Australia’s carbon markets are growing fast, and so is the regulatory complexity that comes with them. For investment managers looking to raise capital for carbon farming, reforestation, natural capital, or climate technology strategies, the licensing and compliance requirements can be a significant hurdle before a single dollar is ever invested.
THE REGULATORY REALITY OF CARBON INVESTING
As our own team puts it:
“There are stringent licensing and compliance rules for raising money, and for dealing in, and providing financial advice in relation to, financial products (such as ACCUs). The core requirement is that organisations must be appropriately authorised under an Australian Financial Services Licence (AFSL) – or be an authorised representative of an AFSL holder.”
Matthew Moses, General Counsel, MARQ Trustees
Australian Carbon Credit Units (ACCUs) are financial products in their own right, which means any fund dealing in them needs to navigate the same rigorous licensing framework that applies across wholesale funds management. For investment managers focused on carbon and climate strategies, this is often unfamiliar territory.
OUR CARBON INVESTMENT MARKET EXPERIENCE
MARQ Trustees provides the trustee, custody and AFSL services required to structure, establish and operate wholesale investment funds across Australia’s carbon and climate-aligned investment markets. We support investment managers in navigating licensing, structuring and regulatory requirements, enabling them to raise private capital for carbon and climate strategies and, where relevant, deal in ACCUs and other carbon-linked financial products.
Carbon funds we support span:
- Environmental plantings, carbon farming and regeneration
- Land-based reforestation and broader natural capital strategies
- Funds generating ACCUs under approved methodologies
- Projects where carbon outcomes sit alongside biodiversity, stewardship and conservation objectives
- Structures involving First Nations partnerships and long-dated land management obligations
Carbon investment products we support include funds and debt structures where capital deployment and investor returns are directly linked to carbon outcomes.
Carbon and climate strategies typically involve extended project timeframes, land-based assets with overlapping obligations, and an evolving regulatory landscape. Our wholesale fund focus is built for exactly this kind of complexity - providing consistent trustee oversight across carbon credit generation, environmental plantings, regeneration projects and carbon-linked investment structures.
SUPPORTING MANAGERS AT EVERY STAGE
Whether you’re an experienced investment manager or raising your first fund, MARQ Trustees has the technical skill-set and professional resources to manage the mesh of interdependent tasks involved in structuring, establishing and operating a carbon fund.
Experienced managers can draw on our full suite of services - AFS licensing, custody, fund administration, KYC and investor registry.
First-time managers benefit from our ability to project-manage the many moving parts - coordinating external consultants, meeting ASIC and tax law requirements, and helping draft the sections of an Information Memorandum that fall to the trustee – removing what is often a major drain on time and resources.
TRUSTED BY LEADING CARBON MARKET PARTICIPANTS
Our clients across the carbon and natural capital sector consistently highlight the value of working with a trustee that genuinely understands both funds management regulation and the realities of carbon markets:
“MARQ Trustees understands both the funds management regulatory environment and the realities of carbon markets. Having a trustee that is well-versed in ACCUs made structuring and launching our fund far more straightforward.”
Damon Petrie, Consultant – Investment Director,
Cibus Capital
“Carbon funds require specialist oversight across complex, long-horizon projects. MARQ Trustees understands the nuances of our Funds and provides the governance framework to match.”
Matthew Tominc, Chief Investment Officer / Board Director & IC Member,
Conscious Investment Management
“As a leading carbon farming developer and carbon offset retailer, Carbon Neutral Pty Ltd values the professional services expertise of MARQ Trustees, whose support across AFSL compliance, carbon investment options and carbon project initiatives – including First Nations partnerships and land stewardship arrangements – has been highly regarded.”
Dr Phil Ireland, CEO,
Carbon Neutral Pty Ltd
COMMITTED TO HIGH-INTEGRITY CARBON MARKETS
MARQ Trustees is a proud member of the Carbon Market Institute, reinforcing our commitment to high-integrity carbon markets and our role in supporting industry leadership. We’re also a sponsor of several key industry events in 2026, including the Carbon Farming Industry Forum in Fremantle, the Carbon Market & Investor Forum in Singapore, and the Australian Emissions Reduction Summit in Adelaide.
Read our full Carbon Sector Experience brochure.
GET IN TOUCH
If you’re structuring, launching or operating a carbon or climate-aligned investment fund and need a trustee who understands both the regulatory framework and the realities of carbon markets, we’d love to talk.
ABOUT MARQ TRUSTEES
Established in 2014, MARQ Trustees brings together a team with decades of financial services experience in managed funds. Under the authority of our Australian Financial Services License (AFSL), our firm provides services to wholesale managed investment schemes including trustee, custody and other AFSL services; advisory, fund administration and registry services; as well as fund to market and capital raising advice. For more information, contact us via phone: +61 3 9005 9282 or email: [email protected].
