Carbon Compliance Through Direct Investment Credits
Alberta Regulation 270/2025 amends the Technology Innovation and Emissions Reduction Regulation to expand compliance flexibility under the Emissions Management and Climate Resilience Act, most notably through the introduction of a new investment credit framework. The amendments are intended to encourage direct private investment in emissions-reducing projects in Alberta while increasing oversight, verification standards, and administrative clarity within the Technology Innovation and Emissions Reduction (TIER) system.
A central feature of the Regulation is the creation of investment credits, which allow regulated facilities to convert eligible monetary investments in approved emissions-reduction projects into compliance credits. These credits may be used to reduce a facility’s net emissions beginning in the 2026 compliance year. An eligible investment must be made by the person responsible for a regulated facility, meet detailed criteria set out in the newly referenced Standard for Direct Investment, and relate to projects located in Alberta. Investments made before January 1, 2025, projects receiving government funding, investments subject to cost containment designations, or amounts recoverable through tax credits are excluded. One investment credit represents one tonne of CO₂e and is calculated based on the ratio of eligible investment dollars to the applicable fund credit amount for the year.
The Regulation establishes rigorous governance for the issuance and use of investment credits. Facilities must submit audited investment statements by June 30 of the year following the investment, prepared and audited in accordance with prescribed standards by qualified accounting firms. Credits may only be used once, by the original holder, within a five-year window following the investment year, and only for one compliance year. Investment credits must be held by the responsible person as of the compliance report submission date to be eligible for use.
In addition to direct compliance use, the Regulation introduces a mechanism to reactivate previously used emission offsets, sequestration credits, or emission performance credits. If a facility makes a qualifying investment and submits an audited investment statement by March 31 of the following year, it may elect to use associated investment credits to reactivate credits used for compliance in any of the three immediately preceding compliance years, provided those years are no earlier than 2025. Reactivated credits are deemed unused and are subject to the same rules that applied prior to their original use.
The amendments also revise how net emissions are calculated by formally adding investment credits to the existing formula alongside offsets, performance credits, sequestration credits, and fund credits. Detailed restrictions are added to prevent double counting and to clarify the timing and ownership requirements for all credit types. Administrative language is updated throughout the Regulation to improve consistency and precision, including changes to terminology, deadlines, and application processes.
Alberta (270/2025) January 13, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.
