From Four Prices a Year to Fifty-Two: How the CBAM Certificate Price Changes in 2027

On 5 October 2026, the Commission publishes the CBAM certificate price for Q3. It will be the third of four quarterly prices this year - and one of the last quarterly prices anyone will ever see.

From 2027, the Commission publishes a weekly price. Four numbers a year becomes fifty-two. For most importers that reads as a technical footnote. For treasury it is the difference between a budget line and a market position.

The short version

• The CBAM certificate price is the weighted average of the auction clearing prices of EU ETS allowances - not a spot index, not a futures settlement.
• In 2026 the Commission publishes four quarterly prices, each fixed in the first week after the quarter ends.
• Published so far: €75.36/tCO₂e for Q1 2026 (published 7 April 2026) and €75.28/tCO₂e for Q2 2026 (published 6 July 2026). Q3 is due 5 October 2026; Q4 on 4 January 2027.
• From 2027, pricing goes weekly.
• Certificate sales open on 1 February 2027, with a quarterly holding requirement and limits on repurchase.

How the price is actually built

The methodology matters more than people assume, because it explains the behaviour of the number.

The price is derived from auction clearing prices for EU ETS allowances, weighted and averaged. It is not the secondary-market spot price, not the December futures contract, and not a closing print on any given day. It is the price at which allowances actually cleared at auction over the reference period.

Two consequences follow:

It is smoother than the market. Averaging across many auction events strips out intraday and single-session volatility. A one-day spike in EUA futures does not move your CBAM price the way it moves a trader's book.

It lags the market. By construction, an average of past auction clearings is backward-looking. If the ETS price is trending, your CBAM price arrives behind the trend. In a rising market that flatters you briefly; in a falling one it costs you briefly. Neither effect is large under quarterly publication - you can see it in the €0.08 gap between Q1 and Q2 2026 - but the underlying ETS market is capable of far more movement than that, and 2026's unusual calm is not a forecast.

What quarterly gives you that weekly does not

Under the 2026 regime, the price for a completed quarter is fixed, knowable and published shortly after the fact. Once 7 April arrived, every Q1 import in the EU carried the same €75.36 reference. You could accrue against it with near-certainty. There was exactly one price variable per quarter, and after the first week of the following quarter there were none.

That is an unusually comfortable position, and it ends in 2027.

	Quarterly (2026)	Weekly (from 2027)
Prices published per year	4	52
When fixed	First week after quarter end	Weekly, shortly after the reference period
What you can rely on	One reference price per quarter, known retrospectively with certainty	A price curve; the applicable price depends on each import's timing
Accrual method that works	Single rate per quarter, applied to quarterly volume	Per-shipment rate, tagged to release date, rolled up
What breaks	Very little	Aggregate volume × single annual rate. Any model that assumes one price
New exposure created	Minimal	Intra-year timing of imports becomes a cost variable

The obligation attaches per import. Once the reference price moves weekly, when goods are released for free circulation determines which price applies to them. A decision that was previously about logistics, working capital and quota position acquires a carbon-price dimension.

An illustrative example

The figures below are illustrative round numbers, chosen to show the mechanism. They are not forecasts.

Take an importer with 40,000 tCO₂e of embedded emissions across the year, and suppose the weekly certificate price drifts from €70 in January to €90 in December.

• Even distribution - 10,000 tCO₂e per quarter, average applicable price ≈ €80. Certificate cost ≈ €3.2m before the CBAM factor.
• Front-loaded - 60% of volume in H1 at an average of ≈ €74, 40% in H2 at ≈ €86. Weighted average ≈ €78.8. Cost ≈ €3.15m.
• Back-loaded - 40% in H1, 60% in H2. Weighted average ≈ €81.2. Cost ≈ €3.25m.

The spread here is around 3% on identical annual volume and identical emissions. Apply the 2026-level CBAM factor and that difference is trivial; apply a factor several times larger later in the phase-in, on a market that has moved more than €20 across a year, and it stops being trivial.

The point is not that you should time the market. It is that your import pattern now has a price consequence you did not previously have to model, and finance will eventually ask you to quantify it.

Why you cannot simply buy early and forget it

The obvious response - buy certificates when they are cheap - runs into the design of the purchase regime.

Certificate sales begin on 1 February 2027. There is a quarterly holding requirement, which sets a floor on how many certificates you must hold relative to your accrued obligation. And there are limits on repurchase: the mechanism for selling unneeded certificates back is bounded, not open-ended.

That gives you a genuine two-sided constraint:

• Under-buy and you breach the holding requirement, with penalties that do not extinguish the underlying certificate obligation.
• Over-buy and you have converted cash into an instrument you may not be able to fully liquidate at will.

We have covered the purchase and surrender mechanics in how buying and surrendering will work from 2027 and the draft repurchase rules in Inside the July 2026 Draft Rules. What weekly pricing adds is that the cost of getting this wrong now varies week to week rather than sitting still for three months.

The underlying driver is the ETS price

None of this is really about CBAM. The CBAM certificate price is a derived number; the thing that moves is the EU ETS.

Which means your 2027 CBAM budget is, in substance, a view on the EU carbon price - and the July 2026 ETS reform proposal, with its reintroduction of free allocation from 2028 and extended CBAM phase-in, sits directly upstream of that view. Anyone building a CBAM price curve for 2027 and beyond should build it off an ETS price scenario rather than off a flat extrapolation of €75.

What to change in the 2027 budget model

1. Replace the single price assumption with a curve. Base, high and low ETS scenarios, converted to a weekly CBAM reference.
2. Tag every import with its release-for-free-circulation date. This becomes the key that joins volume to price. If your systems currently hold only month or quarter, fix that before January.
3. Build a rolling accrual. Per shipment, per applicable weekly price, rolled up - not an annual volume multiplied by one rate.
4. Set a purchasing cadence policy, in writing. Decide in advance whether you buy weekly, monthly or against the quarterly holding checkpoint, and who has authority to deviate. Ad hoc purchasing under a moving price is how organisations end up buying on the worst weeks.
5. Model the holding requirement as a cash-flow constraint, not a compliance checkbox. It determines how much working capital is tied up and when.
6. Decide who owns the price view. Compliance owns the emissions number. Someone in treasury has to own the price assumption. In most organisations nobody currently does.

What to do before year-end

• Diarise 5 October and 4 January for the remaining 2026 quarterly prices, and close out your 2026 accrual against the actual published figures rather than estimates.
• Confirm your systems capture release date at shipment level.
• Draft the purchasing cadence policy now, while there is no price pressure, and get it approved.
• Brief finance that the 2027 CBAM line is a variable-rate exposure, not a fixed cost - before they build the budget on a single number.
• Agree internally which ETS price scenario you are planning against, and revisit it quarterly.

Four prices a year was a gift. It let compliance hand finance a single clean number and let finance treat CBAM as a fee. Fifty-two prices a year turns it into something closer to a commodity exposure with a compliance wrapper. The mechanics are not difficult, but they need to be built before the first weekly price lands - not after.