In 2012, the Brazilian government revised the federal Forest Code that governs the use of forest resources on rural properties. The revisions included a forest trading mechanism whereby landowners who deforested more than what is legally allowed before 2008 could absolve their deforestation “debts” by purchasing Environmental Reserve Quotas (CRA) from landowners who conserved more forest than legally required. CRA holds promise as a tool to complement command-and-control initiatives to reduce deforestation and incentivize restoration. However, the success of this instrument depends on how its implementation is governed. This study builds on a few recent assessments of the potential of the CRA in Brazil–but that is focused on biophysical potential–by assessing how a few key implementation decisions may influence the CRA market development. Specifically, this study estimates how decisions on who can participate will likely influence the potential forest surplus and forest debt for the CRA market and take into account governance characteristics relevant to the State of Pará, eastern Amazonia. In particular, the study evaluates the effects in the CRA market eligibility after simulating a validation of properties in the environmental rural registry (CAR) and assessing different scenarios surrounding the land tenure status of properties. Results show how regulatory decisions on CRA market eligibility will determine the extent to which CRA will serve as a tool to support forest conservation or as a low-cost path to help illegal deforesters to comply with legislation, but with limited additional environmental benefits. The study reviews regulatory options that would reduce the risk of forest oversupply, and thereby increase the additionality of the areas eligible for CRA. Overall, the study demonstrates the importance of including governance as well as biophysical characteristics in assessing the potential of forest trading tools to deliver additional environmental conservation and restoration benefits.