CBAM-2026: Ukraine on the Threshold of a New Energy Era

The European Union is concluding the transition period of the Carbon Border Adjustment Mechanism (CBAM) — the carbon border adjustment system. Starting January 1, 2026, the mechanism will be fully implemented, covering imports of electricity from the Energy Community countries, including Ukraine.

At the same time, the Energy Community Secretariat published the CBAM Readiness Tracker 2025, which highlights steady progress by member states in decarbonization and alignment with the EU energy market.

“CBAM should serve as a bridge to the European Union, not a barrier,”
emphasized Artur Lorkowski, Director of the Energy Community Secretariat.

⚡ What Changes in 2026

CBAM enters its final implementation phase:

• Electricity importers will submit annual reports on CO₂ emissions associated with imports;

• A mechanism for payment of embedded emissions through the purchase of CBAM certificates will take effect;

• No exemptions or simplified regimes are foreseen for electricity under the Omnibus I package.

Although CBAM legally applies to EU importers, its impact will be directly felt by Ukrainian electricity exporters — as the cost of carbon certificates will be integrated into contracts and influence final pricing.

🔋 Ukraine’s Readiness for the New Market

Ukraine is already developing a Monitoring, Reporting, and Verification (MRVA) system and preparing a pilot launch of the national Emissions Trading System (ETS) in 2026.
This is a crucial step toward potential future CBAM exemption, contingent upon full market coupling with the EU.

According to the Energy Community, in 2024 the carbon intensity of member states’ energy sectors fell by 11%, while installed renewable energy capacity (excluding large hydropower) increased by more than 50%, reaching 5.1 GW — largely due to competitive auctions.

🌱 European Integration Through Climate Policy

CBAM is increasingly evolving into a driver of clean energy and regional integration.
For Ukraine, this represents not only a challenge but also a major opportunity — to accelerate its energy transition, develop a domestic carbon market, and strengthen its position as a reliable EU partner in climate and energy security.