If you want to understand the fragility of carbon pricing, look no further than the 2025 trading chart for Alberta TIER credits.
In a recent ClearBlue Markets webinar, hosted by CEO Michael Berends, the panelists dissected a market that has been defined less by supply and demand fundamentals and more by regulatory announcements. As Nico Curtis, Manager of Market Analysis at ClearBlue, highlighted, the market saw a staggering swing in value over the last twelve months:
- Start of 2025: Credits were trading comfortably around CAD 39.
- The Crash: Following the September 2025 announcement of the "Direct Investment Pathway" (DIP) prices reached a low of CAD 17 by November.
- The Rebound: After the Canada-Alberta MOU signaled a renewed commitment to the system, prices recovered to the CAD 35–36 range
This volatility vividly illustrates what Principle Economist Dave Sawyer calls "stroke of pen risk"—the reality that a single government signature can cut the value of a compliance asset in half, or double it overnight.
As Michael Berends noted in his opening remarks, the recent Memorandum of Understanding (MOU) between Ottawa and Alberta represents a "turning point" in this volatile landscape, signaling a shift from confrontation to compromise. But as the experts revealed, the path to the 2026 federal benchmark review is paved with complex technical amendments and significant supply challenges.
Here is a comprehensive deep dive into the insights offered during the event.
1. The Fine Print of TIER: Reactivation and Investment Credits
While headline prices grab attention, the structural changes to the Technology Innovation and Emissions Reduction (TIER) regulation will dictate market behavior for the next decade. Nico Curtis provided a granular breakdown of the December 2025 amendments, highlighting several sleeper details that compliance managers must watch.
The Reactivation Mechanism Perhaps the most technically significant update is the interaction between the new Investment Credits and old inventory. Curtis highlighted a mechanism that allows facilities to "reactivate" previously retired offsets or Emission Performance Credits (EPCs) from the three preceding compliance years (starting with the 2025 vintage).
By submitting audited statements early (by March 31), facilities can swap these retired credits out to use new Investment Credits instead. This effectively allows companies to pull old supply back out of retirement and resell it or bank it for future use.
“It has the potential to shake up the demand side and recirculate previously retired credits.” — Nico Curtis
Direct Investment Pathway (DIP) Calculations Curtis also clarified the math behind the controversial DIP. Investment Credits (ICs) are calculated by dividing the Eligible Investment by the Fund Credit Price (set at $95 for the 2025 compliance year). Crucially, strictly enforced limitations will prevent these credits from flooding the secondary market:
- Usage Limits: ICs can meet up to 80% of a facility's compliance obligation in 2025, rising to 90% in 2026.
- Non-Transferable: Unlike offsets, ICs are facility-specific and cannot be traded.
- The Unknown Variable: The market is still waiting on the "Standard for Direct Investment," an unpublished document that will define exactly which projects qualify.
Opt-Outs and Thresholds With the removal of the consumer carbon tax, facilities were permitted to opt out of the federal fuel charge and partially out of TIER. ClearBlue modeling forecasts that approximately 20 to 21 million tonnes of emissions could leave the program as a result.
Simultaneously, potential federal benchmark proposals may lower the mandatory threshold to 10,000 tonnes of CO2e (down from the current 100,000 in TIER), potentially recapturing smaller facilities. During the discussion on the Environment and Climate Change Canada (ECCC) paper, Curtis noted that "Option C" (a combination of thresholds and activity-based inclusion) would likely be the most effective for market liquidity, as it aggregates smaller facilities in sectors like oil and gas to create a broader compliance pool.
2. The Supply Glut: The 47 Million Credit Question
A major theme of the webinar was the "TIER Bank"—the massive surplus of credits currently suppressing prices. Curtis presented the 2024 compliance results to illustrate the structural looseness of the market:
- Credit Demand: ~12.79 million
- Credit Supply: ~13.82 million (EPCs and Offsets combined)
- The Surplus: The TIER bank currently holds approximately 47 million credits.
This massive oversupply poses a critical problem for the federal government's proposed Magnitude Test. This test suggests that an accumulated bank of credits should be small enough to be absorbed by the market within three years.
“Given the current large base of 47 million credits, we'd assume significant changes would have to come from the provincial side to meet some of these testing requirements.” — Nico Curtis
3. The Direct Investment Pathway: Innovation or Loophole?
The introduction of the Direct Investment Pathway (DIP) sparked a philosophical debate among the panelists regarding the purpose of carbon pricing. The DIP allows facilities to generate compliance credits through monetary investments in technology (like CCUS) rather than verified emission reductions.
Dave Sawyer defended the logic behind the policy, citing the economic reality of decarbonizing heavy industry. He argued that large-scale Carbon Capture, Utilization, and Storage (CCUS) projects are "lumpy, multi-billion dollar investments" that simply do not pay off on an operational basis under current TIER prices without additional support.
However, Michael Berends challenged the mechanism's impact on market efficiency, questioning the logic of effectively subsidizing the carbon price for polluters.
“To double up and say, 'I'll give you a carbon discount on your carbon price if you invest in reductions'... I think it kind of beats the whole point of a carbon price.” — Michael Berends
The consensus? While politically expedient to fund CCUS, the DIP risks watering down the system. As Sawyer noted, if the government gives a break to investors via the DIP, they must tighten stringency elsewhere by limiting offsets or reducing the bank to maintain the price signal. It is a hydraulic relationship: "When you push on one side, it comes out the other".
4. The Canada-Alberta MOU: The $130 Compromise
The discussion moved to the political quid pro quo of the recent MOU. In exchange for Alberta regulating electricity generators through TIER (suspending federal Clean Electricity Regulations), the federal government has agreed to prioritizing the Northwest Coast Oil Pipeline and withhold the oil and gas emissions cap.
A critical component of this agreement is the Minimum Effective Credit Price, which mandates that the TIER system ramp up to CAD 130 per tonne.
How do we get to $130? During the Q&A, a listener asked if the government buying up excess credits (procurement) was a feasible solution to clear the glut and hit that price target. Dave Sawyer confirmed that aggressive intervention is unavoidable.
Sawyer argued that procurement "has to be on the table," alongside other levers like expiry limits, because simply tightening benchmarks might not be enough to drain the bathtub of supply while 5 to 7 million tonnes of new offsets flow in annually.
5. Federal Benchmark Review: Static vs. Dynamic Testing
Dave Sawyer walked attendees through the Environment and Climate Change Canada (ECCC) discussion paper, emphasizing that the headline price of a credit is often a poor indicator of a system's actual stringency.
The Effective Marginal Compliance Price (EMCP) Sawyer introduced the concept of the EMCP, which accounts for the weighted average of all compliance pathways: fund payments, offsets, and performance credits. He presented modeling data showing that across 60+ scenarios, a quarter of them had identical market prices but vastly different effective marginal prices.
He contrasted two provincial systems to illustrate why this matters:
- British Columbia: A system with high administrative stringency. Because traded credits are limited to 30% of compliance, facilities face the full carbon tax on 70% of their emissions. The stringency is high, even with a a low market price.
- Newfoundland: A system that likey fails many ECCC tests due to a massive surplus. However, because the utility has a regulated price floor at 93% of the ceiling price and monopsony power (one dominant market player), the effective price is likely one of the highest in the country.
Sawyer’s conclusion is that we need dynamic tests. A system might look good on paper (static) but fail in practice as markets evolve.
“A lot of systems could pass, frankly, these tests and look very weak... We need dynamic tests that are ongoing to allow for, frankly, systems to course correct.” — Dave Sawyer
6. The Fragmentation Problem: A Plea for Harmony
The event concluded with a broader look at the Canadian market's fragmentation. Michael Berends expressed frustration with the current patchwork of provincial systems, where prices range from effectively $0 in Saskatchewan to over $70 in Ontario and Quebec.
“I thought Canadians could generally get along... but unlike all of Europe, we can't get to one single carbon price.” — Michael Berends
Berends argued that this lack of alignment scares away capital. Multinationals prefer investing in regimes with clear, long-term certainty. He proposed a creative solution to the current imbalance: Fungibility.
“Ontario has a program that currently doesn't have any offsets in it... Maybe our governments could agree that some supply of Alberta credits could go into Ontario.” — Michael Berends
Such a move would solve Alberta’s oversupply issue while providing Ontario emitters with lower-cost compliance options, though it would require a level of inter-provincial cooperation that has so far been elusive.
Conclusion: The Road to 2026
The webinar painted a picture of a market in transition. The April 1, 2026 deadline for finalizing the industrial carbon pricing agreement looms large.
Until then, market participants must navigate a complex web of stroke of pen risks, new investment pathways, and technical amendments. As Dave Sawyer put it, the tests we have now are necessary, but not sufficient."The success of Canada’s carbon future will depend on whether policymakers can turn these static agreements into a dynamic, functioning market that actually drives decarbonization.”