After identifying several surprising and questionable elements in the documentation published by Verra concerning the carbon offset project developed by JTF Tozzi Green in the Ihorombe region, referred to as the SATROKALA ARR Grouped Project, six Malagasy civil society organizations that have long supported the affected communities in the three municipalities:
- sent a letter to Verra and to the public development banks BIO and Finnfund on December 19, 2025;
- requested a response by January 31, 2026.
- BIO and Finnfund replied on January 26 and 29, 2026 respectively.
- European organizations working on carbon offsetting later published the Malagasy CSOs’ letter, together with comments and additional information:
https://reddmonitor.substack.com/p/six-malagasy-civil-society-organisataions - On February 6, 2026, Verra responded that it was not within its mandate to address these concerns directly. However, Verra indicated that it would forward the letter to the project developer as a submission received outside the formal public consultation period, so that it could be considered within the official VCS audit and review process.
Malagasy Civil Society Organizations
To the attention of
Verra
BIO
Finnfund
Subject: Request for clarification regarding the carbon credit project “SATROKALA ARR Grouped Project” implemented by JTF Tozzi Green in the Ihorombe region – Madagascar
Madam, Sir,
We recently learned, through our international partners working on carbon markets, that the certification process for the SATROKALA ARR Grouped Project is moving forward. This development raises serious concerns among the communities we support and among our organizations.
We would therefore like to raise three sets of questions.
1. Context and ongoing conflicts
As documented in several reports (1) (2), the majority of local residents have never freely consented to leasing land to Tozzi Green in the Ihorombe region since 2012. Rather, they report having been pressured by public authorities.
To this day, most local inhabitants — pastoralists and farmers alike — continue to demand:
- that the company withdraw from the land it currently occupies;
- that the State refrain from allocating additional land to the company, whether through lease or sale;
- and that the planned expansion of tree plantations from 4,000 to 6,000 hectares be halted.
A significant portion of the land concerned consists of ancestral grazing areas traditionally used by the Bara community. For generations, cattle herding has been at the heart of Bara identity, culture, and social organization. The land therefore holds not only economic value, but also deep historical, cultural, and social significance.
Were you informed of these longstanding conflicts by Tozzi Green during your exchanges?
Given the allegations of land grabbing and violations of local communities’ rights, we have also filed a complaint with the OECD (3).
2. Procedural integrity and stakeholder responsibility
In May 2024, we wrote to the Italian government and to BIO, noting that key organizations from the municipality of Ambatolahy had not been invited to participate in the consultation process (4).
On May 13, 2024, during a meeting with the raiamandreny (community elders) at the Ambatolahy town hall, all speakers expressed opposition to the tree plantation project. Among their concerns, the most frequently cited was the increase in insecurity linked to the project.
In light of this, we respectfully ask:
- If you were properly informed about the project, did you verify whether consultation procedures were conducted in accordance with legal and institutional standards?
- Which residents of Ambatolahy formally approved the tree plantation project, thereby enabling the company to obtain its environmental permit? When did this approval take place?
- Do you consider that a minority group — known locally to have agreed to transfer land under circumstances involving pressure or fear — and invited to meetings in Satrokala, can legitimately be regarded as representative of the affected communities, in line with your respective institutional codes of conduct?
- When assessing a project for carbon finance or certification, how do you verify that community relations are genuinely sound and that consent has been meaningfully obtained?
- As public financial institutions supporting Tozzi Green, do you not consider it part of your responsibility to ensure that land use — which was central to the initial project you financed — remains legitimate and socially acceptable?
- Given that the project has evolved from an agricultural initiative into a carbon credit project, would it not be necessary to conduct a new consultation process to obtain the free and informed consent of the population?
- Have you requested from Tozzi Green documentation demonstrating the procedures that were carried out?
3. The December 2025 evaluation survey
Our final set of questions concerns the evaluation survey reportedly conducted in December 2025.
Some residents were informed in writing that an evaluation would take place.
We would appreciate clarification on the following points:
- Were you aware of this survey?
- What criteria were used to select the individuals invited to participate?
- Was the survey conducted in only one municipality, even though the plantations extend across three municipalities?
- We understand that no survey may have been conducted in the municipalities of Andiolava and Ambatolahy. Can you confirm whether this is the case?
For over a decade, our organizations, BIMTT; the Collective for the Defense of Malagasy Lands (TANY); the Ihorombe Buffer Zone Land Defense Committee; the National Committee for Family Farming; NGO Fiantso; and the Solidarity of Land Stakeholders (SIF), have supported the communities of the Ihorombe region affected by land acquisitions linked to JTF Tozzi Green.
We sincerely hope to receive your response by January 31, 2026.
Yours faithfully,
December 19, 2025
Signatory organizations:
BIMTT
Collective for the Defense of Malagasy Lands (TANY)
Ihorombe Buffer Zone Land Defense Committee
National Committee for Family Farming
NGO Fiantso
Solidarity of Land Stakeholders (SIF)
References:
(1) Land Grabbing in Madagascar – Echoes and Testimonies (2013)
(2) Entraide et Fraternité – Belgium Complicit in Land Grabbing
(3) Press release: NGOs submit a complaint to the OECD
(4) Letter to the Italian Government