Qualifying carbon pricing schemes

HMRC published on 27 August 2026, as guidance, a list of current qualifying carbon pricing schemes, based on information available as of 19 June 2026, which it describes as not exhaustive and as a draft list to be kept under review. The list is guidance and regulation 6 of SI 2026/809 is the test: an importer whose supplier sits under one of the sixteen has a starting point, and one whose supplier does not has the regulation to apply.

The page states that a listed scheme ceases to qualify if it later fails the criteria, that an unlisted scheme may still qualify if it meets them, and that the liable person remains responsible for determining eligibility.

The test in regulation 6

Regulation 2 of SI 2026/809 defines a carbon pricing scheme as an emissions trading scheme, a carbon tax, or an amount required to be paid in relation to emissions under the law of a country in connection with importing goods into it. Regulation 6(1) requires four things of a qualifying scheme. It must be administered by or on behalf of a city, a province, state or region or a group of them, a national government or a supra-national organisation, with the use of the revenue determined by or on behalf of that body. It must require, as a matter of law, that all installations that manufacture or process a CBAM good participate, or all such installations above a specified level of emissions. It must impose a cost on relevant emissions, directly or indirectly. And its rules, scope and headline carbon price must be made publicly available by the body administering it.

Regulation 6(2) explains that a cost is imposed directly by charging a price per tonne of carbon dioxide equivalent emitted, and indirectly by charging a price for fossil fuels used, multiplied by an emissions factor from a source identified in a Treasury notice. As at 21 September 2026 the final notice under regulation 6(2)(b) had not been published; HMRC's draft Administrative Provisions and Determination of Carbon Price Relief notice of 14 July 2026 names the Intergovernmental Panel on Climate Change, the International Energy Agency and the United Nations Framework Convention on Climate Change as the sources, and the draft notice does not currently have force of law. Chapter 18 of UK CBAM for Importers covers the relief, the effective carbon price and form CarbonVP1.