NZ ETS unit settings and annual regulatory updates 2025

Closes 29 Jun 2025

Managing NZ ETS auctions

There are 4 question that can be answered within this section.

You can read managing NZ ETS auctions and the questions either:

Read managing NZ ETS auctions - HTML format

Managing NZ ETS auctions

The Government auctions NZUs quarterly to NZ ETS participants. Possible outcomes for NZ ETS auctions include the following.

  • Auction fully clears: There are enough bids at or above the confidential reserve price (CRP) to account for the units available.8  Any bids below the CRP do not affect the auction result. If the CRP is not applied, all valid bids must be above the auction price floor established by the settings process. Units are allocated to the highest bidders first, but all units sell at the same clearing price.
  • Auction fully clears and cost containment reserve (CCR) triggered: As above, but with a CCR price triggered and additional volume made available.
  •  Auction partially clears: There are fewer bids than units available. All bids are at or above the CRP, so all bidders are successful.
  • Auction declines: There are fewer bids than units available. There is at least one bid below the reserve price, so the auction declines and no units are sold. An auction also declines if there are no bids at all.

If an auction declines, or partially clears, any unsold NZUs are rolled over to the next auction within the same calendar year. This ensures participants can access the full allocation of NZUs set by the annual NZ ETS cap for each calendar year. Unsold NZUs do not roll over into the next calendar year. However, these unsold units may affect decisions on unit limit settings in following years.

The objectives of the proposals in this section are to support the effective functioning of NZ ETS auctions.

8 The auction clearing price is the greater of either the confidential reserve price (CRP) or the auction floor price. The CRP functions to prevent the sale of units below prevailing secondary market prices. It can be different at each auction and is not revealed to the public. The auction floor price is set in regulation.

Manage rollover auction volumes within a calendar year

Currently, NZUs that do not sell at auctions accumulate into later auctions within the same calendar year. This can mean progressively larger auction volumes across a calendar year. Although this preserves the availability of auction volume throughout the year for NZ ETS participants, it increases the number of bids at or above the CRP9 needed for the auction to clear.

The problem: Bidding behaviour can affect auction results. In particular, bids below the CRP can cause auctions to decline. This can prevent NZ ETS participants from purchasing units, even when they are bidding above the CRP. The accumulation of unsold NZUs across the calendar year increases the implications of this risk. This is inconsistent with the policy objective of the auction mechanism.

Figure 1 illustrates how the accumulation of unsold NZUs within a calendar year can affect auction outcomes. Both scenarios have identical bidding behaviour. However, the latter, which includes previous unsold NZUs, fails to clear due to bids below the CRP.

9 The confidential reserve price functions to prevent the sale of units below prevailing secondary market prices. The confidential reserve price can be different at each auction and is not revealed to the public.

Figure 1: Example of impact of current auction rollover provisions for units within the same calendar year

A dark blue box showing auction volume of 5 million units. A vertical arrow shows 5 million bids above the confidential reserve price and 2 million bids below the confidential reserve price. In this scenario, the auction has cleared, and 5 million units are sold.          A dark blue box showing auction volume of 5million units sits on top a light blue box showing 5 million units that have been rolled over. The total is 10 million units for auction. A vertical arrow shows 5 million bids above the confidential reserve price and 2 million bids below the confidential reserve price. In this scenario, the auction has declined, and no units are sold.

Note: CRP = confidential reserve price.

Proposal: Amend regulations to change the way that rollover NZUs are treated at subsequent NZ ETS auctions in the calendar year. Options are outlined in table 7. The proposed changes would not affect the number of NZUs available, nor other aspects of the auction mechanism such as how the CRP functions.

Table 7: Options for managing rollover auction volumes

Option Description  Assumed impact 

No change 

Unsold units continue to roll over to the next auction. 

This can contribute to progressively larger auction volumes throughout the year, and bids below the CRP causing auctions to decline, as shown in figure 1.

Option 1: Sell unsold units if there is enough demand

Unsold units roll over, but are only sold if the current auction first clears its newly offered volume.

Bidders can still access the unsold units if there is enough demand. However, these additional units will not affect participant’s ability to first access the newly offered units.

Remaining unsold volume will not roll over into next the calendar year, the same as current provisions.

This approach maintains market stability by preventing a buildup of unsold units that could distort the outcomes of later auctions, while also ensuring the volume remains available to participants if there is demand.

Cost to the Crown to implement this change. However, enabling participants to better access units when there is sufficient demand would result in revenue from clearing those auction units to the Crown.

Participants may find accessing units in larger quantities via auction more convenient than the secondary market.

Option 2: Spread out unsold volumes across the year

Instead of rolling over all unsold units to the next single auction, this option spreads them evenly across the remaining auctions in that year.

May enable better access to NZUs throughout the year. Will not resolve the issue for the final auction of the year if no auctions clear during the year, because all units accumulate into the final auction.

Figure 2 is an example of how option 1 would work, using the same scenario as in figure 1. In it, 5 million units are sold.

a)    The auction operator first checks whether there are enough bids above auction clearing price to clear the ‘new’ auction volume of 5 million units. There is, so these units are sold, with the five millionth bid determining the sale price. This is the same outcome as the scenario in which there are no ‘rollover units’.

b)    The operator then calculates if the remaining bids are enough to clear the rollover volume. In the example, there are 1 million bids above the CRP and 2 million bids below it, so the rollover units fail to sell.

c)    In all, 5 million ‘new’ units sell and re-offered 5 million do not. These unsold units are rolled over to the next auction or are cancelled if it is the last auction for the calendar year.

Figure 2: Example of auction result under option 1

A dark blue box showing auction volume of 5 million units sits on top a light blue box showing 5 million units that have been rolled over. The total is 10 million units for auction. A vertical arrow shows 5 million bids above the confidential reserve price and 2 million bids below the confidential reserve price. In this scenario, the auction has partially cleared, and 5 million units are sold.

Note: CRP = confidential reserve price.

Other options include holding two additional auctions per year, at regular intervals, so NZ ETS participants can access NZUs that were not sold in previous auctions, or cancelling any unsold NZUs after an auction has failed to clear. However, we are not considering these options further because we do not consider they are viable. Holding two additional auctions would be administratively complex, and cancelling rollover NZUs would remove the ability of NZ ETS participants to access these NZUs.

8. Please rank the options in order of preference.
9. Is there any other change that you think we should consider?
10. Are there any unintended impacts or risks of the options that we have not identified? If so, what are they and how might they be managed?
Read managing NZ ETS auctions continued - HTML format

Amend the collateral window for NZ ETS auctions

To participate in the NZ ETS auction, bidders are required to provide collateral at least five working days before the auction.10 Since NZU auctions began in 2021, bidders have largely used cash as collateral, but Letters of Credit are also accepted. Collateral protects the Government against adverse price movement if a successful bidder refuses to or cannot settle their bid.

The problem: The NZ ETS does not pay interest on collateral that it holds. If the collateral is cash, the bidder loses the opportunity to earn interest on that money while it is held. 

Proposal: Reduce the window that collateral is held for, to reduce the potential for lost earnings for the bidder. Table 8 outlines options for this change.

10 Regulation 25, Climate Change (Auctions, Limits, and Price Controls for Units) Regulations 2020.&

Table 8: Options for amending the collateral window for NZ ETS auctions

Option Description  Assumed impact 
No change  Collateral must be provided at least five working days before the auction. Potential remains for a minimum of five working days’ lost earnings for the bidder. 
Option 1: Reduce the window to three working days  NZ ETS market participants would need to post collateral three working days before the auction. Reduces the potential for the bidder to lose earnings, compared with the current situation.
11. Which of the following options do you agree with?