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EU ETS Review 2026

What changes, what stays the same and what it means for EUA prices

23.07.2026  •  by Christoph Zehetner, Head of Consulting / Partner at Inercomp  •  9 min read

The Commission is proposing a slower decline in the ETS cap after 2030, new rules for the Market Stability Reserve, and significantly more support for industrial decarbonisation. Most of the changes would only take effect after 2030, but they still reshape the long-term supply picture in the EUA market.

European climate policy is currently going through a paradigm shift, and is more contested than it has been in a long time. Where the fight against climate change dominated the agenda in the early 2000s, the last four to five years have pushed two other themes to the fore: the competitiveness of European industry, and the reduction of energy imports. On competitiveness, climate policy can be viewed from two angles. In the short term, carbon costs weigh on manufacturing companies across the EU. In the long term, however, a shift to renewables, and the electrification that comes with it, may be the only way for European industry to remain competitive at all.

On one side stand the clear advocates of a strict climate policy: the Iberian Peninsula, Scandinavia, the Benelux countries, and the industrial companies that have already invested heavily in decarbonisation. On the other side are the Eastern and South-Eastern European countries, along with industrial companies that still rely wholly or largely on fossil fuels.

Against this backdrop, European institutions have been negotiating intensively - or, more accurately, wrestling over a compromise - on changes to the Emissions Trading System (ETS) as part of the long-planned ETS review. On 17 July 2026, the European Commission presented its proposal.

Below, we outline the most significant changes.

Key changes over time

CBAM = Carbon Border Adjustment Mechanism (the EU's carbon charge on imports)

Market Stability Reserve (MSR)

The Market Stability Reserve (MSR) is the ETS's automatic volume-adjustment mechanism. It reacts directly to past surpluses, cuts future auction volumes of EU emissions allowances (known as EU Allowances, or EUAs) and shifts those volumes into a reserve. Until now, any volume in the reserve above 400 million EUAs was automatically cancelled. That automatic cancellation is now being scrapped, giving policymakers more scope to respond quickly to price movements using allowances drawn from the reserve in future. In addition, the rate at which the MSR cuts auction volumes would fall from 24% to 12%. At first glance, this looks like a substantial change. In practice, however, the MSR is unlikely to be triggered at all in the coming years, since past surpluses now sit below the threshold that would activate it. The real-world impact of this change is therefore very limited.

Linear Reduction Factor

The annual reduction in the total number of allowances issued (the Linear Reduction Factor) currently stands at 4,4% per year through 2030. Under the proposal, this rate would ease to 3,7% per year from 2031 to 2035, and 1,7% per year from 2036 to 2040. These changes stretch out the EU's decarbonisation trajectory somewhat, giving industry more time to complete the transition.

Waste incineration plants

Waste incineration plants have so far been treated quite inconsistently across the EU; this review resolves that inconsistency. Waste incineration plants would enter the ETS from 2031 (rather than 2028, as previously expected). The surrender obligation would be phased in gradually: 25% of verified emissions in 2031, 50% in 2032, 75% in 2033, and 100% from 2034.

Free allocation

Free allocation for industrial users would be extended to 2040 (2038 for sectors covered by the Carbon Border Adjustment Mechanism, or CBAM). From the 2031 allocation period onward, however, it would become fully conditional on investment commitments. The only exemption applies to the 10% most efficient installations under each benchmark, which the EU considers to have already done their decarbonisation homework. Industrial companies would need to submit an "Invest in EU Decarbonisation Plan": a verified, publicly available investment pathway toward climate neutrality by 2050.
 
The calculation of free allocation itself would remain largely unchanged, still based on sector-specific benchmarks that are progressively tightened. What's new is that the Commission would gain the power to set sector-specific fallback benchmarks for heat and fuels, to better reflect the actual abatement potential of individual sectors.

Aviation

Until now, only flights within Europe have fallen under the ETS. From 2029, this would extend to all flights up to a distance of 5,000 km, measured from Frankfurt. At a carbon price of €80/t, a return flight from Vienna to Istanbul would incur roughly €20 in carbon costs.

Industrial Decarbonisation Bank (IDB)

The Industrial Decarbonisation Bank (IDB) would be established from 2028 as a new EU instrument. It would fund both investment costs, including grid-connection, storage and flexibility costs, and operating costs for emissions reductions and permanent CO2 removals. Waste incineration plants are explicitly included.
 
The Bank would operate in two phases. From 2028 to 2030, 400 million EUAs would be reserved for a so-called Investment Booster. This funding would be awarded on a first-come, first-served basis in the form of fixed carbon premiums, and could take the form of allowances allocated directly.
 
From 2031 to 2040, a further 400 million EUAs would be auctioned. The resulting revenue would then be distributed mainly through competitive tenders, such as Carbon Contracts for Difference or carbon premiums.

Our assessment

Overall, various stakeholders had called for (and in some cases expected) considerably stronger, more price-relevant changes. The proposal, for example, makes no changes to Article 29a of the ETS Directive, which contains an automatic mechanism for releasing additional volumes depending on the EUA price - one that is largely toothless given its current parameters. A significant tightening of this article would have had a stronger price-dampening effect.

The biggest immediate price impact would likely come from the Industrial Decarbonisation Bank's allowance volumes, since they create additional supply. However, these volumes had already been partly anticipated through various prior signals. Some had been expected as early as 2027; they will now arrive no sooner than 2028.

The changes now actually proposed alter the ETS only marginally and fall well short of the additional supply pressure the market had feared; some measures, moreover, only take effect after 2030. Precisely because the reform is weaker than expected, it reinforces our fundamentally bullish outlook on EUAs.

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by Christoph Zehetner, Head of Consulting / Partner at Inercomp

23.07.2026