It is important to consider recommendations on unit limits and price controls as a package. Our proposed options on unit limits do not include changes to price control settings, beyond adjustment for inflation.15
15 The only additional possible change would be if under option 2 or option 3 the Government chose to shift the 2027 volumes to later years (see Aligning the timing of supply to market needs). In that scenario, cost containment reserve volumes for 2027 would be set to zero.
The role of price controls
Auction price controls provide the Government with additional tools to manage the supply of units. The settings do not set the NZU price but can influence that price by withholding units from, or adding units to, the market.
Price controls act as a safety valve to prevent the auction price from going too low (which could lower the secondary market NZU price below what is needed to meet domestic emissions reduction targets) or too high (unnecessarily impacting on the cost of living and the economy). They also signal the price pathway likely to be needed to meet future targets. Price controls apply only to government auctions and not the secondary market.
Auction price controls include:
- the auction price floor16 – the Government will not sell units at auction below this price and the confidential reserve price17
- cost containment reserve (CCR) trigger prices – additional NZUs will be released if an auction’s interim clearing price reaches or exceeds one or both of these prices
- CCR volumes – the number of NZUs that will be released if the trigger price is reached.
The auction price floor stays at a prescribed value for each auction within the year. It prevents additional units from being sold if the market is so well supplied that businesses are not willing to pay a price aligned with domestic emissions reduction targets.
The CCR exists to manage the risk from shocks and unforeseen events that may result in extremely high prices in the ETS. It functions by releasing more NZUs into an auction where prescribed prices have been met. In 2023, the Government adopted the Commission’s recommended two-tier design for the CCR. This means there are two trigger prices – each with its own CCR.
The auction price floor and CCR trigger prices should, together, set out a price corridor that allows units to enter the market at prices that accord with New Zealand’s domestic emissions reduction targets.
16 In its advice, the Commission refers to the auction price floor as the auction reserve price.
17 The confidential reserve price functions to prevent the sale of units at a price materially below prevailing secondary market prices. It can be different at each auction and is not revealed to the public. This price is not set alongside other ETS settings and is not being consulted on.
Auction price floor and CCR trigger prices
The Commission has concluded that the auction price floor and CCR trigger prices remain fit for purpose. It recommended that existing levels remain unchanged (apart from routine inflation adjustments to figures from 2029 onwards). It also recommended extending both to 2031, based on the existing 3 percent annual growth rate.
Auction price floor
The evidence in the Commission’s 2025 advice suggested that prices around or above the current auction price floor are needed to support emissions reductions necessary to meet EB2 and EB3. The Commission has highlighted that this remains relevant and has not sufficiently changed. The Commission recommends extending the price floor by one year, based on the existing 3 percent annual growth rate and adjusting for inflation.
We agree with the assessment that the current price floor remains fit for purpose. Although current secondary market prices are below the current auction price floor, this could be a signal that the market is currently oversupplied. The auction price floor helps limit supply until the oversupply is addressed. Ministry modelling suggests that pricing is likely to return to above the auction price floor within the settings period, because the auction volumes are expected to be needed alongside industrial allocation, stockpile, and forestry units to meet compliance demand.18 Maintaining the auction price floor will also support the Government’s key objectives of supporting confidence in the ETS and encouraging investment in decarbonisation.
18 For more detail, see Implications for market dynamics and emissions budgets.
CCR trigger prices
The Commission reiterated its 2025 findings. Specifically, that there is a risk that trigger prices may be too low to allow for the high NZU prices needed to meet EB3 through additional gross emissions (if afforestation follows the trajectory projected in ERP2). However, additional afforestation in the next few years could help meet EB3 at a relatively lower price. The key uncertainties identified in the Commission’s 2025 advice have not been resolved, and it therefore still considers it too early to tell whether the CCR levels need to be increased. It once again advised maintaining and extending current CCR trigger prices (adjusted for inflation) until it is clearer whether current trigger prices are too low. We agree with the Commission’s findings.
The Commission also recommended that, if there is no ETS settings update in 2027 because of a shift to biennial ETS settings decisions, the Government should consider adding a temporary lower CCR tier to mitigate the risk of a shortfall in 2028. As explained above, we have not considered this recommendation but may explore it in future.
Below we outline potential adjustments to the auction price floor and CCR trigger price levels for inflation and extended to 2031. In our view, the rationale for maintaining current price controls holds for all unit limits options.
We seek your feedback on this approach.
Cost containment volumes
The CCR volumes need to be large enough for the CCR to perform its function of bringing down the auction price when it gets too high. Where prices are so high, there is a risk that the higher cost will be passed on to consumers, potentially putting pressure on household budgets.
In its 2026 advice, the Commission recommended maintaining CCR volumes for 2027–30, plus an extension to 2031. It noted that there has been no new evidence suggesting existing CCR volumes are inappropriate, and that retaining existing volumes would support regulatory predictability and remain in accordance with EB2 and EB3.
As with last year, there is no indication that changes to CCR volumes are necessary. We consider the current volumes sufficient for the CCR to perform its role, without risking accordance with emissions budgets if the CCR is triggered. This applies for all unit limits options.
Because the existing CCR volumes were based on a surplus estimate, which is intended to be drawn down by 2030, there is no existing volume to use for 2031. For 2031, the Commission proposes a volume based on the declining trajectory of the volumes currently in regulation. We agree with the Commission’s recommendation.
Summary of price control settings
Table 4 shows the proposed price control settings for all options.
Table 4: Proposed price control settings for the next five years, 2027–31
| - |
2027 |
2028 |
2029 |
2030 |
2031 (new) |
| Auction price floor |
$75 |
$78 |
$83 |
$88 |
$92 |
| CCR tier 1 |
$213 |
$224 |
$239 |
$251 |
$264 |
| CCR tier 2 |
$267 |
$289 |
$298 |
$313 |
$328 |
| Tier 1 volume (million NZUs)* |
2.1 |
1.9 |
1.7 |
1.4 |
1.2 |
| Tier 2 volume (million NZUs)* |
3.8 |
3.4 |
3.0 |
2.5 |
2.3 |
| Total CCR volume (million NZUs)* |
5.9 |
5.3 |
4.7 |
3.9 |
3.5 |
*If, under option 2 or option 3, the Government chose to shift the 2027 volumes to later years, tier 1, tier 2 and total CCR volumes for 2027 would be 0.