EU and UK Near Deal to Link Carbon Markets After Brexit

The EU and UK are close to a final agreement to link their carbon emissions trading systems after Brexit, a move expected to boost liquidity and ultimately save companies millions of euros in carbon border taxes. According to Sina Finance, the deal is planned for announcement at a major summit later this month and would allow allowances to be traded across the two systems. Negotiators have agreed on emissions caps, supply controls and free allowances; the treatment of financial derivatives remains unresolved. The EU emissions trading system, launched in 2005, sets declining annual emissions caps for about 10,000 facilities in industries including steel, cement, fertilizers, power generation and aviation. Linking the systems would allow each side to recognize the other's allowances for compliance. The agreement would not automatically exempt either side from its carbon border adjustment mechanism (CBAM), but could pave the way for exemptions once specified domestic-law conditions are met. EU rules require a full link to its emissions trading system and effective carbon pricing without preferential rebates. The EU would then add the UK to the list of countries outside CBAM oversight through a delegated act. The EU's carbon border tax took effect this year, with the first compliance deadline in September; the UK's equivalent mechanism is planned to start in early 2027. Since the sides pledged to link their markets last year, the UK carbon price discount to the EU system has narrowed. UK carbon contracts for December delivery settled at £64.81 per ton last Friday, while the EU benchmark allowance price was €86.55. In a report on November 5, Rabobank (ABN Amro) senior energy economist Moutaz Altaghlibi wrote that the price gap could narrow further over the next two years as UK allowances converge toward EU allowances, requiring UK companies to pay more. He said linking the systems should also improve liquidity, make carbon prices more consistent across Europe, and reduce CBAM-related costs and paperwork in UK-EU trade. The EU will recognize UK emissions caps for 2028–2030. From 2031, the UK's annual allowance issuance will be capped at 7.1% of EU issuance. The UK will establish its own market stability reserve, starting with at least 29.5 million allowances. Adjustments before 2030 are intended to ensure that by 2029 the UK reserve contains allowances equal to at least 6.7% of the EU reserve. The draft also requires the UK to incorporate European rules into domestic law over time. The agreement requires approval by both the UK and the EU, including the European Parliament and EU member states. It will take effect one month after final notification of the summit's other two outcomes: the sanitary and phytosanitary agreement and the youth mobility plan known as YES. The sides may also apply the agreement provisionally before it formally takes effect.