On 7 April 2026 the European Commission published the first quarterly CBAM certificate price at €75.36 per tonne of CO2, putting a real, paid carbon price on imported steel, cement, aluminium, fertiliser, hydrogen and electricity for the first time and beginning a phase-in that runs from 2.5% in 2026 to 100% by 2034.
At the same moment, the Omnibus I package, formally adopted by the Council on 24 February 2026, raised CSRD thresholds to over €450 million in turnover and 1,000 employees, removing roughly 80% of previously in-scope companies and pushing Wave 2 and Wave 3 reporters back by two years.
Across the Atlantic, the One Big Beautiful Bill Act signed in July 2025 reset most of the IRA framework that European exporters and US-revenue scale-ups had built their unit economics around: the 45V hydrogen credit window now closes in 2027, which Energy Ventures Analysis estimates disqualifies around 95% of announced US hydrogen capacity, and the DOE Office of Clean Energy Demonstrations cancelled $3.7 billion of awards on 30 May 2025, including Sublime Systems, Brimstone and several other industrial-decarbonisation programmes.
Elemental Impact's June 2025 Climate Week survey found 69% of Climate-tech investors now expect first-of-a-kind capital to shrink further through 2026, with over half openly pivoting toward what the survey called policy-proof business models. The non-dilutive part of the capital stack has not disappeared, but it has narrowed and split along Atlantic lines, and the companies most likely to clear the next eighteen months are the ones whose plan still works if the policy environment moves another two notches before financial close.