Starting January 1, 2026, the European Union will complete the transition period of the Carbon Border Adjustment Mechanism (CBAM).
This new stage introduces the full application of CBAM to electricity imports into the EU — including from the Energy Community countries, among them Ukraine.
Although CBAM legally applies to importers within the EU, its implementation will directly affect Ukrainian electricity exporters, since the cost of carbon certificates will be reflected in commercial contracts and pricing mechanisms.
What changes in 2026:
- Electricity importers into the EU will switch from quarterly to annual greenhouse gas emission reporting related to imports.
- The payment mechanism for embedded CO₂ emissions will begin, requiring the purchase of CBAM certificates.
- No exemptions or simplifications are provided for electricity within the “Omnibus I” package.
What this means for Ukraine:
CBAM becomes a new regulatory factor influencing electricity exports to the EU.
A potential exemption from CBAM in the future is linked to:
- Full market integration (market coupling) with the EU, and
- The implementation of a national Emissions Trading System (ETS).
Ukraine is already developing a Monitoring, Reporting, and Verification of Emissions (MRVA) system and is preparing for a test launch of the ETS in 2026.
The Energy Community Secretariat, together with the European Commission, continues monitoring and consultations on the technical aspects of CBAM implementation and its impact on regional electricity markets.
Source: Energy Community CBAM Readiness Tracker 2025 (October 2025)