Ten Company Groups Carry 72% of California’s Carbon Obligation

California’s cap-and-invest program covered 256.6 million tonnes of emissions in 2024, reported by 822 facilities and fuel suppliers belonging to 669 company groups. The ten largest groups carried 71.5% of the total. The two largest carried 27.3%, about 70 million tonnes between them.

Washington’s program is more concentrated still, with its ten largest groups carrying 81.7% of 59.8 million tonnes. In Québec, fuel distributors, which the environment ministry publishes as one total rather than by company, carried 66.3% of 57.0 million tonnes. Across the three programs, ten groups carried 64.7% of 373.4 million tonnes.

The largest obligations belong to suppliers of fuel. California’s top ten are seven suppliers of transport fuel, two natural gas suppliers and one electricity group. That is where each program places the obligation, and it decides who has to buy allowances and how the cost reaches consumers.

CARB MRR 2015–2024; Ecology GHG Reporting Program 2023–2024; MELCCFP covered emissions 2013–2024; Climate Decode company grouping.

In California, the largest group carried 14.2% of 2024 covered emissions, the top five 51.5% and the top 25 85.3%. The other 644 groups carried 14.7% between them. The largest group’s 36.5 million tonnes is almost as much as those 644 groups combined, at 37.8 million.

Washington’s 220 groups follow the same shape at a smaller scale. The largest carried 18.5%, the top five 60.2% and the top 25 94.4%. Québec’s curve starts at 66.3% because its fuel distributors appear as a single block; the 83 named groups behind them carried the remaining 33.7%, most of it in aluminium, cement, steel and refining.

Exhibit 1 · Cumulative share of 2024 covered emissions by company-group rank

CARB MRR 2024; Ecology GHG Reporting Program 2024; MELCCFP 2024; Climate Decode company grouping. Québec’s first group is MELCCFP’s total for fuel distributors.

All three programs put the obligation for transport and heating fuel on the companies that supply it. In California, transport fuel suppliers carried 46.3% of covered emissions in 2024 and natural gas suppliers 16.8%. Electricity carried 16.3%, refining and hydrogen 11.7%, and cement, oil and gas production and other industry 8.9% together. In Washington, fuel and gas suppliers carried 59.6%, electricity 22.7% and refining 11.3%. In Québec, fuel distributors carried 66.3%, and electricity and gas networks only 1.1%, on a mostly hydroelectric grid.

Exhibit 2 · Share of 2024 covered emissions by sector group

CARB MRR 2024; Ecology GHG Reporting Program 2024; MELCCFP 2024; Climate Decode sector grouping.

Suppliers of transport fuel receive no free allowances for the fuel they deliver in any of the three programs. California allocates to industrial facilities, electric and natural gas utilities, legacy contract generators and public wholesale water agencies (§95891 to §95895). Washington allocates to energy-intensive trade-exposed facilities, utilities and a waste-to-energy facility (RCW 70A.65.110 to .135), and Québec to industrial establishments. The largest obligations are therefore met mostly by buying allowances, and their cost reaches consumers through the price of fuel.

California’s covered emissions fell 25% between 2015 and 2024, from 340.4 to 256.6 million tonnes. The share carried by the ten largest groups stayed between 68% and 73% in every one of those years, and the largest group’s share moved between 13% and 17%. Québec’s fuel distributors carried between 66% and 71% of covered emissions in every year since they entered the program in 2015. Washington’s top ten carried 81.1% in 2023 and 81.7% in 2024.

Emissions have fallen without changing how the obligation is distributed.

• Most auction demand is compliance demand. Compliance entities bought between 80% and 88% of the current allowances sold at each joint California–Québec auction from November 2022 to February 2026, and between 73% and 93% at Washington’s auctions from May 2023 to September 2026. Most of the obligation behind that demand sits with a few groups.
• The cost reaches consumers through fuel prices. With 60% to 66% of the obligation on fuel and gas suppliers, most of each program’s allowance cost travels in the price of gasoline, diesel and natural gas.
• A few decisions move large volumes. A refinery closure, a change in a supplier’s fuel mix or a change in how one large group buys and banks allowances moves more of the obligation than hundreds of small emitters together.
• A long tail of small positions. The 644 California groups outside the top 25 averaged about 59,000 tonnes each in 2024.

Climate Decode · Advisory

Where does your company sit on the obligation curve?

We track facility-level emissions, allocation and auction data across California, Québec and Washington.

Sources

• CARB, Mandatory Greenhouse Gas Reporting data, 2015–2024
• Ecology, Greenhouse Gas Reporting Program publication, emissions years 2023–2024
• MELCCFP, emissions of establishments and fuel distributors subject to the cap-and-trade system, 2013–2024 (Données Québec)
• CARB and MELCCFP, joint auction summary results, November 2022 to February 2026; Ecology, auction summary reports, May 2023 to September 2026
• California Code of Regulations, title 17, §95891 to §95895; RCW 70A.65.110 to 70A.65.135
• Climate Decode company grouping and WCI analysis, October 2026

This article is market analysis provided for information only and is not investment advice.