CBAM, ETS1 and ETS2: what moved this autumn, and what it means for your 2026 data

Written By Sven Starckx

Europe's three carbon-pricing systems are all moving at once, and this week is a busy one. On 20 October, EU negotiators sit down on both the CBAM downstream extension and the Market Stability Reserve, days after EU leaders used their 15–16 October summit to call for a more predictable carbon market.

Behind the politics runs a more practical story: in all three systems, verified data is becoming the currency. ETS2 fuel suppliers filed their first verified emissions reports in April 2026. CBAM importers will need verified embedded emissions for their first declaration in September 2027. And the ETS1 review rewrites parts of the monitoring, reporting and verification rulebook for the decade after 2030.

Here is what changed, and what it means for your 2026 data.

At a glance

  • 18 January 2027 – first ETS2 early auctions

  • February 2027 – CBAM certificate sales expected to open

  • 31 March 2027 – verified ETS1 emissions reports due for 2026

  • 30 April 2027 – verified ETS2 emissions reports due for 2026

  • 30 September 2027 – ETS1 surrender, and first CBAM declaration and surrender for 2026 imports

Every deadline from January to September 2027 turns on verified 2026 data. Beyond this window, ETS2 and the proposed CBAM downstream extension both start on 1 January 2028, and the first ETS2 surrender falls on 31 May 2029.

EU ETS1: the post-2030 rulebook is on the table

The Commission's 17 July 2026 review proposal keeps the cap shrinking but slows the pace: a linear reduction factor of 3.7% for 2031–2035, then 1.7% for 2036–2040. The aim is to hold a strong carbon price while giving industry a more gradual run-in.

The headline proposals:

  • Free allocation stays benchmark-based after 2030. For CBAM sectors, the phase-out is slowed and stretched to 2038.

  • Fallback benchmarks: a separate proposal adds roughly €6 billion of free allocation for 2026–2030 under the heat and fuel benchmarks.

  • Carbon removals: permanent removals (BioCCS and DACCS) enter through 250 million extra allowances, auctioned in 2031–2040 to fund Commission purchases of removal units.

  • New scope: municipal waste incineration phases in between 2031 and 2034; aviation coverage extends from 2029 to departing flights within 5,000 km of the EU's geographical centre.

  • Revenues and relocation: member states would steer 50% of national ETS revenues to decarbonising ETS sectors, and operators that move covered activity out of the EU would hand allowances back.

For verifiers and shipping companies, the package also carries a companion MRV proposal. It folds verification and accreditation into a single framework across maritime MRV, the ETS and FuelEU Maritime.

The Market Stability Reserve is the near-term fight. On 1 April the Commission proposed to stop invalidating allowances held in the reserve, keeping them as a buffer. The Parliament's environment committee instead wants to keep invalidation but lift its threshold from 400 to 650 million allowances from March 2027. Negotiators meet on 20 October.

The political signal is "predictable, not weaker". At the 15–16 October European Council, leaders asked for a carbon market that protects against leakage, dampens price volatility and limits the knock-on to electricity prices. In the same breath they backed keeping a market-based carbon price that drives investment.

The market is steady. Verified ETS emissions fell 1.3% in 2025, and December EUA futures reached €88.3 on 12 October, their highest since late January. Council and Parliament positions on the review are expected this half-year, with trilogues in the first half of 2027.

None of this changes the 2026 compliance cycle: verified emissions reports are still due by 31 March 2027, with allowances surrendered by 30 September 2027.

ETS2: delayed on paper, already running in practice

Carbon pricing for buildings, road transport and small industry now starts on 1 January 2028, but its monitoring, reporting and verification never paused.

  • The delay is law. Regulation (EU) 2026/667, in force since 7 April 2026, moved the start from 2027 to 2028 as part of the 2040 climate target package. The first surrender is due by 31 May 2029, for 2028 emissions.

  • Verification is already live. Fuel suppliers have monitored since 2025 and filed their first verified emissions reports, covering 2025, by 30 April 2026. The next verified report, for 2026, is due by 30 April 2027.

  • Allowances go on sale first. The 2027 ETS2 auction calendar, published on 30 September, starts early auctions on 18 January 2027, three days a week on EEX.

  • The 2028 date survived another push. At the October summit, ten governments, including Italy and the four Visegrad states, pressed for a delay to at least 2030. Leaders did not grant it; they asked the Commission to update its assessment of ETS2's design and safeguards instead.

For regulated entities, the practical message is to plan on 2028 and treat the 2026 report as a dress rehearsal. Early verifiers reported that resource constraints at smaller suppliers stretched first-cycle timelines, so starting the 2026 verification early pays off.

CBAM: the rules are set, the verifiers are scarce

CBAM's definitive period has applied since 1 January 2026, and the binding constraint is no longer the rulebook but the number of accredited verifiers.

Where things stand. Importers bringing in 50 tonnes or more of covered goods a year must declare embedded emissions and surrender certificates, with the first deadline on 30 September 2027 for 2026 imports. Certificate sales are expected to open in February 2027. The Q3 2026 certificate price, published on 5 October, is €82.32 per tonne, up from €75.36 in Q1 and €75.28 in Q2. Default values were also corrected on 31 July by Implementing Regulation (EU) 2026/1740, retroactively from 1 January 2026.

Verification rules are in force. Implementing Regulation (EU) 2025/2546 requires risk-based verification to reasonable assurance. The first verification of each installation needs a physical site visit; later years can use a virtual visit or a waiver under conditions, with a physical visit at least every two years.

The infrastructure went live this autumn. The Commission published guidance for verifiers and accreditation bodies on 24 August. Verifiers must register in the CBAM Registry within two months of accreditation, and will issue verification reports there from January 2027. Germany's DEHSt has confirmed that verification of 2026 emissions cannot start before 2027, with no provisional or quarterly verification in between.

Accreditation is the bottleneck. As of 13 October, only five verification bodies were documented as CBAM-accredited, by three national accreditation bodies, and the Commission's official list was not yet published:

  • EmiCert (ESYD, Greece)

  • Bureau Veritas Italia, RINA Services and SGS ICS Italia (Accredia, Italy)

  • Intertek Certification AB (Swedac, Sweden)

Eighteen accreditation bodies are now taking applications, including BELAC (Belgium), RvA (Netherlands), DAkkS (Germany) and COFRAC (France). At a dialogue with the Commission in mid-October, industry representatives flagged the shortage of accredited verifiers for non-EU producers. The arithmetic explains why: every installation whose actual emissions an importer wants to use needs a physical visit in 2027, before the September declaration.

The scope is about to grow. The co-legislators start trilogues on extending CBAM to downstream steel and aluminium goods on 20 October, with a second round provisionally on 30 November. The proposed start is 1 January 2028. The three positions on the table:

  • Commission proposal (December 2025): about 180 downstream product types

  • Council general approach (12 June 2026): about 200

  • European Parliament (September 2026 plenary): 457

Twenty European industry associations and industriAll Europe called on 16 October for the broadest possible coverage.

What to do now

The policy debate will run into 2027, but your 2026 data is being generated today, and in all three systems it will be verified next year.

ETS1 operators

  • Plan the 2026 cycle as usual: verified emissions report by 31 March 2027, surrender by 30 September 2027.

  • Model free allocation under the proposed slower phase-out and higher fallback benchmarks, but budget on current law until the review is agreed.

  • Watch the MSR outcome: whether invalidation stops or its threshold rises will shape allowance supply through 2027.

ETS2 fuel suppliers

  • Close the gaps your first verification found, in your monitoring plan, before the 2026 data year ends.

  • Book verification of the 2026 report early; the deadline is 30 April 2027.

  • If you plan to buy allowances before 2028, prepare for auction access ahead of 18 January 2027.

CBAM importers and non-EU producers

  • Decide supplier by supplier whether you will use actual verified emissions or default values for 2026 imports.

  • Where you want actual values, confirm that each installation is monitoring its 2026 data to the CBAM methodology now; gaps cannot be fixed after the fact.

  • Line up an accredited, or applying, CBAM verifier. Ask which accreditation body, which activity groups are in scope, and when the 2027 site visit can take place.

  • Check whether any downstream steel or aluminium goods you import could fall in scope from 2028.

Need help planning your 2026 verification cycle under ETS1, ETS2 or CBAM? Get in touch with our team. Read more about our EU ETS, ETS2 and CBAM services.

Sven Starckx