CBAM verification guidance leads the month's carbon market news — September 2026

September's clearest compliance signal came from Brussels: The European Commission opened the CBAM verification and accreditation system importers will need to use from 2027. Brazil also fixed a compliance schedule for its aviation fuel mandate, and Washington State published the rule that lets its carbon market trade with California and Quebec. Singapore and Laos also signed a new bilateral Article 6 agreement for carbon credit transfers, extending a pattern of country-to-country deals across Southeast Asia. Here's what happened and what it means for your business.

Published on September 30, 2026.

What happened

The European Commission published guidance on CBAM verification and accreditation for verifiers and National Accreditation Bodies on August 24, 2026, alongside a CBAM Registry access procedure. The guidance sets out how verifiers register and gain system access from September 1, 2026, and confirms that accredited verifiers must register in the CBAM Registry within two months of accreditation. 

What it means for your business

Importers of cement, steel, aluminum, fertilizers, electricity and hydrogen into the EU will be able to use independently verified emissions data, rather than default values, in their CBAM declarations once verifiers are accredited under this framework. Non-EU producers supplying these goods can confirm their emissions data is being independently verified in time for the 2027 declaration cycle, since verified figures determine the number of CBAM certificates an importer must purchase. 

Entry into force

The guidance applies now. The definitive CBAM regime, including certificate purchase obligations based on verified emissions, begins January 1, 2027. 

Further reading

European Commission publishes guidance for CBAM verifiers and accreditation bodies 

What happened

The Council of the EU and the European Parliament reached a provisional agreement on June 11, 2026, to amend the Market Stability Reserve for ETS2, the EU's emissions trading system covering buildings, road transport, and additional sectors, due to launch in 2028. The agreement extends the reserve's price-stabilizing role beyond 2030, doubles the volume from 20 million to 40 million allowances released when prices exceed EUR 45 per tonne of CO2 equivalent, and introduces a more gradual release mechanism when circulating allowances fall below 260 million. Both institutions must still formally endorse the text before it enters into force. 

What it means for your business

Fuel and heating suppliers that will hold compliance obligations under ETS2 gain a clearer view of how the scheme is designed to respond to price shocks once trading starts. Companies preparing for ETS2 compliance may want to factor the revised intervention thresholds into their allowance budgeting and hedging plans ahead of the 2028 launch. 

Entry into force

Formal adoption by the Council and Parliament, plus legal-linguistic revision, is still pending. Once complete, the revised reserve will apply ahead of ETS2's operational launch in 2028. 


Further reading

ETS2 market stability reserve: Council and Parliament reach provisional agreement, Council of the EU

What happened

Brazil's federal government issued Decree No. 13,094 on August 12, 2026, establishing the operational framework for the ProBioQAV sustainable aviation fuel program. The decree sets a CO2 reduction mandate starting at 1% from January 2027 and rising to 10% by January 2037, applying to aviation operators emitting 10,000 tonnes of CO2 or more annually. Compliance is met through a book and claim system: operators retire Sustainability Certificates for Sustainable Aviation Fuel (CS-SAF), with carbon credits and other alternative instruments available as a partial offset, capped at 15% of the annual target through 2028 and stepping down to 5% from 2030 onward. 

What it means for your business

Airlines and fuel suppliers operating in Brazil now have a fixed compliance timeline to plan procurement against, alongside the other aviation carbon compliance obligations, such as CORSIA and EU ETS, that many of the same operators already manage. The book and claim model lets operators source certified sustainable aviation fuel or eligible offset instruments from outside their direct supply chain, widening the pool of counterparties available to meet the mandate. Companies with Brazilian aviation exposure can map their CS-SAF and offset procurement needs against the January 2027 start date and the declining offset caps that follow through 2030. 

Entry into force

The mandate takes effect on January 1, 2027, in Brazil. Complementary monitoring, reporting and verification rules remain under public consultation, with ANAC's consultation period open through October 1, 2026. 

Further reading

Sustainable Aviation Fuel (SAF): ANAC launches public consultation following the issuance of the regulatory decree, Mayer Brown 

What happened

Singapore and Laos signed a bilateral Implementation Agreement under Article 6 of the Paris Agreement on September 4, 2026, establishing the legal framework for generating and transferring internationally corresponding-adjusted carbon credits between the two countries. It's Singapore's twelfth such agreement and its fourth with an ASEAN member state. 

What it means for your business

The agreement creates a new sovereign-authorized supply route for internationally transferred mitigation outcomes (ITMOs) originating in Laos, which companies can apply toward Singapore's carbon tax obligations under approved international credit categories. Businesses with carbon tax liabilities in Singapore, or with Southeast Asian supply chains generating emissions-reduction projects, are able to assess whether Laos-originated credits fit their compliance or voluntary procurement strategy. 

Entry into force

The agreement is in force from the signing date of September 4, 2026. Detailed project eligibility and crediting procedures will follow as both governments implement the agreement. 

Further reading

Singapore and Lao People's Democratic Republic sign Implementation Agreement on carbon credits under Article 6 of the Paris Agreement, Singapore Ministry of Trade and Industry 

What happened

Washington State's Department of Ecology published final rule language enabling its Cap-and-Invest program to link with the California-Quebec joint carbon market, effective October 24, 2026. Washington's implementation plan, describing how the state will operate under linkage, is due for publication later in September 2026. California and Quebec still need to complete their own rulemakings and approvals before the three-way market can formally launch, which could happen as early as 2027. 

What it means for your business

Once linked, the three jurisdictions will hold joint allowance auctions and trade under a shared price. Companies with compliance obligations under Washington's Cap-and-Invest program, or that already trade in the California-Quebec market, can review how a combined allowance pool and joint auction calendar affects their compliance planning across all three jurisdictions. 

Entry into force

Washington's linkage rule takes effect October 24, 2026. California and Quebec's own approvals are still pending, so the joint market is not yet operational; a formal three-way launch could occur as early as 2027. 

Further reading

Washington publishes final rule language to enable California-Quebec carbon market linkage, Carbon Pulse · Cap-and-Invest linkage, Washington State Department of Ecology 

Advisory support is included in every service we deliver. Our specialists help you assess needs, choose the right approach, and plan next steps. Every solution is aligned with your industry requirements. Support with local and international regulations helps set you up for effective execution.

Disclaimer

This content reflects regulatory developments confirmed as of September 30 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.

This content does not constitute legal, regulatory, tax, or compliance advice. Readers should obtain independent professional advice before acting on the information contained herein.

Neither ACT Commodities Group B.V. nor any of its subsidiaries, affiliates, or group companies (together, "ACT Group"), nor their respective directors, officers, employees, or agents, accepts any liability for any loss or damage arising from the use of, or reliance on, any information set out herein, except to the extent such liability cannot be excluded by applicable law. ACT Group is under no obligation to update this content after the date of publication.

© ACT Commodities Group B.V. [2026]. All rights reserved. Reproduction or distribution without prior written consent is prohibited. This disclaimer is governed by the laws of the Netherlands.