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EU ETS 2 Guide: Compliance, Timeline and Carbon Prices

European cityscape with buildings, road traffic and industry representing EU ETS 2 sectors
Isaure Courcenet
Co-Founder & CEO

Summary: The EU ETS 2 is a new carbon market for buildings, road transport and small industry, now launching in 2028, with roughly 11,400 fuel suppliers required to surrender allowances.

Around 11,400 companies across Europe are about to face a carbon cost they have never priced before. The second EU Emissions Trading System extends carbon pricing to fuels burned in buildings, road transport and small industrial sites, sectors that together represent a vast share of the bloc's emissions. If your organisation supplies fossil fuels for combustion, this guide to the EU ETS 2 matters to your bottom line. For the broader context, our The EU ETS Explained: How Europe's Carbon Market Works sets the foundation.

The stakes are considerable. According to the EEA, in 2023 road transport and buildings covered by the ETS2 emitted 1,235 million tonnes of CO2 equivalent, with 61% from road transport and 28% from buildings. Understanding the rules early is the difference between managing cost and absorbing shock.

What the new carbon market actually covers

The EU ETS 2 is a distinct, parallel system to the original EU ETS that has operated since 2005. It applies the same cap-and-trade logic but targets different sectors. The European Commission confirms that the system covers fuel combustion in buildings, road transport and additional sectors, mainly small industrial emitters not captured by the first system.

The critical design choice is that it operates upstream. The obligation falls on fuel suppliers, not on end consumers such as households or car drivers. Regulated entities purchase allowances at auction and surrender them to cover the emissions embedded in the fuels they place on the market. The cap tightens over time: it is designed to bring emissions in these sectors down by 42% by 2030 compared to 2005 levels.

European street with buildings, traffic and a fuel truck illustrating ETS 2 covered sectors

To see how this second system fits alongside the wider policy architecture, our The Complete Guide to the EU Carbon Market in 2026 maps the full landscape.

The timeline: why the launch moved to 2028

The original schedule set full operation for 2027. That changed. In November 2025, EU co-legislators agreed to delay the ETS2 by one year, to start in 2028 instead of 2027, a move tied to negotiations on the 2040 climate target and concerns about energy prices and vulnerable households.

The postponement became definitive in early 2026. The EU Council formally adopted the amendments on 5 March 2026, moving the start of the system to 1 January 2028 to give Member States more preparation time. The practical sequence now runs as follows:

  • 2025: monitoring and reporting of emissions began.
  • 2026: emissions data must be verified by an accredited verifier.
  • 2027: early auctioning is expected to begin ahead of full operation.
  • 2028: the system becomes fully operational; surrender obligations apply.
  • 31 May 2029: the first surrender deadline, covering 2028 emissions.

The delay postpones the price signal, but it does not remove the obligation to prepare. Suppliers must still monitor, report and verify throughout the transition.

Who must comply, and what compliance requires

Compliance is not universal; it is concentrated among fuel suppliers. When the system was first proposed, the Commission estimated that approximately 11,400 entities across the EU would be regulated. These are the companies that release fuels for consumption, such as fuel distributors and suppliers liable for energy tax.

The core duties are sequential. Regulated entities must hold a greenhouse gas emissions permit and an approved monitoring plan, then report emissions annually. Covered entities must surrender one allowance per tonne of CO2 emitted, and the penalty for non-compliance is steep: an excess emissions charge of EUR 100 per tonne, adjusted for inflation, on top of buying and surrendering the missing allowances.

Because the compliance cycle spans monitoring, verification and surrender, preparation cannot wait for the auctions to open. Our EU ETS Readiness: How to Prepare for Carbon Market Compliance breaks the operational steps into a practical checklist.

How allowances are auctioned and priced

Unlike the first system, which historically allocated some allowances for free, the EU ETS 2 distributes allowances exclusively via auctioning. Price is therefore set by supply and demand, which introduces volatility that obligated companies must plan around.

Several stabilisation mechanisms exist. A frontloading mechanism increases the initial auction volume to smooth the launch, and a rule-based Market Stability Reserve (MSR) adds or withdraws allowances to counter excessive or insufficient supply. There is also a price safeguard: during the first two operational years, if the allowance price exceeds EUR 45 in 2020 prices, additional allowances may be released from the reserve. This is a dampener, not a hard cap, so prices can still move well beyond that reference.

For a deeper explanation of how these units trade, see our EU Allowances Explained: How EUAs Work and Trade in 2026.

Managing carbon price risk before 2028

Consider a mid-sized fuel distributor facing its first surrender in 2029. Every tonne sold in 2028 will require an allowance bought in an auction-driven market with no guaranteed ceiling. Waiting until the compliance deadline exposes the business to whatever price the market sets. Proactive hedging converts that unpredictable exposure into a planned cost.

This is where market access design matters. Traditional exchanges typically require large minimum lot sizes, which can lock smaller operators out of precise, incremental hedging. On our platform, you can trade from a single allowance rather than a standard block of 1,000, with real-time pricing and pre-trade risk controls that let you size exposure exactly. The table below illustrates the difference in access.

FeatureTraditional carbon exchangeOur exchange platform
Minimum trade sizeStandard lot of 1,000 EUAsFrom 1 EUA (1 tonne of CO₂)
Live price transparencyLimitedReal-time price monitoring
Automated executionVariesAPI access and configurable alerts
Pre-trade risk controlsVariesBuilt in
Cash protectionVariesGuaranteed up to 100 k€ by the FGDR

Whether you are a compliance entity or a financial participant, granular access lets you build a hedging position that matches your actual obligation rather than an arbitrary lot size.

Analyst reviewing carbon allowance price charts on trading screens

The Social Climate Fund and the wider stakes

The system was designed with a social counterweight. Revenues from the EU ETS 2 feed a dedicated Social Climate Fund intended to protect households and micro-enterprises exposed to higher fuel costs. Together with a mandatory 25% Member State contribution, the Fund should mobilise at least EUR 86.7 billion between 2026 and 2032.

For businesses, the takeaway is strategic rather than social. The political effort to cushion consumer impact signals that policymakers intend to keep the carbon price meaningful. The delay to 2028 buys preparation time; it does not soften the eventual obligation. Companies that treat the interim years as a window to build monitoring capability, procurement strategy and hedging discipline will enter the market with an advantage.

Conclusion

The second EU emissions trading system reshapes carbon obligations for roughly 11,400 fuel suppliers, applying an auction-only market to buildings, road transport and small industry from 2028. The 2028 launch is now fixed in law, the first surrender falls in 2029, and prices will be set by a market with dampeners but no hard ceiling. The practical response is to prepare now: verify emissions data, model your exposure, and put a hedging strategy in place before auctions open. Precise, low-minimum access to the allowance market lets you match every tonne of obligation without over-committing capital or accepting oversized lots. To take the next step, explore our solutions for traders and corporates and start planning your carbon strategy today.

Frequently Asked Questions

When does the EU ETS 2 start?

The system becomes fully operational on 1 January 2028, after EU co-legislators postponed the original 2027 date. The postponement was formally adopted in March 2026. The first allowance surrender deadline is 31 May 2029, covering 2028 emissions.

Who has to buy allowances under the EU ETS 2?

The obligation is upstream, so it falls on fuel suppliers rather than households or drivers. The Commission estimated that around 11,400 entities across the EU, mainly fuel distributors, will be regulated and required to surrender allowances.

How can companies manage EU ETS 2 price volatility?

Because allowances are auction-only with no hard price cap, hedging in advance is the main tool. On our exchange platform you can trade from a single allowance with real-time pricing and pre-trade risk controls, letting you size exposure precisely to your obligation.

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