The federal government has updated the headline price trajectory for industrial carbon pricing systems assessed under the federal carbon pricing benchmark. As of May 15, 2026, the headline price trajectory per tonne of CO₂e emissions for industrial carbon pricing systems is as follows: The updated trajectory is lower than the previous federal benchmark pathway through 2030, and extends the headline trajectory to 2040. A full updated federal benchmark is expected to be published later in 2026. The federal government has stated that the updated trajectory takes into account feedback from provinces, territories, industry, and other stakeholders, and is intended to provide longer-term certainty to support major decarbonization projects. The updated trajectory was announced days after the Canada-Alberta MOU Implementation Agreement, which applies the same trajectory to Alberta’s Technology Innovation and Emissions Reduction (TIER) system and includes related commitments on annual benchmark stringency rates, a regulated minimum transfer price for TIER credits (i.e., a price floor) beginning in 2030, limits on direct investment credits, and carbon contracts for difference for eligible emissions-reduction investments. The benchmark announcement does not, by itself, amend the excess emissions charge under the federal output-based pricing system (OBPS), which is set out in Schedule 4 to the Greenhouse Gas Pollution Pricing Act. We anticipate that, if the federal OBPS charge is to be aligned with the updated trajectory, further implementation would follow, including through an Order-in-Council amending Schedule 4. For further information or to discuss the contents of this bulletin, please contact Lisa DeMarco at lisa@resilientllp.com or Jonathan McGillivray at jonathan@resilientllp.com. Image: CC 4.0 Joli Rumi