ETS and CBAM are here to stay

31/03/26

This article is last updated on 2 April 2026, following an announcement by the European Commission of its first concrete measure to strengthen the EU ETS.

The European Council concluded its spring summit on 19 March 2026 by reaffirming the EU Emissions Trading System as the cornerstone of European climate policy. This despite relatively urgent calls to suspend or soften the system, in light of the currently rising (energy) prices and the short-term EU competitiveness in general. Eight Member States, including Spain and the Netherlands, had warned ahead of the summit that undermining the carbon market would harm (long term) competitiveness and energy security, a position backed by nearly 150 major companies and investors including Unilever, IKEA, Tata Steel and Heidelberg Materials.

With the already-scheduled ETS review approaching in July 2026, the conclusions sharpen its focus on three priorities: reducing CO₂ price volatility, limiting the impact of carbon costs on electricity prices and industrial supply chains, and mitigating the risk of business relocation. Commission President Ursula von der Leyen signaled the review could extend free emission allowances for energy-intensive industries. She also unveiled plans for a 30 billion Euro "ETS Investment Booster" — an industrial decarbonisation fund financed through the auctioning of 400 million ETS allowances.  

What does this mean for your business?

Any change to the ETS and related systems could directly affect your business if you are (or work with) CO2 intensive industry. This article gives you insights into the potentially upcoming changes, to enable you to strategically prepare.

CBAM Definitive Phase in Force, Expansion on the Horizon

The CBAM’s definitive phase has been in force since 1 January 2026, establishing a binding obligation for importers across six sectors—cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen—to ultimately surrender CBAM certificates priced in line with the EU ETS. The phase‑in of CBAM obligations, aligned with the gradual phase‑out of free EU ETS allowances, is proceeding as scheduled, starting at 2.5 percent coverage in 2026 and increasing progressively to 100 percent by 2034.

While the definitive phase has formally begun, the purchase of CBAM certificates is not yet possible. The CBAM certificate trading platform is still under development and is expected to become operational in January 2027. Importers will then be required to purchase and surrender certificates corresponding to the embedded emissions of CBAM goods imported during 2026. 

A significant expansion of the scope is under negotiation. The Commission's December 2025 proposal would extend coverage to approximately 180 downstream product categories with high steel and aluminum content — including machinery, automotive parts, household appliances, and construction materials. Expansion to further sectors such as chemicals remains possible. The European Commission has proposed stricter rules to prevent companies from avoiding CBAM and the creation of a Temporary Decarbonisation Fund. The anticircumvention rules aim to stop practices such as minor product changes, rerouting trade, or reclassification to escape CBAM obligations. For companies, this means closer checks on product classification, sourcing, and supplychain structures.

The Temporary Decarbonisation Fund addresses a gap created by CBAM: while CBAM protects EU producers from higher‑emission imports on the EU market, it does not protect EU producers when they export to countries without a comparable carbon price. As free EU ETS allowances are phased out, EU exporters of CBAM goods face higher carbon costs than foreign competitors, increasing the risk that production shifts abroad. The fund tackles this by temporarily and partially compensating eligible EU producers for EU ETS carbon costs linked to exported goods, provided they demonstrate concrete decarbonisation efforts.  

First Concrete Measure: Strengthening the Market Stability Reserve

On 1 April 2026, the Commission delivered on one of the commitments made at the March European Council by proposing an amendment to the Market Stability Reserve (MSR) Decision. The MSR has been operational since 2019 as a rules-based mechanism to adjust the supply of allowances in the EU ETS. It reduces the supply of allowances to the market when there are too many in circulation and injects allowances when there is market scarcity.

Under the current system, all allowances in the reserve above 400 million are invalidated — by the end of 2024, 3.2 billion allowances have been invalidated. The proposed amendment will stop this invalidation mechanism, allowing these allowances to be kept as a buffer that can support market stability. This change, which may be applicable as per 2027 at the earliest, will better equip the MSR to respond to future market developments, including potential tightness in supply in the coming decades.

The proposal preserves the fundamental rules-based design of the MSR and the integrity of the EU ETS as a market-based instrument, while strengthening the system's ability to ensure both stability and predictability. As the suggested adjustment aims to reduce the risk of a significant scarcity of allowances in the future. The proposal will now be submitted to the European Parliament and the Council and would need to follow the ordinary legislative procedure (co-decision) for adoption. A comprehensive review of the EU ETS will follow in July 2026, which is expected to assess the ETS benchmarks and is expected to include any relevant adjustment to keep the MSR fit for purpose in the next decade.

Other Key Developments

The launch of ETS2, covering buildings and road transport, has been delayed by one year to 2028 amid concerns over the impact on household energy costs. More broadly, affordable energy dominated the summit agenda, with leaders calling for targeted interventions on electricity prices and faster deployment of grids and renewables — framing the upcoming ETS review firmly within the context of industrial competitiveness and energy affordability.

For aviation, the EU extends the ETS to departing flights within the European Economic Area, as from 2027, unless the destination country is deemed to be adequately covered by CORSIA.

Maritime has been included in the ETS since 2024, cargo and passenger ships of 5,000 gross tonnage and above are included for their emissions during voyages between EU/EEA ports, and for 50% of emissions from voyages involving a third country. For global coverage of a CO2 trade system, the International Maritime Organization is finalizing its Net-Zero Framework, aiming for a global levy to be implemented by 2027.

Summary Comparison Table

Below a comparison between the current ETS system and (possible) changes in the near future is included. 

Theme Remains the Same Potential Change
ETS as a policy instrument Confirmed as the central climate instrument ETS review scheduled for July 2026, focusing on price volatility and industrial impact
ETS pricing mechanism Cap-and-trade system remains intact €30 billion "ETS Investment Booster" via auctioning of 400 million allowances proposed
Market Stability Reserve Rules-based mechanism operational since 2019 Proposed amendment to stop invalidation mechanism; allowances above 400 million kept as buffer
Free allowances Phase-out schedule 2026–2034 unchanged (2.5% in 2026 rising to 100% in 2034) Possible extension for energy-intensive industries to be examined in the review
ETS2 (buildings/transport) System still planned Launch delayed from 2027 to 2028
CBAM definitive phase Operational since 1 January 2026; six sectors unchanged Expansion to approximately 180 downstream product categories proposed
CBAM simplifications De minimis threshold of 50 tonnes, declaration deadline 30 September, 50% quarterly coverage required In 2026, CBAM will be finetuned through targeted technical and enforcement measures, followed by a broader review that may inform future scope adjustments.
CBAM anti-circumvention Basic rules in force Strengthened measures and broader scope proposed
Export protection No export mechanism in original CBAM New Temporary Decarbonisation Fund for EU exporters in CBAM sectors

Contact us

Niels Muller

Niels Muller

Partner, Energy transition and sustainable energy, PwC Netherlands

Tel: +31 (0)65 160 08 61

Juliette Marsé

Juliette Marsé

Director (Tax) - Energy, Utilities & Resources, PwC Netherlands

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Claudia Buysing Damsté

Partner, PwC Netherlands

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Maxime den Boer

Manager, PwC Netherlands

Tel: +31 (0)62 053 05 41

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