Event:16 September | Carbon Removal Policy Summit
Internal Carbon Fees and Shadow PricingVoluntary and Normative Drivers

INTERNAL CARBON FEES AND SHADOW PRICING

Lever last updated: 14 September 2026

An internal price on emissions that shapes an organisation's own investment decisions.

Cost

Very low to High

The organisation pays for emissions data, budget administration and checks. Shadow pricing mainly uses staff time; a fee that finances substantial climate action also incurs project or removal-purchasing costs. Transfers between its departments are not counted twice.

Complexity

Very low to Medium

Shadow pricing can be added to existing investment appraisal. An internal fee also requires rules for charging departments, reliable emissions data, approved transfers and procedures for spending the money on eligible climate activities.

Timeline

Very short to Short

An established finance team may apply a shadow price to investment decisions within a year. Introducing a fee, collecting data and beginning the associated climate spending may take one to two years.

Integrity, Transparency & MRV

1–2

Innovation & Cost Reduction

1–2

Social & Environmental Safeguards

1–2

Energy, Transport & Storage Infrastructure

N/A

Inputs & Capacity

N/A

Demand Formation

1–4

Bankability and Cost of Capital

1–3

Policy Architecture & Coordination

1–2

Overview

An internal carbon price makes an organisation's emissions matter in its own investment and budget decisions. Management can use a shadow price, adding an assumed emissions cost when comparing options without collecting money. Alternatively, an internal carbon fee charges departments or business units according to their emissions and transfers money into a climate budget. The first approach can make managers consider lower-emission choices and the cost of future removal needs; the second can also finance removal purchases when management allocates the proceeds for that purpose. Finance teams must apply the rule in actual approvals or budgets for it to influence behaviour.

Key Considerations

Management should choose which emissions and decisions the price covers, how it changes over time and whether its purpose is to guide choices, fund action or both. The price used to compare investments need not equal the price of removals; a funded purchasing plan must separately account for the cost and quality of eligible supply. Finance should embed the rule in budgets and approvals. For a fee, allocation rules should cover environmental and social safeguards, delivery risk and how commitments remain funded if emissions fall. Including suppliers' or product-use emissions can increase relevance but requires more data and clearer responsibility.

Opportunities

A price applied in real decisions can make lower-emission options more attractive and expose the future cost of residual emissions. A fee can create a recurring funding route for removal procurement and make departments or business units accountable for contributing to it. A published escalation schedule can improve planning for both internal teams and suppliers where it supports multi-year contracts. Shadow pricing offers a lighter route to better appraisal, but should not be described as generating a removal budget or guaranteeing purchases.

Risks

A token price or a model that decision-makers routinely ignore can have little effect. Paying a fee may be treated as permission to continue avoidable emissions, while weak procurement can spend the proceeds on unsuitable credits. Revenue may shrink as emissions fall or fluctuate with business activity, leaving long-term contracts underfunded. Internal transfers can also be mistaken for new spending: the relevant external costs arise when the organisation funds activities or purchases removals.

Monitoring and Evaluation

Finance and internal audit should examine which investments and purchases changed because of the price, alongside covered emissions and fee receipts. For funded programmes, procurement teams should report expenditure, contracted quantities, delivered removals and retired credits separately. Management should use these results and updated reduction and removal costs to revise the rate, spending allocation or exemptions when the mechanism is no longer influencing decisions or adequately funding commitments.

Stakeholder Engagement

Finance and sustainability teams should jointly design the mechanism, with the organisation's leadership or governing body approving its use under the applicable budget rules. Departments and business units need clear emissions data and budget responsibilities. Procurement and technical experts assess removal quality and delivery exposure; internal audit tests whether the price and spending rules are followed rather than merely disclosed.

Governance Levels

InternationalSupranationalNationalRegional / StateCity / MunicipalCorporate / IndustryPhilanthropy

Each level refers to an organisation applying the price to decisions it controls. An international agency or EU institution could price its own travel, buildings and purchasing; a national government, regional administration or municipal council could do so within its own departments and budgets. Company boards and foundation trustees can approve equivalent internal rules. A fee additionally requires permission to transfer departmental funds and spend the receipts. The authority comes from managing those budgets. It does not mean that the UN, EU or a government imposes this internal price on everyone in its jurisdiction.

Implementation Strategies

  • Management should define the purpose, emissions covered and price trajectory before choosing the initial rate. Testing different prices can show whether they materially change investment choices and whether expected fee receipts would cover planned climate spending.

  • Finance should embed the price in capital and operating approvals, procurement and departmental or business-unit budgets. Internal audit should check that decision-makers actually apply it and explain any exemptions, rather than merely recording that the organisation has an internal price.

  • For a fee, the responsible budget authority should approve the charge and permitted uses of the proceeds. Management should establish spending rules and a procurement plan covering quality, safeguards, delivery and retirement of removal credits. Expected receipts and reserves should match the timing of contractual payments, including scenarios in which emissions and fee income decline.

  • The organisation should review changed decisions, emissions and spending annually. It should adjust the rate or coverage when the price stops influencing behaviour and report fee receipts separately from expenditure, future contracts and removals already delivered.

Case Studies

Microsoft's internal carbon fee

Microsoft, a technology company, introduced an internal carbon fee in 2012, initially covering direct operations, purchased electricity and business air travel. In 2020 it extended the charge to its business groups' wider value-chain emissions. Each year the company aggregates emissions data and charges the relevant groups, creating a budget consequence for managers and funding for carbon reduction and removal efforts. Its 2022 account describes further fee increases and redesign to reflect the costs of reducing emissions. The mechanism connects everyday business decisions with the resources needed to implement the company's climate commitments. For removals, its practical value is a funding route that procurement teams can use; the fee itself does not determine which projects are selected or what they deliver.

Swiss Re's Carbon Steering Levy

Swiss Re is a reinsurer, providing insurance protection to other insurers. Its CO₂NetZero programme applies a real Carbon Steering Levy to covered operational emissions, reported at USD 156 per tonne for 2026, following USD 100 in 2021 and a planned increase to USD 200 by 2030. Business units bear the charge, which is intended to influence behaviour and fund carbon certificates. The planned escalation makes future emissions increasingly costly within internal budgets, giving managers a forward signal when considering operational choices. The purchasing programme separately determines which certificates are bought, including the transition toward removals. The example demonstrates how an internal fee can combine an incentive to reduce emissions with a continuing source of climate-procurement funding.

Unilever's shadow carbon price

Unilever, the consumer-goods company, describes a shadow carbon price of EUR 70 per tonne of CO₂-equivalent in its 2024 Climate Transition Action Plan. It reviews the price annually and uses it to recalculate capital-investment cases with an assumed cost for emissions. Managers can then see whether an option remains attractive once those costs are included, although no money is collected through that calculation. Unilever also states that its operational emissions-reduction targets are a more significant decision factor because many of its operations are not especially energy-intensive. This detail shows why applying a price is insufficient evidence that it drives the final choice. Any removal-purchasing budget still requires an allocation separate from the shadow-price calculation.

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©2026 Alexander Mäkelä and Carbon Gap.
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