Germany’s environment agency tenders for up to 1.1 million PACM-aligned carbon credits
By Article 6 Network
The German Environment Agency (UBA) has launched a tender to buy up to 1.1 million carbon credits aligned with Article 6.4 of the Paris Agreement. The credits will compensate for emissions from federal government travel and other activities. It is Germany’s largest such tender to date, following a failed 2025 round. It gives an early demand signal for credits from the Paris Agreement Crediting Mechanism (PACM) and its standards.
On 7 October 2026, the German Environment Agency (Umweltbundesamt, UBA) opened a tender for up to 1.1 million carbon credits aligned with Article 6.4. They will compensate for greenhouse gas emissions from official government travel and other federal activities.
The tender continues a long-standing policy. Since the 2014–2017 legislative period, the federal government has bought carbon credits to offset official travel, journeys and events. Germany stopped using CDM certificates in 2021 because they did not meet the quality requirements of Article 6. Its first tender for Article 6-compatible credits was held in 2022.
Tender volumes have grown each year. The 2024 round sought up to 616,145 credits. In October 2025, the UBA tendered for as many as 800,000 Article 6.4 credits for official travel, vehicle use and related activities. But that round ran into supply problems. Spending on offsetting for official travel fell by more than 90% in 2025 because stricter international standards left officials struggling to find enough qualifying credits. The new tender’s “PACM-aligned” wording, rather than requiring credits already issued under Article 6.4, suggests the UBA has adjusted its approach to the limited supply of A6.4ERs.
Signals to watch
- First meaningful public buyer for PACM-grade credits: At 1.1 million units, this is one of the largest government tenders built specifically around Article 6.4 standards. It sends a clear price and volume signal to developers registering or transitioning activities under the PACM.
- The meaning of “aligned” is the key detail: The 2025 shortfall showed that requiring only issued A6.4ERs leaves demand unmet. Developers should study the tender documents closely to see whether they accept projects in transition, credits meeting PACM-equivalent methodology and integrity criteria, or other forms of proof. This will decide who can bid.
- Supply is still the bottleneck: The PACM has approved only a few methodologies so far: landfill gas, nitric acid N₂O, grid renewables and, most recently, clean cooking. CDM transition credits are the most likely near-term source. Developers with transition-eligible portfolios have the strongest position.
- A template for other public buyers: Government offsetting for official travel is a small but symbolic market. Other European ministries, development agencies and corporates that use UN standards as a benchmark may follow Germany’s procurement criteria.
- Corresponding adjustments: Since the credits are for voluntary compensation rather than NDC use, watch whether the UBA requires host-country authorisation and corresponding adjustments. This choice would affect pricing and which host countries can take part.
Sources:
- Carbon Pulse – Germany launches tender for 1.1 mln PACM-aligned credits
- Carbon Pulse – Germany to buy 800k PACM credits (2025)
- Carbon Pulse – German govt offsetting slumps amid shortage of high-quality credits
- carbon-mechanisms.de – 2024 UBA tender