研究院 2025 年 10 月 11 日 2025 年第 36 期（总第 608 期） Ω 中银研究产品系列 作 者：赵廷辰 中国银行研究院 电 话：010 - 6659 1558 签发人：陈卫东 审稿人：王家强 李佩珈 联系人：程栖云 刘佩忠 电 话：010 – 6659 4016 ＊ 对外公开 ＊＊ 全辖传阅 ＊＊＊ 内参材料 把握我国碳金融发展的未来方向 与政策路径＊ 发展碳金融对于活跃碳市场、满足经济社会低碳 转型资金需求具有重要意义。2025 年 8 月 25 日，中 共中央办公厅、国务院办公厅发布《关于推进绿色低 碳转型加强全国碳市场建设的意见》（《意见》）， 这是首份由中央层面出台、专项支持全国碳市场发展 的政策文件。《意见》在"着力提升碳市场活力"章 节中，对发展碳金融作出整体部署。我国碳金融尚处 于起步阶段，下一步应参考国际经验与教训，坚持以 服务实体经济为出发点和落脚点，大力发展碳市场融 资工具，稳妥推进金融机构参与碳市场交易，不急于 推出碳期货等衍生品，探索一条符合中国国情实际的 发展路径。 ● 《经济金融展望季报》 ● 《中银调研》 ● 《宏观观察》 ● 《银行业观察》 ● 《国际金融 ...

Group 1 - The Shanghai carbon market has cumulatively traded 265 million tons of carbon emissions since its inception in 2013, with a total transaction value of 5.544 billion yuan, making it the only pilot region in China to achieve 100% compliance for twelve consecutive years [1] - Shanghai has implemented an "electricity-carbon" collaborative mechanism, with green electricity transactions exceeding 8 billion kilowatt-hours from January to September 2025, and has introduced incentives for outstanding companies, offering free quota rewards of 0.3% or 0.5% [1] - The carbon market in Shanghai covers over 400 enterprises across 28 industries, including steel, chemicals, automotive, aviation, and water transport, with a total carbon quota of approximately 100 million tons [1] Group 2 - Shanghai has organized 16 sessions of paid quota auctions by August 2025, with a total of 26.68 million tons of quotas auctioned and a total transaction value of 628 million yuan [2] - The city is promoting carbon financial innovations, forming a "carbon spot + carbon forward" linkage model, and has developed various financial products such as carbon funds, carbon trusts, and carbon insurance [2] - A carbon inclusive management platform has been established, attracting over 200,000 citizens to open accounts and involving nearly 500 distributed photovoltaic projects, resulting in the issuance of over 100,000 tons of emission reductions [2] Group 3 - Future plans for the Shanghai carbon market include enhancing operational capabilities and focusing on three major actions: improving the carbon trading market, incentivizing voluntary greenhouse gas reductions, and enhancing innovation capabilities [3] - The city has outlined 16 key reform tasks, including establishing quota management systems, improving greenhouse gas reporting, and enriching carbon financial products and services [3] - Shanghai aims to stimulate market vitality by expanding market participants, integrating carbon assets into financial institutions' collateral, and developing a carbon account system based on corporate carbon performance [3]

Core Viewpoint - The construction of China's carbon market is accelerating, with the government aiming to create a more effective, vibrant, and internationally influential carbon market to support carbon peak and carbon neutrality goals [1] Group 1: Carbon Market Development - China's carbon market consists of three parts: the national carbon market launched in July 2021, covering over 2,200 key emission units in the power sector, with a cumulative trading volume of 680 million tons and a total transaction value of 47.41 billion yuan as of August 2025 [2] - The voluntary greenhouse gas emission reduction trading market (CCER) started in January 2024, with a cumulative certified voluntary reduction of 2.49 million tons and a transaction value of 210 million yuan as of August 2025 [2] - Local carbon markets have been piloted since 2011 in various regions, allowing non-national market sectors to trade and manage emissions [2] Group 2: Carbon Financial Market - The carbon financial market includes financing, trading, and support tools, with carbon bonds being the most significant financial instrument, totaling 805.739 billion yuan issued from 2021 to the end of 2024 to support green and low-carbon transitions [2] - Trading tools in the carbon market include carbon futures, options, forwards, swaps, and loans, while support tools encompass carbon indices, insurance, and funds [2] Group 3: Challenges and Development Strategies - Despite significant achievements, the national carbon market faces challenges such as insufficient industry inclusion, low market liquidity, and the need for improved price formation mechanisms [3] - The government has proposed new development strategies to address these challenges, emphasizing coordinated development among the national carbon market, CCER, and local markets, as well as enhancing market vitality through product diversification and regulatory improvements [3] - Key areas for strengthening include management systems, carbon emission accounting, and data quality oversight [3] Group 4: Implementation and International Cooperation - The government has outlined key directions for implementation, including improving the national carbon market's clearing mechanism and enhancing international cooperation [4] - The existing clearing model needs adaptation to meet the demands of the rapidly developing carbon market and financial sector [4] - There is significant potential for increasing the internationalization of China's carbon market, which is crucial for supporting the internationalization of the renminbi and financial openness [4]

Core Viewpoint - The article discusses the release of the "Opinions on Promoting Green and Low-Carbon Transition and Strengthening National Carbon Market Construction" by the Central Committee of the Communist Party of China and the State Council, emphasizing the development of the national carbon market as a key policy tool for controlling greenhouse gas emissions and achieving carbon peak and carbon neutrality goals [2][7]. Group 1: National Carbon Market Goals - The document sets specific targets for the national carbon market, aiming for basic coverage of major industrial sectors by 2027 and a comprehensive trading system by 2030, including quota control, distribution, and international market integration [12][13]. - The goals reflect a coordinated approach with the dual control system for carbon emissions, transitioning from intensity control to total control by 2030 [16][17]. Group 2: Development of Trading Systems - The national carbon market consists of mandatory emission reduction trading and voluntary emission reduction trading, with key sectors like power generation, steel, cement, and aluminum already included [3][18]. - The voluntary carbon market is set to restart in January 2024, with methodologies being developed for various sectors, including power, oil and gas, and forestry [20]. Group 3: Financial Product Innovation - The document encourages financial institutions to develop green financial products related to carbon emissions, such as carbon bonds, carbon futures, and carbon funds, to enhance support for greenhouse gas reduction [22][23]. - Local governments, such as Guangdong and Shanghai, are implementing policies to support carbon asset financing and expand the range of market participants [24]. Group 4: Carbon Emission Accounting and Verification - The article highlights the need for improved carbon emission accounting and reporting management, including the revision of guidelines for key industries and the establishment of a national carbon measurement center [25][26]. - The ecological environment department has released guidelines for greenhouse gas accounting and reporting for four key industries since the market's inception in 2021, with ongoing updates needed for other sectors [27].

Core Insights - The national carbon market has been operating for four years, showing a healthy and orderly development with a cumulative trading volume exceeding 670 million tons and a transaction value of 46 billion yuan [1][2][3] - The introduction of the "Interim Regulations on Carbon Emission Trading Management" in 2024 provides a strong legal framework for the market, with the first expansion planned for 2025 to include steel, cement, and aluminum industries [2][3][9] - The market price has shown a positive trend, with the average closing price surpassing 100 yuan per ton in April 2024, and recent prices fluctuating between 70-80 yuan per ton [3] Market Development - The national carbon market has seen accelerated development in 2024, with the introduction of new trading methods such as single-direction bidding to enhance trading efficiency [2][3] - The trading system's continuous improvement has positively impacted market activity and price formation mechanisms, with trading prices remaining within a reasonable range [2] Regional Market Coordination - The implementation of the regulations on May 1, 2024, clarifies the boundaries between national and local carbon markets, preventing overlapping controls [4] - Shanghai's carbon market has introduced various carbon financial products, significantly increasing green electricity consumption and achieving a 72% growth in carbon reduction credits used for compliance [5][6] Financial Products and Innovations - Shanghai has launched multiple innovative carbon financial products, including carbon pledges, carbon repurchase, and carbon insurance, effectively mobilizing over 800 million tons of carbon assets [6][7] - The introduction of the carbon neutrality index and the upcoming capital market transformation index aims to enhance the synergy between carbon markets and financial markets [7] International Context and Challenges - The EU's Carbon Border Adjustment Mechanism (CBAM) poses challenges and opportunities for Chinese export enterprises, particularly in high-carbon industries [8] - Companies are encouraged to track domestic and international policies, build carbon data management systems, and enhance their low-carbon management practices to adapt to evolving trade rules [8][9]

Core Viewpoint - The ESG (Environmental, Social, and Governance) concept is becoming a key force in promoting sustainable development amid global climate crises and social inequality, with a focus on leveraging regional financial advantages and industrial clusters to enhance sustainable information disclosure and achieve high-quality economic development [1] Group 1: Policy and Standards - Regions in China should actively explore the establishment of sustainable information disclosure policies and standards that align with international norms and domestic needs, drawing from global standards like GRI and TCFD [2] - Local financial institutions should integrate these policies into their business processes, ensuring compliance in project approvals and risk assessments to provide scientific decision-making support [2] - The development of policies should consider the characteristics and needs of financial institutions, encouraging their participation in the policy-making process to ensure feasibility and effectiveness [2] Group 2: Information Disclosure Mechanism - Establishing a unified ESG information disclosure standard is essential to enhance the normativity and mandatory nature of disclosures across industries [3] - Financial institutions should incorporate ESG factors into due diligence and risk assessment processes, ensuring that information disclosure is closely integrated with business operations [3] - Collaboration with local governments and regulatory bodies is crucial for building an effective information disclosure mechanism, utilizing fintech to optimize disclosure processes [3] Group 3: Financial Market and Industrial Cluster Advantages - Financial markets in China should leverage their comprehensive elements to direct more capital towards low-carbon emission sectors, strengthening the carbon finance ecosystem [4] - Financial institutions are encouraged to develop green credit businesses and explore green bonds and carbon finance, linking financial services with local industrial upgrades [4] - Collaboration among financial institutions is vital to develop green financial products and services, enhancing credit support for low-carbon sectors [4] Group 4: Innovation in Green Financial Products and Services - Continuous innovation in green financial products and services is necessary, promoting various carbon-related financial instruments to support the green transformation of the economy [5][6] - Financial institutions must ensure comprehensive and accurate disclosure of environmental benefits and risks associated with new products, enhancing transparency for investors [6] - The development of unique green financial products should consider market demands and regional characteristics, improving their attractiveness and credibility [6] Group 5: Talent Development and International Cooperation - Green finance talent should be included in the list of scarce talents, with efforts to attract and cultivate professionals with international perspectives [7] - Strengthening exchanges with international financial centers can introduce advanced concepts and practices, enhancing local financial institutions' capabilities in sustainable information disclosure [7] - Financial institutions should focus on building a skilled workforce knowledgeable in both finance and ESG principles, participating in international exchanges to improve competitiveness [7]

Core Viewpoint - Hubei province is leveraging its ecological advantages to develop a carbon finance ecosystem, with the establishment of the national carbon market registration and settlement platform ("Zhong Carbon Registration") in Wuhan serving as a catalyst for innovation in carbon financial products and services [1][2]. Group 1: Carbon Finance Development - The People's Bank of China Hubei Branch has been actively promoting financial product and service innovation based on green assets, leading to the emergence of pioneering products such as carbon emission rights pledge loans and carbon asset custody [2]. - The current development of carbon finance in China faces several bottlenecks, including the unclear legal status of carbon emission rights, which complicates their pledge and collateralization [2][3]. Group 2: Legal and Regulatory Recommendations - To protect the rights of financial institutions in carbon emission rights pledge loans, it is recommended to establish national-level management measures and operational guidelines for carbon quota registration, pledging, and disposal [3]. - The suggestion includes utilizing the Zhong Carbon Registration's freezing function for pledged carbon emission rights to mitigate risks such as double pledging [3]. Group 3: Market Participation and Infrastructure - Financial institutions are currently unable to directly participate in the national carbon market, which limits the development of carbon finance and may lead to asset losses in case of loan defaults [4]. - It is proposed that financial institutions be allowed to participate in the national carbon emission rights trading market to enhance market liquidity and ensure the legality of their trading qualifications [4]. Group 4: Future Directions for Carbon Finance - Support is recommended for the Zhong Carbon Registration to leverage its core infrastructure advantages to establish a carbon clearinghouse in Wuhan, attracting various carbon finance entities and fostering innovation in carbon finance [5]. - The creation of a "Zhong Carbon Index" is suggested to stabilize carbon price expectations and provide clear pricing signals for carbon asset rights, trading, and pricing [5].