Commission proposal Parliament position Council position (closely aligned to Commission Proposal
Emissions 2030 vs 2005 61% lower emissions by 2030 vs. 2005 63% lower emissions by 2030 vs. 2005 61% lower emissions by 2030 vs. 2005
Linear Reduction Factor (LRF) 4.2% LRF (percentage by which cap on emissions drops each year) 4.4% LRF in 2024 & 2025, 4.5% LRF from 2026 4.2% LRF
Rebasing (removal of EUAs from market to backdate changes to 2021) 117 million EUAs removed from market when legislation is approved (likely 2024) 70 million EUAs removed from market in 2024, 50 million in 2026 117 million EUAs removed from market when legislation is approved (likely 2024)
MSR Threshold 833 million upper threshold, buffer from 833-1096m MSR upper threshold 700 million TNAC, buffer between 700m and 921m. Upper threshold decreases by LRF 833 million upper threshold, buffer from 833-1096m
Restrictions on non-compliance market participant access from 2025, subject to Commission assessment MSR prolonging the 24% annual intake rate beyond 2023. Threshold of 400m allowances, above which those placed in reserve are no longer valid.
Intervention against price spikes Market intervention: Trigger = Price for 6 consecutive months is 2x average price in previous 2 years. If triggered, meeting to be convened to determine if intervention is necessary The Council has agreed to make releasing MSR volumes via Article 29a (mechanism to address excessive price fluctuations) more automatic – Council has probably lowered trigger price (currently 3x average price in the two preceding years) to 2.5x the average price in the two preceding years. Before, the proposal was to intervene if the market could be assessed to be driven higher by non-fundamental factors (i.e. speculators) – this assessment would be done by the Commission. Now it seems to be a more automatic process without the Commission having qualitative oversight. This is closely aligned with the Parliament’s position on Article 29a.
The two-year period ends before the first month of the period of six calendar months over which the trigger level has to be met.
Injection of 100m allowances from MSR subject to commission decision Final document confirms an automatic release of 75m allowances over three months in case the Article is triggered.
Maritime  Maritime: 100% compliance in 2026, phased in 2023-26 Maritime: 100% compliance from 2024 Maritime: 100% compliance in 2027, phased in 2024-26

20% emissions covered in 2024, 45% in 2025, 70% in 2026, 100% in 2027.

Aviation  Aviation: Full derogation to extra-EEA flights Aviation: flights from EEA to third countries to be covered by EU ETS  Plus: Align proposal with CORSIA –  The EU ETS will apply for intra-European flights (including the United Kingdom and Switzerland), while CORSIA will apply to EU operators for extra-European flights to and from third countries participating in CORSIA.
Aviation: free allocation phaseout by 2025 Aviation: free allocation phaseout by 2027 Aviation: free allocation phaseout by 2027.
CBAM (affecting initially: steel, aluminium, fertilizers, energy, cement) CBAM Phase in 2026-2035 (affects free allocation for covered sectors) Phase in 2027 – 2032 CBAM Phase in 2026-2035 (affects free allocation for covered sectors).
However, slower reduction to free allocations at the beginning and accelerated rate of reduction at the end of the 10-year period. 5% from 2026-2028, 7.5% from 2029-2030, 10% from 2031-2032, 15% from 2033-2034 and 20% in 2035
Under Council proposal, covered sectors would receive 70% of their free allocations in 2030
Benchmarks Benchmark reduction rate 2.5% vs. current 1.6% per year. Benchmark reduction to be minimum 0.4% – note the hot metal benchmark reduces by 0.2% at present For the next update of product benchmarks that determine free allocation, from 2026-2030, hot metal benchmark will be left alone rather than widened to include existing low or zero carbon steelmaking procedures. This protects steel production free allocations