Interactive · Policy & Scenarios

EU ETS Reform: Tracking Toward 2.5–3 °C, Not 1.5 °C

Nick Gogerty · Carbon Finance Lab · 17 July 2026 · Licensed CC BY 4.0

The EU Commission's latest ETS proposal made headlines, but the climate arithmetic tells a more sobering story than the 1.5 °C Paris goal suggests. Run through a four-expert framework, the reform is best framed as 2 °C aspirational, 2.5–3 °C probable. The interactive below compares the warming cone with and without the reform.

3.7% → 1.7%
Annual ETS cap cut: 3.7%/yr 2031–35, slowing to 1.7%/yr 2036–48
2048
Zero-emissions date for ETS sectors (~40% of EU emissions)
≤ 2%
International carbon credits admissible post-2036

The probability cone: before & after policy

Each band is a scenario; its width is the uncertainty around the central path (dashed). The dotted horizontals mark the two Paris reference lines — 1.5 °C and 2 °C. Toggle between the side-by-side comparison and a single overlay.

Interactive · CFL estimates
Global-warming trajectory, 2025–2050
Without reform · business-as-usual
With EU ETS reform · current proposal
Upside · ~2 °C Base · ~2.5 °C Downside · 3 °C+ BAU risk zone · 3.5 °C+
How to read it. Bands are Carbon Finance Lab estimates conditioned on the reform's stated cap trajectory and on assumptions about non-ETS sectors, credit integrity and technology — not a forecast. The three reform likelihoods below are the author's indicative subjective weights; because the scenarios overlap they are not a normalised distribution.
2.0 °C
Upside · ~30% likely
  • Hydrogen & green-steel breakthroughs accelerate cuts post-2036
  • Non-ETS sectors over-perform
  • International credits prove genuinely additional
2.5 °C
Base case · ~50% likely
  • ETS hits stated targets (~11% EU-wide cut by 2030)
  • Non-ETS sectors meet their own targets
  • ~55% EU cut vs 1990 — 2 °C-compatible only if all nations match
3.0 °C+
Downside · ~40% likely
  • Only ~50% of international credits genuine (additionality haircut)
  • Buildings, agriculture & transport lag their targets
  • 1.7%/yr post-2036 proves too ambitious; friction compounds

Methodology: a four-expert framework

The proposal was stress-tested across four mutually-exclusive lenses, each challenging a different assumption.

1 · Emissions modeller — physical science

Cumulative emissions, not the 2048 end-date, drive warming. Slow early action locks in roughly 0.3 °C this decade regardless of later targets. A ~11% cut by 2030 is far short of the −40 to −50% a 1.5 °C path needs.

2 · Policy analyst — systemic incentives

The ETS is one tool of many. If buildings, agriculture and non-ETS transport hit their own targets, the EU can still reach ~55% by 2030. If only the ETS moves, the package is off-track. It all hinges on policy stacking.

3 · Market-integrity skeptic — credit quality

"High-quality" international credits do not yet exist at scale, and Article 6 double-counting is a live risk. Assume ~50% of the 2% credits are real and effective ambition slips a further ~0.2 °C.

4 · Macro / feasibility analyst — real-world friction

The slowdown to 1.7%/yr is an admission that easy substitution is exhausted and hard-to-abate industry remains. 2048 is a wild card — 2040 on a tech breakthrough, 2055 on realistic friction.

The assumptions, and where they can break

AssumptionExpert viewRisk
Cap trajectory 3.7% → 1.7%Modeller: too slow early. Economist: realistic friction late.Under-delivers this decade; may over-promise post-2036
ETS-only pathwayAnalyst: incomplete — depends on non-ETS sectorsIf non-ETS lags, warming 2.7–3 °C
International credits (≤2%)Skeptic: only ~50% credibleEffective ambition +~0.2 °C
Technology progressEconomist: assumed neutral; actually a wild card±0.5 °C on breakthroughs vs bottlenecks
Cumulative emissions this decadeModeller: under-weighted in the 2020s–30sEarly deficit locks in ~0.3 °C

Four assumptions worth watching

1 · Non-ETS credibility. The single biggest execution risk. The ETS alone cannot carry the target; buildings, agriculture and transport must hit their own — and their track record is mixed at best.

2 · "High-quality" credits, defined. The 2% cap leaves room for definitional gaming. Standard carbon-market practice applies a 30–50% additionality haircut to stated impact.

3 · The 1.7%/yr rate post-2036. Needs independent verification, not political optimism. It assumes breakthroughs stay on schedule and ignores harder-to-decarbonise industry hitting substitution limits sooner.

4 · The cumulative-emissions maths. Even if 2048-zero is achievable, slower action now means more CO₂ in the atmosphere this decade — pre-locking warming regardless of the end-date.

The verdict

This proposal is a pragmatic political compromise that trades 1.5 °C ambition for perceived feasibility. Best framed as 2 °C aspirational, 2.5–3 °C probable. The execution test comes in 2025–2030: if non-ETS sectors move aggressively and international credits stay bounded and genuine, the pathway can bend toward the upside; if those assumptions slip, the downside toward 2.7–3 °C is substantial. Relative to business-as-usual, the reform still buys an estimated 0.7–1.2 °C of avoided warming by 2050.
Read the LinkedIn article All Policy & Scenarios

Sources & calculations

Cite this

Gogerty, N. (2026). EU ETS Reform: Tracking Toward 2.5–3 °C, Not 1.5 °C. Carbon Finance Lab. https://carbonfinancelab.com/eu-ets-warming-cone/

@misc{eu_ets_warming_cone_2026,
  author = {Gogerty, N.},
  title = {EU ETS Reform: Tracking Toward 2.5--3 C, Not 1.5 C},
  year = {2026},
  publisher = {Carbon Finance Lab},
  howpublished = {\url{https://carbonfinancelab.com/eu-ets-warming-cone/}}
}
© 2026 Carbon Finance Lab · CC BY 4.0 · Scenario estimates for informational purposes only; not investment advice and not an official forecast.