maximum 4 pages)
• Concise summary of key findings and recommendations
• Clear advocacy messages and priority actions tailored for engagement with the National Council on Climate Change and other relevant policymakers
• Presentation of Findings; PowerPoint presentation and debrief session with ActionAid team

Timeline of the Consultancy 

The assignment is expected to be completed within Fifteen (15) days.

Consultant Key Competencies and Experience

This assignment is expected to be undertaken by an individual with the requisite expertise and experience. Specifically, the individual consultant will be required to have the following qualifications:

• Advanced degree in law, human rights, climate policy, environmental governance, development studies or a related field
• At least 15 years’ experience in climate policy, human rights, environmental governance or related areas
• Demonstrated knowledge of carbon markets, climate finance and climate governance
• Strong understanding of human rights, gender, land rights and just transition issues
• Familiarity with Nigeria’s climate policy and governance landscape
• Proven experience conducting policy reviews and producing high-quality analytical reports and policy briefs
• Demonstrated experience in conducting assessments, designing and implementing projects related to climate and climate finance
• Excellent writing, facilitation and stakeholder engagement skills.
• Have at least a minimum of 15 years’ experience in carrying out such an assignment and capacity (a report of such work done in the last 2 years is required evidence)

The following compliance documents submitted with the applications: 

• Company profile
• CAC registration (CAC 7)
• Tax clearance certificate
• Evidence of previous jobs, especially with INGOs
• Audited accounts (at least 2023)

Submission of expression of interest

Please send your expression of interest (detailing your approach to the assignment), profile/CV and financial budget in one Microsoft Word document to procurement.nigeria@actionaid.org  on or before 29th of June 2026. 

Applications should be titled: Consultancy – Nigeria’s Carbon Market Framework