Carbon markets hold their ground as climate regulation tightens — March 2026

Energy market turbulence dominated the first quarter of 2026, but the direction of travel on climate regulation remains consistent: market mechanisms are being reinforced, and the bar for credible climate claims is rising. This month's update covers three areas that carry direct commercial implications: the EU's decision to fast-track ETS stability measures rather than suspend the scheme; Switzerland's tightened legal framework for carbon credit claims, and evolving renewable gas policy in California and Brazil. Each signals a market becoming more demanding of quality and compliance. Read on to discover what these policy developments mean for you.

Published on 20th March 2026.

What happened

The EU confirmed that fertilizers will remain within the scope of the Carbon Border Adjustment Mechanism (CBAM). The decision was contested by agricultural sector representatives but has been confirmed as part of the ongoing CBAM implementation framework.

What it means for your business

Companies importing fertilizers into the EU are required to report and, from January 2026, pay for the embedded carbon content of those goods. The confirmation removes a period of regulatory uncertainty for both importers and industrial clients managing cross-border carbon exposure. For companies operating in agriculture, chemicals, or food manufacturing with EU supply chains, CBAM compliance is now a fixed cost and operational requirement.

Entry into force

Full CBAM pricing applies from January 2026. The fertilizer inclusion is confirmed.

Further reading

European Commission CBAM implementation documentation.

What happened

The EU adopted the Omnibus I simplification package and advanced its updated Climate Law, including a one-year delay to ETS-2, now scheduled to launch in 2028 rather than 2027. The updated framework opens the door to limited use of international carbon credits within the new scheme.

What it means for your business: The delay extends the window before buildings and road transport operators face mandatory carbon pricing obligations under ETS-2. For companies planning compliance procurement strategies in these sectors, forward timelines should be updated accordingly. The provision for limited international credit use, if confirmed in final legislation, would expand the pool of compliant instruments, with implications for both demand and pricing in voluntary and compliance markets.

Entry into force

  • ETS-2 launch confirmed for 2028.

  • International credit provisions remain subject to further legislative detail.

Further reading

What happened

At the 19 March EU leaders' summit, the European Commission reaffirmed the ETS as the central instrument for industrial decarbonization and rejected calls for suspension despite recent EUA price volatility. The Commission outlined four concrete measures: updated free allocation benchmarks to reduce industry burden; increased Market Stability Reserve (MSR) firepower to reduce price volatility; a revised post-2034 free allocation trajectory for industry; and a EUR 30bn investment fund financed by EUAs. Additional measures outlined in advance of the summit include accelerating clean energy deployment, expanding long-term power purchase agreements, and targeted short-term relief mechanisms including carbon cost compensation.

What it means for your business

The MSR reinforcement is expected to be fast-tracked ahead of the broader ETS review due in July 2026, providing a near-term floor against price volatility. The EUR 30bn investment fund and revised post-2034 trajectory are medium-term measures subject to ongoing legislative process. Companies with open EUA positions or forward compliance obligations should factor in continued near-term uncertainty while the short-term package is finalized, with more structural clarity expected later in 2026.

Entry into force

  • MSR measures expected to be fast-tracked.

  • Remaining measures subject to multi-year legislative process

  • ETS post-2030 framework to follow.

Further reading

What happened

The Swiss Federal Office for the Environment issued new guidance on corporate climate claims in marketing and product communications. The law has been in force since 1 January 2025; the March guidance provides legal clarity on how product-level claims can be substantiated. The motivation is to limit greenwashing and strengthen consumer protection.

What it means for your business

Carbon credits are treated as compensation measures outside the value chain and can support contribution claims only; not neutrality claims. Guarantees of Origin (GOs) are explicitly accepted as evidence of renewable energy sourcing within emissions accounting frameworks, provided they are properly tracked and retired. The overall direction is toward value-chain decarbonization instruments. Companies operating in or marketing into Switzerland that currently use carbon credits to underpin neutrality statements should review their claims framework against the new requirements; non-compliant claims carry reputational and legal exposure.

Entry into force

  • Law in force from 1 January 2025.

  • Guidance confirmed March 2026.

Further reading

Swiss Federal Office for the Environment climate claims guidance.

What happened

The US Environmental Protection Agency submitted the final Renewable Volume Obligation (RVO) for 2026 and 2027 under the Renewable Fuel Standard (RFS). The submission moves the RFS closer to confirmed implementation for the two-year period.

What it means for your business

Obligated parties under the RFS, including refiners and importers, now have confirmed blending obligations for the next two years. The RVO sets the volume of renewable fuels that must be blended into the fuel supply, directly determining RIN demand and pricing dynamics. Companies with RIN exposure on either the compliance or supply side may wish to update their forward positions in light of confirmed volumes.

Entry into force

2026-2027 obligation period. Final rule submitted.

Further reading

US EPA Renewable Fuel Standard program

What happened

The California Public Utilities Commission (CPUC) reduced blending targets under the state's RNG blending mandate. The CPUC broadened eligible feedstocks but maintained restrictions on geographic eligibility and pricing.

What it means for your business

The program remains restrictive. Feedstock and geographic eligibility limits continue to constrain the pool of qualifying RNG supply in the California market. Companies active in California RNG procurement or supply should assess their position against updated eligibility criteria; non-qualifying volumes do not generate compliant credits under this program.

Entry into force

2026. Confirmed by CPUC.

Further reading

CPUC Resolution documentation

What happened

The Brazilian National Agency for Petroleum, Natural Gas, and Biofuels (ANP) finalized Resolution No. 995/2026, establishing the National Program for Decarbonization of Natural Gas Producers and Importers under the Future Fuels Law. Natural gas producers and importers are subject to individual mandatory targets, calculated against a national annual threshold. Compliance is met through the retirement of Biomethane Certificates of Guarantee of Origin (CGOBs).

What it means for your business

The resolution creates a structured compliance demand for Brazilian biomethane. Companies generating biomethane in Brazil can now produce CGOBs as a compliance instrument, but the regulation also requires purchasers to disclose whether the same volume generated RenovaBio CBIO credits — a direct acknowledgement of double-counting risk.

Entry into force

2026. Resolution finalized by ANP.

Further reading

ANP Resolution No. 995/2026

Disclaimer

This content reflects regulatory developments confirmed as of 20/03/26 and was accurate as of the date of publication.

It is provided for general informational purposes only, is limited to confirmed developments, and does not purport to be comprehensive. Any forward-looking statements reflect the position as understood at the date of publication and are subject to change.

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