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The EU ETS 2 at the Crossroads: Evaluating Reform Options

EPICO, in collaboration with Frontier Economics, has released a new policy report outlining a targeted reform strategy to ensure the fair and effective implementation of the new emissions trading system (EU ETS 2).


With its proposed 90% emissions reduction target for 2040, the European Commission has sent a clear signal:

The EU remains committed to climate neutrality. While this target offers planning certainty and affirms long-term ambition, it risks becoming symbolic without the backing of effective implementation tools.

To meet these goals, ETS 2 is indispensable. There is no credible alternative.

Yet political pressure is mounting — particularly from Central and Eastern European countries. Several are calling for delays or structural revisions to the system. The Czech Republic’s recent consideration of an opt-out shows just how tangible this resistance has become.

In our new Policy Report we explore how to safeguard ETS 2 without watering it down — proposing a smart, balanced reform strategy to keep the system fair, credible, and politically viable.

To enable a smoother rollout and secure Member State consensus, we recommend a two-step approach: Early investments through revenue frontloading (2025–2027), followed by activation of a reformed Market Stability Reserve (MSR).

Key Recommendations:

  • Frontload up to €50bn in ETS 2 revenues for early investment in heating, mobility, and social compensation measures
  • Reform the MSR — extend its operations beyond 2030 and combine it with a more gradual and responsive trigger rule and relative injection rates.
  • Do not extend the target price mechanism beyond 2029 to protect price signals and social funding
  • Implement an effective policy mix for emission reduction: scale up support via the Social Climate Fund, tax relief, and inclusive tools like e-mobility and renovation
  • Reject opt-outs, regional price differentiation & early auctioning — all weaken the system’s fairness and impact

Read the Policy Report here