On 9 December 2025, the European Parliament and the Council reached the provisional agreement to postpone the start of ETS2 by one year, the European emissions trading system extended to buildings and road transport. Official start date: 1 January 2028, no longer 2027 as set out in Directive (EU) 2023/959. For many Italian fleet managers the news arrived as “12 more months”. This is a partial and potentially expensive reading.
The one-year postponement does not modify the obligation to collect and verify emissions data, already operational since 2025 through the MRV system (Monitoring, Reporting, Verification). And it does not change the order of magnitude of the impact: for road transport, estimates point to 2-3 billion €/year of extra costs in Italy and +0.30-0.32 €/litre on the diesel price, equivalent to +20% on the current net price. Federtrasporti calculates 6,000 €/truck/year for a vehicle running 100,000 km, that is 120,000 €/year for a 20-vehicle fleet.
This article takes stock of the real ETS2 mechanisms, the expected costs for Italian fleets, the MRV obligation already in force, and the operational checklist to reach 1 January 2028 without surprises.
What ETS2 is and why it concerns those who don’t know ETS
The original ETS (EU ETS, since 2005) covers heavy industry and intra-EU aviation. ETS2 extends the “polluter pays” principle to two new sectors so far excluded: buildings (heating) and road transport of goods and passengers, excluding aviation and maritime transport already covered separately.
The mechanism is “upstream”: the price of CO2 is not paid directly by the haulage company at delivery, but by fuel suppliers (refineries, distributors) when fuel is released for consumption. Oil companies buy quotas to cover the emissions of the diesel sold and — like any upstream cost — pass the price downstream through the final pump price.
The EU-wide quota volume for 2028 will be calibrated on the average 2016-2018 emissions of the covered sectors, with a cap progressively decreasing to reach -42% by 2030 versus 2005. On the price of a single quota, ETS2 estimates range between 45 and 90 €/tonne of CO2 in the early years, with a soft cap of 45 € activated by the “price stability mechanism” if the curve rises too quickly.
The diesel impact (and the cost-per-kilometre impact)
A litre of burned diesel emits about 2.68 kg of CO2. At an ETS2 quota price of 60 €/tonne — the median estimate value — the additional fuel cost is 0.16 €/litre. At 80 €/tonne it rises to 0.21 €/litre; at 90 €/tonne it reaches 0.24 €/litre. Estimates by Federtrasporti and Confetra point to a realistic range of 0.30-0.32 €/litre considering margins and management charges of the mechanism passed downstream.
On a heavy vehicle burning 35,000 L/year (order of magnitude for 100,000 km at 35 L/100 km), the impact is:
- at 0.30 €/L extra: +10,500 €/year per vehicle (aligned with Federtrasporti’s 6,000 € estimate at lower mileage)
- for a 20-vehicle fleet: +210,000 €/year of fuel surcharge alone
- for a 50-vehicle fleet: +525,000 €/year
This adds to already-expensive diesel. Today (June 2026) self-service diesel runs between 1.98 and 2.07 €/L; in 2028 the base scenario (without further geopolitical shocks) is 2.28-2.40 €/L. For a third-party haulier working on multi-year contracts, this structurally changes the operating margin.
MRV obligations are already active since 2025
The crucial point many operators underestimate: postponing the payment mechanism to 2028 does not postpone the reporting obligations. Since 2025 fuel suppliers and a series of regulated entities have been required to:
- Monitor quantities of fuel released for consumption
- Report associated emissions according to standardised methodologies
- Get the data verified by an accredited verifier
For haulage companies this means two things. First: the suppliers from which they buy diesel (oil companies, tank operators, fuel card networks) are already gearing up and reporting systems will be operational when payment kicks in. Second — more important: if the company doesn’t already today have a punctual tracking system for its real consumption per vehicle and per mission, from 2028 it will pay a cost it cannot internally attribute.
This is the real reason why the “extra time” of the postponement should be used well: not to defer decisions, but to build the data infrastructure that allows control of CO2 cost from day 1.
What changes for those running an Italian fleet
The operational impact of ETS2 plays out on four levels.
Level 1 — Pricing of transport contracts
For those operating in third-party haulage, multi-year contracts signed today must include adjustment clauses for fiscal and regulatory shocks. A standard “ETS2 pass-through” clause must specify the formula for transferring CO2 cost to the principal, with an automatic trigger mechanism on threshold crossing. Without this clause, the risk stays entirely on the haulier.
For own-account, the extra cost goes directly into the cost per delivery or the cost per km of the logistics cost centre. Companies with thin operating margins (food & beverage, capillary distribution, parts) must assess the impact on the final price list.
Level 2 — Vehicle strategy
The operating cost differential between Diesel and low-carbon alternatives (HVO, BIO-CNG, electric, fuel cell) changes. At ETS2 regime, HVO from renewable sources — exempt or reduced under ETS2 based on origin certification — becomes competitive for many urban and regional applications, while for long-haul, electric starts having a payback below 7 years if you sum operating TCO, urban LEZ access and emissions bonuses.
The optimal fleet at 2028 is not the optimal fleet at 2026. Purchase decisions made today over a 7-10 year horizon must incorporate the ETS2 scenario in TCO. On the topic, see our analysis on managing a mixed diesel-electric fleet and the 5 fleet data points to analyse before going electric.
Level 3 — Kilometre optimisation
Every kilometre not driven is a kilo of CO2 not emitted and an ETS2 quota not bought. A fleet that today gains 12% fewer kilometres from route optimisation will, from 2028, gain 12% kilometres + 12% ETS2 cost avoided. The payback of optimisation projects compresses further.
The same applies to eco-driving and consumption reduction: a programme today worth 12% fuel saved is, from 2028, worth 12% fuel + 12% ETS2. For a 20-vehicle fleet this means raising annual saving from about 100 thousand € to about 130-140 thousand €.
Level 4 — CSRD reporting
For companies subject to CSRD (large enterprises from 2027 on the 2026 financial year, listed SMEs from 2028), the ETS2 cost must be reported in their Scope 1 and Scope 3 (depending on fleet type), with a level of detail requiring granular data per vehicle, route and mission. Our CSRD guide for fleets goes into requirement detail.
Three estimates of ETS2 costs for your fleet
To gauge the order of magnitude, here are three scenarios of additional annual cost, calculated on average 35 L/100 km consumption and ETS2 quota price at 60 €/t (central scenario):
| Fleet size | Total km/year | Diesel litres/year | Extra ETS2 cost (at 0.30 €/L) |
|---|---|---|---|
| 10 vehicles | 1,000,000 | 350,000 | +€105,000/year |
| 20 vehicles | 2,000,000 | 700,000 | +€210,000/year |
| 50 vehicles | 5,000,000 | 1,750,000 | +€525,000/year |
| 100 vehicles | 10,000,000 | 3,500,000 | +€1,050,000/year |
To these add indirect effects: lower demand from clients closing or reducing volumes due to expensive transport, possible price shocks on ETS2 quotas in the early months (market not yet liquid), variability in the downstream pass-through of cost by fuel suppliers.
Operational checklist: what to do in the 18 months left
From June 2026 to January 2028 there are 18 months. To be ready, these are the actions to close in priority order.
Month 1-3 (by September 2026):
- Map every fuel supplier and ask for visibility on their MRV compliance plan
- Calculate the expected ETS2 cost on existing multi-year contracts and identify those without an adjustment clause
- Open negotiations on “ETS2 pass-through” clauses with main principals
Month 4-9 (by March 2027):
- Implement a consumption tracking system per vehicle, mission and — if possible — per client, at minimum monthly granularity
- Start a route optimisation pilot if not already in place (ROI accelerated by the expected CO2 surcharge)
- Evaluate introducing HVO or B100 on urban routes where payback is already positive at ETS2 regime
Month 10-18 (by January 2028):
- Update internal pricing (for those billing per delivery) with the new CO2 cost
- Train the sales team on negotiating adjustment clauses
- Prepare the first ESG/CSRD report with the data collected, so you can show evidence to principals
The key point
ETS2 will arrive in 2028, not 2027, but it will not disappear. For Italian fleets the additional cost will be structural and will add to an already heavy diesel scenario. The one-year postponement is a tactical opportunity — used well, it allows arriving at 2028 with data, contracts and fleet in order; used poorly, it postpones decisions that will become urgent without room for manoeuvre.
The three actions producing the highest payback are the same ones a fleet manager should already be doing today: measure real consumption per vehicle and mission, optimise routes with a VRP system and negotiate pass-through clauses in new contracts. On the analysis of fleet data as a decision tool, see the 7 KPIs every fleet manager should monitor.
If you want to understand how your fleet will be exposed in 2028 and which levers to activate to reduce risk, talk to our team: an analysis of consumption data from the last semester is enough to build the ETS2 projection and identify priorities.