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Policy Commentary • CD-CCP-REG-2026

Evolving Carbon Pricing Regulations in Canada: Impact & What to Watch

The federal benchmark now runs to $140 by 2040, Alberta gets a credit price floor, BC gets compensated, and Saskatchewan sits outside every operating system. A market-by-market read of the federal OBPS, Alberta TIER, BC OBPS, and Ontario EPS after the July 2026 package.

By Koorosh Behrang • 12 min read

At a Glance — Our Assessment

Price Certainty

STRENGTHENED

A locked national trajectory to 2040, a regulated TIER credit floor from 2030, and CfDs replace annual political repricing.

2030 Ambition

WEAKENED

The 2030 headline drops from $170 to $115 — a 32% cut. Stringency eases for the largest buyers precisely when CCUS supply arrives.

Fragmentation

WIDENING

Credit prices span ~$0 (Saskatchewan, paused) to ~$72 (Ontario). The benchmark is becoming a set of negotiated bilateral deals.

The Reset by the Numbers

$115/t
New 2030 Headline (was $170)
$140/t
National Trajectory End-State 2040
$60/t
TIER Credit Floor at 2030
16Mtpa
Oil Sands Alliance Reduction Pledge
4+SK
Federal OBPS Jurisdictions; SK Backstop Unimplemented
30%
BC OBPS Compliance-Unit Limit From 2026
~$72/t
Ontario EPU — Canada’s Highest Credit Price
Dec 12026
BC Compensation Deal Deadline
In This Commentary
The Reset: How We Got HereThe New National TrajectoryFederal OBPSAlberta TIERBC OBPSOntario EPSCross-Market ImpactsWhat to WatchRelated Markets
Our View

In fourteen months, Canada removed its consumer carbon price, froze and then re-anchored its industrial price, and replaced a uniform $15-per-year escalator with a negotiated trajectory that runs to 2040. The July 2026 package — a west coast pipeline referral, a trilateral Pathways MOU, and the Canada–BC Cooperative Prosperity Agreement — is the first time the new architecture has been applied deal by deal, province by province.

For anyone holding, buying, or creating compliance credits, the question is no longer “what is Canada’s carbon price” — it is “what is the price, floor, and stringency in my system, and what did my province negotiate.” This commentary works through the four operating markets in turn.

1

The Reset: How We Got Here

Canada prices industrial emissions through the Greenhouse Gas Pollution Pricing Act (GGPPA) benchmark: provinces either run their own system that meets the federal minimum, or the federal Output-Based Pricing System (OBPS) applies as the backstop. Between April 2025 and July 2026, nearly every load-bearing element of that architecture changed.

Table 1 · Fourteen Months That Rewired Canadian Carbon Pricing
Date Event Why It Matters
Apr 1, 2025Federal fuel charge removed; BC repeals its carbon taxConsumer pricing ends; industrial systems lose their voluntary opt-in incentive
Nov 27, 2025Canada–Alberta MOUPipeline-for-carbon-policy framework; TIER credits jump ~25% on the news
May 15, 2026Implementation Agreement + federal benchmark trajectory updateTIER schedule to 2040, credit floor, CfDs; the same trajectory becomes the national headline path
Jul 1, 2026Alberta submits West Coast Oil Pipeline proposal to the Major Projects Office1 Mbbl/d, Trans Mountain corridor; the MOU’s first hard deliverable lands on time
Jul 2, 2026Pipeline referred to MPO; trilateral Pathways MOU with the Oil Sands Alliance; Canada–BC Cooperative Prosperity Agreement16 Mtpa oil sands reduction pledge for a stringency discount; BC secures compensation for the lower benchmark plus a National Carbon Credit Framework commitment

The through-line: industrial carbon pricing survived — every deal reaffirms it — but its parameters are now set in federal–provincial negotiation rooms, not in a uniform national schedule. The full updated benchmark, expected later in 2026, will codify what those rooms produced.

2

The New National Trajectory

On May 15, 2026 the federal government updated the headline price trajectory for every industrial carbon pricing system assessed under the benchmark — the same schedule agreed with Alberta days earlier. The trajectory is lower than the prior path through 2030 but extends ten years further, to 2040.

Table 2 · Prior vs Updated Headline Trajectory, CAD per tonne CO₂e
Year Prior Benchmark Updated Trajectory Delta
2026$110$95 (hold)–$15
2027$125$100–$25
2030$170$115–$55
2035Not defined$130New certainty
2040Not defined$140New certainty

Updated trajectory holds $100 from 2027–2029, steps +$3/yr from 2030–2035, then escalates ~1.5%/yr to $140 in 2040. A full updated federal benchmark is expected later in 2026.

Two readings coexist. Bearish: the 2030 price signal is cut by roughly a third, and a $3/yr nominal ladder likely trails inflation mid-decade. Bullish: for the first time, every project financier in Canada can underwrite a carbon price to 2040 with federal–provincial agreement behind it — and in Alberta, a regulated floor under the credit itself.

3

Federal OBPS — Where It Actually Applies

The federal OBPS operates today in Manitoba, Prince Edward Island, Yukon, and Nunavut. It is also the legal backstop for Saskatchewan — but it has not been implemented there. After Saskatchewan paused its own provincial OBPS, large emitters in the province have faced an effectively zero carbon price, and Ottawa has so far not moved to apply the backstop. That gap — a province with no operating system and no enforced federal replacement — is the clearest evidence that benchmark enforcement has become a negotiation, not an automatic mechanism.

Where the federal OBPS does operate, it is a small market moved by outside forces. Facilities beating their output-based standard earn surplus credits; those exceeding it pay the excess emissions charge or remit surplus credits, federal offset credits, or recognized units — a category of select Alberta TIER offsets and BC forest carbon offsets.

CHARGE · SCHEDULE 4

The legal price still says $110

The May benchmark announcement did not amend Schedule 4 of the GGPPA, which sets the 2026 excess emissions charge at $110 on the old path. Aligning it to the $95/$100 trajectory requires an Order-in-Council — watch for it alongside the full benchmark.

CREDITS · ~$37.50

Priced by Alberta, not by its own fundamentals

The one-way inflow of cheaper recognized TIER units has dragged federal surplus credit pricing to roughly $37.50 — an acknowledged unintended consequence of the linkage design.

Impact of the reset. Two forces pull in opposite directions. The lower headline trajectory compresses the price ceiling — bearish for surplus credit values. But Alberta’s $60 credit floor from 2030 effectively imports a floor into the federal market through the recognized-unit channel: if TIER units cannot legally transfer below $60, the cheap supply that caps federal pricing disappears. Meanwhile, with the consumer fuel charge gone, voluntary participants that opted in to avoid it are exiting — regulatory amendments already allow this, and analysis by ClearBlue Markets pegs the potential demand loss at up to ~9.5% across evaluated programs.

SK

The Saskatchewan Question

A backstop that is never applied is a precedent, not a safety net. How the full 2026 benchmark treats Saskatchewan — equivalency deal, federal imposition, or continued abeyance — will define whether the GGPPA floor still binds anywhere it is unwelcome.

4

Alberta TIER — The Epicentre

Canada’s oldest and largest industrial carbon market is where the reset was negotiated, and where its mechanics bite first. We covered the Implementation Agreement’s architecture in detail in our May commentary; the July 2 trilateral MOU with the Oil Sands Alliance (Canadian Natural, Suncor, Cenovus, Imperial, and ConocoPhillips) now adds the industry counterparty.

The MOU’s core trade: the Alliance commits to 16 Mtpa of net emissions reductions — 6 Mtpa from Pathways carbon capture and storage by January 1, 2035, plus 5 Mtpa of additional reductions by 2040 and a further 5 Mtpa by 2045. In exchange, compliant Pathways companies face benchmark tightening of 1% per year instead of 2% from 2031–2040. Definitive agreements are due this fall.

01 · FLOOR

The $60 convergence trade

Credits that traded near $18 under the freeze must transfer at $60+ from 2030. Anything banked and held gains regulated value — but pre-floor credits are grandfathered, and a ~48 Mt bank still clears near-term compliance cheaply.

02 · STRINGENCY

A two-track demand curve

2% tightening for all to 2030; then 1% for Pathways-compliant firms vs 2% for large oil sands generally. The biggest structural buyers see their obligation growth halve exactly as Pathways CCS reductions arrive on the supply side.

03 · DIP

Direct investment, capped

The Direct Investment Pathway is limited to 50% of eligible capital and up to 50% of operating costs, net of other public support — scaled back from the 90% design that threatened to hollow out credit demand.

04 · CfD

75 Mt of contracted certainty

Jointly funded carbon contracts for difference cover up to 75 Mt of abatement from 2030–2040, administered so the effective credit price tracks toward $130 by 2040 — a quasi-guaranteed price for large projects.

Market read. TIER credits collapsed to roughly $18 during the freeze, jumped ~25% on the November MOU, and traded in the $30–40 range through Q1 2026. The forward curve now has a regulated anchor: hold-to-2030 economics improve mechanically as the floor approaches. Everything else turns on how Alberta defines and manages the effective price — the market price of credits it has agreed to steer toward $130 by 2040 — via offset usage limits, stringency top-ups, or floor design. The floor regulation, due by December 31, 2026, is the single most consequential regulatory document pending in Canadian carbon markets.

Key Insight: Watch forward-delivery contracts straddling January 1, 2030. The Implementation Agreement grandfathers pre-regulation credits through their original expiry — but how the floor applies to previously executed forward sales is explicitly unresolved, and the answer moves real money.

5

BC OBPS — Tightest System, First Compensation

British Columbia runs the most stringent design in the country: mandatory for industrial operations above 10,000 tCO₂e since April 2024, a compliance charge tracking the federal minimum ($95 for compliance year 2025), and a compliance-unit usage limit that tightens from 50% in 2024 to 30% from 2026 onward. Earned credits and BC offset units have traded around $65 against an $80 charge — the smallest discount of any provincial credit market except Ontario’s.

BC built its fiscal plan on the old ride to $170 by 2030 — and aligned its system to the federal benchmark in good faith, including repealing its consumer carbon tax when Ottawa dropped the fuel charge. The May reset strands that alignment. The Canada–BC Cooperative Prosperity Agreement (July 2) answers with a first-of-its-kind commitment: Canada will quantify the fiscal impact of the revised benchmark and negotiate a funding agreement that fairly compensates BC, with the arrangement due on or before December 1, 2026.

What the CPA Gives BC

Compensation + carbon market build-out

A negotiated payment for lost benchmark revenue; a commitment to explore a National Carbon Credit Framework spanning consumer sustainability credits (retrofits, EVs) and nature-based solutions; Northwest conservation financing consistent with 30x30; and the Clean Electricity ITC extended to intra-provincial transmission.

What It Means for the Credit Market

Demand-secure, supply growing

The 30% usage cap and 65% program stringency keep BC the most demand-secure market in Canada — modelling shows it only flips to oversupply if it harmonizes down to federal design. Compensation reduces BC’s incentive to soften. Meanwhile Great Bear-scale forest projects grow the BC offset supply, a subset of which flows into the federal OBPS as recognized units.

The precedent matters beyond BC: benchmark alignment is now a federally compensated liability. Expect other provinces to cite it in their own equivalency negotiations.

Exposed to more than one of these systems?

We model credit positions, floor exposure, and cross-market compliance strategy under the new trajectory — TIER, BC OBPS, Ontario EPS, and the federal backstop.

Contact Us →
6

Ontario EPS — The Closed Market Takes a Ceiling Cut

Ontario’s Emissions Performance Standards program is the structural outlier: offsets are not eligible for compliance. Facilities either remit Emission Performance Units (EPUs) generated by out-performing facilities, or pay the excess emissions charge. That scarcity design — combined with minimal public data on issuance and trading — has made ON EPS Canada’s tightest and most opaque credit market. EPUs trade around $72, the country’s highest credit price and the smallest discount to the government charge (for the 2023 compliance year, EPUs averaged $57 — a 13% discount to the $65 charge).

Ontario’s charge follows the federal benchmark, currently $110 for 2026 on the old path. The reset cuts the 2027 ceiling from a scheduled $125 to $100 — and in a market where the credit trades near the ceiling, cutting the ceiling directly cuts EPU value and the abatement economics built on it. An August 2025 amendment allowing voluntary participants to exit the program trims demand at the margin.

CEILING CUT

~$25/t off the 2027 forward

EPUs price off the charge. A $100 ceiling in 2027 instead of $125 is a direct haircut on holdings and on every abatement project underwritten against the old curve.

CBAM EXPOSURE

The EU gap widens

CBAM’s definitive period began in 2026. Ontario’s steel, cement, and fertilizer exporters are Canada’s most exposed — and a lower domestic trajectory widens the spread to the EU ETS price, raising residual CBAM liability.

NCCF WILDCARD

Could offsets crack Ontario open?

A National Carbon Credit Framework pressing for harmonization could eventually challenge the no-offset design — dilutive for EPU holders, transformative for offset developers eyeing a new compliance demand pool.

Ontario faces the same equivalency re-test as everyone else when the full benchmark publishes. Whether Queen’s Park mirrors the new trajectory promptly — or uses the moment to push for further softening — is the province-level decision to watch.

7

Cross-Market Impacts

The benchmark is now a floor negotiated deal-by-deal, not a uniform escalator. Alberta traded pipeline cooperation and CCUS for a softer, longer price path. BC traded corridor cooperation for compensation and infrastructure. Saskatchewan has so far traded nothing and pays nothing. The full 2026 benchmark publication must reconcile these bilateral outcomes into criteria that still mean something — on coverage, stringency, credit usage rates, and offset eligibility.

Offsets are fragmented three ways too — BC, Alberta, and the federal government each run their own offset program. Three separate legal frameworks, three protocol lists, three registries — and credits that are not interchangeable between them. For project developers, the choice of program determines protocol eligibility, buyer pool, and price floor exposure.

Table 4 · Three Governments, Three Offset Programs
Program Framework Example Protocols Where Credits Can Be Used
Federal — GHG Offset Credit SystemFederal offset regulations (2022) under the GGPPALandfill methane recovery, refrigeration systems, improved forest managementCompensation in the federal OBPS; applies nationally except where an equivalent provincial protocol already covers the activity
Alberta — Emission Offset SystemTIER Regulation — Canada’s oldest offset program, running since 2007CCS (Quantification Protocol v2.1), renewable electricity, landfill gas and methaneTIER compliance; select offsets flow into the federal OBPS as recognized units; the $60 transfer floor applies from 2030
British Columbia — B.C. Offset ProgramGreenhouse Gas Industrial Reporting and Control Act (GGIRCA)Forest carbon — the Great Bear projects are the flagship supplyBC OBPS compliance within the 30% compliance-unit cap; a subset of forest carbon offsets is recognized in the federal OBPS

The linkage is strictly one-way — provincial offsets can flow up into the federal system as recognized units, but federal credits are not accepted provincially and the provinces do not accept each other’s. Ontario accepts none of them. Québec runs a fourth protocol list inside its cap-and-trade system.

A National Carbon Credit Framework enters the picture — the first attempt to knit these together. The Canada–BC agreement commits both governments to work with provinces and territories on a framework covering credits from consumer sustainability choices — retrofits, EVs — and nature-based solutions. Read alongside Budget 2025’s first-ever federal language on linking and harmonizing credit markets, this is the clearest signal yet that Ottawa wants a common credit infrastructure spanning today’s fragmented systems. For offset developers — especially nature-based — it is the document stream to track.

Clean fuel and clean electricity credit systems are being recruited as carrots. The Pathways package contractualises a minimum 20% Clean Fuel Regulations credit-creation rate for upstream CCUS and extends the CCUS ITC to 2035; the BC agreement extends the Clean Electricity ITC to major intra-provincial transmission. Compliance credit systems beyond the GGPPA are now part of the federal deal-making toolkit — which supports credit supply, but also ties their parameters to megaproject politics.

CBAM is the external deadline nobody negotiated with. The EU’s definitive regime prices embedded carbon in imports from 2026. The lower Canadian trajectory widens the EUA spread, and it remains unresolved whether compliance met through offsets and credits — standard practice in TIER and BC — will be recognised as “carbon price effectively paid.” A weaker domestic price that isn’t CBAM-recognised simply transfers revenue from Canadian treasuries to Brussels.

8

What to Watch

Table 3 · The Regulatory Calendar, Q3 2026 → Q3 2027
Deadline Milestone Market Most Affected
Fall 2026Pathways definitive agreements; full updated federal benchmark published; Schedule 4 Order-in-CouncilAll systems; federal OBPS charge
Oct 1, 2026MPO process on national-interest listing of the West Coast Oil Pipeline under the Building Canada ActTIER (Pathways conditionality)
Dec 1, 2026Canada–BC compensation arrangement for the revised benchmark; CPA first-wave deliverablesBC OBPS; precedent for all provinces
Dec 31, 2026Alberta enacts the TIER credit price floor regulationTIER; federal OBPS via recognized units
Through 2027Equivalency re-assessments under the new benchmark; Saskatchewan resolution; National Carbon Credit Framework scopingON EPS, SK, offset developers
Sep 2027Target date for the pipeline conditions document — the test of whether the entire deal architecture holdsTIER, BC, national policy durability

Bottom Line

Canada traded a higher carbon price for a longer, harder one: less ambition by 2030, more certainty to 2040, and — in Alberta — a regulated floor under the credit itself. Each market inherits the reset differently: the federal OBPS needs an Order-in-Council and a Saskatchewan answer; TIER holders get a 2030 convergence trade; BC gets paid to stay stringent; Ontario’s tight, closed market absorbs a straight ceiling cut.

The documents that will decide the next decade are all due within twelve months: the full benchmark, the TIER floor regulation, the BC compensation agreement, and the National Carbon Credit Framework. Position before they publish, not after.

About the Author

Koorosh Behrang — Founder of Climate Decode, Canadian Carbon Pricing series lead

Koorosh Behrang

Founder, Climate Decode

Founder of Climate Decode with more than 10 years of experience across decarbonization strategy, corporate sustainability, Net Zero target setting, and compliance carbon markets. His work centres on the interaction between decarbonization pathways and regulated carbon systems.

Koorosh has worked extensively across programs including WCI, Ontario EPS, Alberta TIER, BC OBPS, Canada’s Clean Fuel Regulations, the EU ETS, the EU Shipping ETS, and FuelEU Maritime, integrating carbon pricing exposure, credit strategy, and regulatory trajectory into capital allocation and long-term compliance planning.

Speak to Koorosh → LinkedIn →

© 2026 Climate Decode · Policy Commentary · Reference CD-CCP-REG-2026

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