Market Insight · CD-WCI-WA-2026
Washington Cap-and-Invest Linkage California · Québec

Washington allowance prices are converging toward California–Québec

Washington’s September auction settled at $39.50, cutting the premium over California–Québec to $7.02 after the three governments signed a linkage agreement.

By Koorosh Behrang · Founder, Climate Decode · · 6 min read

SEPTEMBER 2026 AUCTION Pricing the market it expects to join WASHINGTON −39% $64.56 → $39.50 CA-QC PREMIUM −80% $35.75 → $7.02 PRICE RATIO 1.22× from 2.24× in June BUDGET GAP −18% vs 2024 emissions All 6.28 million allowances sold and bids covered the offer 1.88 times, so the fall came from expected linkage rather than weak demand. California and Québec budgets are 6.2 times Washington’s so Ecology expects the linked price to follow the joint market. No 90-day notice by mid-October, so linkage cannot start before mid-January. Ecology auction summary reports; CARB and MELCCFP joint auction results.

Washington’s 2 September cap-and-invest auction settled at $39.50 per allowance, down $25.06, or 39%, from June’s $64.56 and the lowest current-auction price since September 2024. All 6.28 million allowances offered were sold, while qualified bids covered the offer 1.88 times, up from 1.74 times in June.

Washington’s standalone market balance still points to tight supply. Covered emissions exceeded the annual allowance budget in both years reported by Ecology. The 2026 budget of 49.0 million allowances is 18% below the 59.8 million tonnes emitted in 2024. Reserve demand was also strong before September, with compliance buyers bidding for 4.2 to 7.8 times the allowances offered at reserve sales between October 2025 and May 2026.

The September move is therefore better explained by expected linkage than by a change in Washington’s underlying balance. Washington, California and Québec signed their linkage agreement on 25 June. Once linkage takes effect, allowances issued by any of the three jurisdictions can be used across the linked market. Ecology expects the common price to be driven largely by California–Québec, whose combined 2026 allowance budgets are 6.2 times Washington’s. Washington’s premium over the California–Québec auction price fell from $35.75 in June to $7.02 in September, even as the California–Québec price increased.

$39.50

Washington’s 2 September settlement, down $25.06 or 39% from June

1.22×

Washington’s price relative to California–Québec, down from 2.24× in June

Zero

bids for reserve allowances at $65.26 on 30 September, after 7.79× cover in May

18%

2026 budget shortfall against 2024 covered emissions, or 14% on the amended budget

Ecology auction, reserve-auction and ECR summary reports (2025–2026); CARB and MELCCFP joint auction results #42–#48; Ecology GHG Reporting Program data; WAC 173-446-210.

Exhibit 1 · Washington and California–Québec current-auction settlements

Current-auction settlement prices in US dollars an allowance. The Washington line rises from about 50 dollars in March 2025 to 70.86 in December, eases to 64.56 by June 2026 and then falls to 39.50 in September. The California-Quebec line stays between about 26 and 29 dollars throughout and rises to 32.48 in August 2026. A dashed marker shows the linkage agreement signed on 25 June 2026.

Source: Washington Department of Ecology auction summary reports #9 to #15; CARB and MELCCFP joint auction results #42 to #48.

01

Washington’s Allowance Budget Remains Below Reported Emissions

Washington’s annual allowance budget declines by about 4.76 million allowances a year, from 63.3 million in 2023 to 49.0 million in 2026. Covered emissions were 64.0 million tonnes in 2023 and 59.8 million in 2024, above the budget in both years. Ecology has not yet published 2025 covered emissions.

Table 1 · Washington annual allowance budget and covered emissions

YearAllowance budgetCovered emissions (t CO2e)Emissions less budget
202363,288,56564,005,277+716,712
202458,524,90959,835,072+1,310,163
202553,761,254not yet published–
202648,997,598 (51,401,884 amended)not yet published–

WAC 173-446-210 Table 210-1, budgets in force before 24 October 2026, with the amended 2026 budget in parentheses; Ecology GHG Reporting Program data (data.wa.gov), covered emissions as revised in April 2026.

House Bill 1975 adds near-term supply. It increases the 2023–2026 budgets by about 6.0 million allowances in total, raising the 2026 budget to 51.4 million when the amended rule takes effect on 24 October. It also makes about 14.08 million additional reserve allowances available from 2027. Ecology’s implementation guidance links the change to ensuring that businesses hold enough allowances for the first compliance period, which closes with full surrender on 1 November 2027.

Market pressure was visible before the September auction. Quarterly settlements reached the reserve Tier 1 trigger in September and December 2025 and again in March 2026. Ecology then held four reserve sales between October 2025 and May 2026 at $60.43 and $65.26. All four sold out, with bids covering 4.2 to 7.8 times the volume offered.

Table 2 · Ecology reserve sales, October 2025 to September 2026

Reserve saleDatePriceOfferedSoldBids ÷ offer
APCR #41 Oct 2025$60.433,641,333All4.22
APCR #512 Nov 2025$60.433,641,333All6.15
APCR #611 Feb 2026$60.433,641,334All7.20
APCR #713 May 2026$65.26129,262All7.79
APCR #830 Sep 2026$65.26172,348None0.00

Ecology APCR auction summary reports #4 to #8 (Publications 25-14-059, 25-14-080, 26-14-017, 26-14-025 and 26-14-073).

02

September’s Price Fell 39% Despite Stronger Bidding

Auction #15 offered 6.28 million current allowances, including 2.80 million from Ecology and 3.48 million consigned by utilities. The offer was 28% larger than June’s 4.92 million, while demand increased faster. Qualified bids covered the auction 1.88 times compared with 1.74 times in June, and compliance entities purchased 79% of the volume. The auction cleared at $39.50, $11.58 above the $27.92 floor.

Two sales later in September reinforced that level. On 16 September, Ecology sold 731,000 vintage-2023 allowances from the emissions containment reserve at $39.50, with bids covering the volume 2.11 times. On 30 September, the annual pre-compliance reserve sale offered 172,348 allowances at $65.26 and received no bids. Those reserve allowances move directly into compliance accounts and cannot be resold, so buying at $65.26 was unattractive while current allowances were available near $39.50. In May, the same reserve price had attracted bids equal to 7.79 times the volume offered.

The additional supply announced under House Bill 1975 does not explain the September decline on its own. Ecology published the additions on 29 April, before the June auction cleared at $64.56. Its 11 June update shifted 5.57 million new vintage 2023–2026 allowances into the December auction without changing the total amount added. June also followed Ecology’s proposed linkage rule filed on 1 June. The material change between the June and September auctions was the 25 June linkage agreement itself.

03

The Premium Over California–Québec Narrowed to $7.02

From June 2025 through June 2026, Washington’s quarterly auctions settled at 2.24 to 2.50 times the price of the preceding California–Québec joint auction. In September, the ratio fell to 1.22 and the dollar premium narrowed by about 80%. The California–Québec price rose from $28.81 in May to $32.48 in August, while Washington moved sharply lower toward it.

Table 3 · Washington and California–Québec current-auction settlements, US$ per allowance

Washington auctionSettlePreceding California–Québec auctionSettleGapRatio
Mar 202550.00Feb 202529.2720.731.71×
Jun 202558.51May 202525.8732.642.26×
Sep 202564.30Aug 202528.7635.542.24×
Dec 202570.86Nov 202528.3242.542.50×
Mar 202665.26Feb 202627.9437.322.34×
Jun 202664.56May 202628.8135.752.24×
Sep 202639.50Aug 202632.487.021.22×

Ecology auction summary reports #9 to #15; CARB and MELCCFP joint auction results #42 to #48. Each joint auction was held about two weeks before the Washington auction beside it. Gap and ratio are Climate Decode calculations.

Washington’s amended rule defines the effect of linkage. From the effective date, California and Québec allowances can be surrendered in Washington, and Washington allowances can be surrendered in California and Québec under WAC 173-446-090(4). Ecology’s linkage findings state that the linked price is expected to be largely influenced by the California–Québec joint market because of its much larger scale.

The first Washington compliance period closes with full surrender on 1 November 2027. A buyer purchasing allowances in September was therefore pricing the probability that linkage takes effect before that deadline. If it does, California–Québec allowances that cleared at $32.48 in August can satisfy the same Washington obligation.

Washington’s advance auctions had already shown this convergence for later vintages. Allowances of the 2028 and 2029 vintages, which generally cannot be used before 2029 and 2030, sold at $26.61 in June 2025, $29.40 in December 2025 and $30.00 in June 2026. Each was within $1.24 of the same vintage in the preceding California–Québec advance auction, while Washington current allowances in those auctions sold between $58.51 and $70.86.

04

Three Steps Remain Before Linkage Takes Effect

Washington has completed its rulemaking. Ecology’s director signed the amendments on 17 September and they take effect on 24 October. Washington officials have said they expect the linked market to operate in 2027. Three remaining steps determine the effective date.

California rulemaking. CARB must adopt a regulation that accepts Washington allowances. Governor Newsom completed the findings required under Government Code section 12894 on 21 September, allowing CARB to proceed with formal rulemaking.

Québec approvals. Québec must amend its regulation to accept Washington allowances and complete the government approvals required by the linkage agreement.

Effective-date notice. Under Section 17 of the agreement, the three governments set the effective date in writing after completing their internal requirements. Washington’s rule requires Ecology to announce that date at least 90 days in advance under WAC 173-446-090(2)(a). No notice had been issued by mid-October, so linkage cannot begin before mid-January 2027.

The remaining $7.02 premium over California–Québec can be read as the market value of implementation risk. Section 23 describes the agreement as a voluntary initiative that creates no enforceable rights, and each government retains the ability to withdraw. If linkage were delayed beyond 1 November 2027, Washington entities would have to complete first-period surrender using Washington supply in a market where reported emissions have exceeded the allowance budget.

05

Four Events Will Test the Linkage Price

Four events over the next year will show whether Washington allowances remain anchored near the California–Québec price.

18 November 2026. California–Québec joint auction #49 will reset the reference price after Washington’s September auction cleared $7.02 above the linked market.

2 December 2026. Washington Auction #16 will offer 11.38 million current allowances, the largest current-vintage offer in the programme to date, including House Bill 1975 additions and utility consignment, plus 2.14 million 2029-vintage allowances. A settlement near California–Québec despite the larger volume would provide further evidence that buyers are pricing linkage.

CARB linkage regulation. The proposed regulation will open the formal comment period and provide a clearer timetable for California to complete its side of the link.

Ecology’s 90-day notice. The notice will set the linkage effective date. From that date, allowances from all three jurisdictions can be used across the linked market.

September buyers priced Washington closer to the market it is expected to join. Washington’s own balance remains tight, with reported emissions above budget and reserve sales heavily oversubscribed through May. The remaining premium over California–Québec reflects the regulatory steps still outstanding in California and Québec and the risk that the effective date is delayed. Progress on those steps should narrow the premium further, while delay would support a wider spread.

Climate Decode · Advisory

How will linkage change your Washington compliance cost?

Climate Decode tracks Washington and California–Québec supply, demand, auction results and each remaining linkage step.

About this analysis. Prices are current-auction settlement prices in US dollars from Ecology auction summary reports and CARB/MELCCFP joint auction results. Each Washington auction is compared with the California–Québec joint auction held about two weeks earlier. Gaps and ratios are Climate Decode calculations. Advance-auction comparisons pair the same vintage. Allowance budgets are from WAC 173-446-210 Table 210-1 as in force before 24 October 2026, with the amended 2026 budget shown separately. The 6.2 times market-size comparison uses 2026 budgets of 254.0 million for California, 49.08 million for Québec and 49.0 million for Washington. Covered emissions are Ecology GHG Reporting Program data revised in April 2026. The analysis uses published data only.

Sources

Washington Department of Ecology auction summary reports #15 (Pub. 26-14-063) and #14 (26-14-039), and #9 to #13 (25-14-003, 25-14-037, 25-14-051, 25-14-083, 26-14-003); APCR summary reports #4 to #7 (25-14-059, 25-14-080, 26-14-017, 26-14-025) and #8 (26-14-073); ECR Auction #1 summary (26-14-070); Auction Notice #16 (26-14-093); HB 1975 implementation guidance (26-14-035, updated 11 June 2026); Cap-and-Invest Linkage Criteria Findings (26-14-020, June 2026); Agreement on the Harmonization of Carbon Market Programs (June 2026); Chapter 173-446 WAC as adopted (CR-103), including WAC 173-446-090 and Table 210-1; Office of Governor Ferguson (25 June 2026); Office of Governor Newsom (23 September 2026); CARB and MELCCFP joint auction results #48 (August 2026), #47 (May 2026) and #42 to #46; Ecology GHG Reporting Program data.

This article is analytical research provided for information only and is not investment advice.

About the Author

Koorosh Behrang — Founder of Climate Decode

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 · Market Insight · Reference CD-WCI-WA-2026

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