CBAM, CSRD Reduction, and Anti-Blackout Package: A Week Reshaping the ESG Landscape

From January 1, 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) enters its definitive phase^[1]. Importers of steel, aluminum, cement, fertilizers, electricity, and hydrogen into the European Union must register as authorized CBAM declarants^[2] and are required to purchase certificates linked to the weekly average EU ETS allowance price^[3], which at the beginning of February stood around EUR 79–84/t CO₂^[4]. The first annual declaration will be submitted by importers by September 30, 2027^[5] for the year 2026, and applicants for declarant status may benefit from a transitional period^[6], if they submit to customs authorities by March 31, 2026^[7]. However, the lack of finalized CBAM benchmarks maintains high market uncertainty^[8] and fuel discussion about expanding the mechanism to include processed products^[9].

CBAM with Real Costs and CSRD Cuts

At the same time, EU institutions are finalizing the Omnibus I deregulation package^[10], which sharply limits the scope of the CSRD directive. After an agreement reached on December 9, 2025, it will cover only entities exceeding simultaneously 1,000 employees^[11] and EUR 450 million in annual net turnover. The European Commission estimates business savings at EUR 4.4 billion annually^[12], while the number of covered companies drops by about 80%^[13]. EFRAG reduced mandatory data points in ESRS standards by 61%^[14], removed optional indicators and abandoned sector-specific standards^[15]. The so-called Wave 2 was postponed by two years (reporting from the 2027 financial year)^[16], and The CSDDD directive will cover only the largest groups^[17]—those with more than 5,000 employees and EUR 1.5 billion in turnover, effective from July 26, 2029. Member States will also have the option to exempt some Wave 1 companies^[18] below the new thresholds from reporting as early as 2026.

Rising CO₂ Prices and EU Raw Material Risks

Price pressure is rising on the EU ETS emission allowance market. Intraday EUA contracts reached EUR 93.80/t^[19], before falling to EUR 78.86/t on February 10^[20]. A consensus of ten analysts surveyed by Reuters indicates^[21], and Montel forecasts speak of EUR 92/t^[22]. EUA auction volumes in 2026 will be lower by 25–30% year on year^[23]; implementation of CBAM drives a structural shortage of allowances^[24]. The market assumes that the CO₂ ton price may reach about EUR 126/t^[25], and has already released USD 3.5 billion to mitigate impacts^[26] of the ETS2 system for transport and buildings, planned for 2027–2028.

Strategic risks also arise in critical raw materials^[27]. The European Court of Auditors, in a special February 4, 2026 report, evaluates^[28], that the European Union will not meet the targets set by the law by 2030^[29]. China controls about 60% of global critical raw materials production^[30] and 90% of refining capacity. For 10 key materials of the energy transition in the EU, practically no recycling exists^[31], and for analyzed raw materials, recycling rates are only 1–5%^[32]. They exceed the 65% import limit from a single country^[33] at the processing stage. The Court recommends introducing binding recycling targets for specific raw materials^[34], while The European Commission announces the establishment of the European Raw Materials Centre^[35] to manage stocks and reduce risks.

Polish Anti-Blackout Package and Weaker Signals

At the national level, a key decision was made by the Council of Ministers^[36]. On January 7, 2026, it adopted a draft amendment to the Energy Law (UC84)^[37], forming the core of the anti-blackout package. This is the largest reform in years of connection rules for sources to the grid and a direct response to the Iberian blackout of April 2025, which affected about 55 million people^[38] and generated losses of approximately EUR 4.5 billion^[39]. According to the update to the National Energy and Climate Plan, renewable energy share is set to rise to 51.6–53.2% by 2030^[40] from around 30% in 2024. Installed photovoltaic capacity is to reach 32.4 GW^[41], national energy storage has about 8 GWh of capacity^[42] and 2 GW of power. Flexible connection agreements are introduced^[43] and could unlock a wave of investments in renewables and energy storage^[44], while simultaneously eliminating speculative blocking of connection capacities^[45] noted for years by the sector and business organizations, including the Lewiatan Confederation^[46]. Experts point, however, to the lack of comprehensive solutions for the energy storage capacity market^[47].

Amid regulatory changes, signals intensify of a deepening climate crisis^[48] and a shift in climate policy burden towards adaptation costs. C3S/Copernicus recorded January 2026 as the fifth warmest^[49] in history, with a global average temperature of 12.95°C, which is 1.47°C above pre-industrial levels. At the same time, Europe experienced its coldest January since 2010^[50], while the southern hemisphere faced record heat and fires^[51]. In Ceduna, temperatures reached 49.5°C^[52]. Insurers report a sharp rise in damages and premiums^[53], while current economic models systematically underestimate real climate risks^[54]. This has direct consequences for financial regulators’ and pension funds’ decisions^[55]. The European Investment Bank is strengthening ETS2 shielding financing^[56], and The European Commission is developing cross-border renewable energy projects^[57]. All these factors contribute to the image of 2026 as a transitional year^[58]: easing and shifting reporting requirements on one hand, and tightening climate realities and transformation costs on the other.

Related posts:

• EU Taxonomy Consultations, First CBAM Price, and Energy Price Pressure — A Week in ESG
• ESG and Climate: Narrowed CSRD, CBAM Price Start, and New Wave of Green Financing
• CBAM, the Hamburg Declaration, and CSRD Adjustment: A Breakthrough Week in Global ESG
• ESG at a Crossroads: CBAM, Simplified Reporting, and Real Costs of the Climate Crisis