In May 2026, The Receipts documented the $103-billion fiscal commitment flowing through Canada’s clean economy investment tax credits and the companies positioned to receive it. That piece mapped where the money goes. This one examines what happens when a government tries to take it back.
In every previous Canadian subsidy program, the exit strategy was simple. A future government cancels the auto bailout and exposure stops. It lowers the film credit rate and costs go down. It tightens agricultural eligibility and savings are realized. Canada’s carbon capture architecture works differently. Buried inside the framework are binding contracts that guarantee companies a carbon price floor. If governments weaken the carbon pricing regime, public payments increase. The mechanism does not require a change in government to activate. On June 30, 2026, Prime Minister Mark Carney described the previous government’s climate plan as “well-intentioned” but “not sustainable over the long term.” [1] His government has already begun moving in the direction that tests these contracts.
The Eight Channels
Canada’s taxpayer commitment to carbon capture is not a single program. It is distributed across eight distinct instruments, administered by different entities, backed by different legal mechanisms, and disclosed in separate reports. No government publication aggregates them.
Channel 1: The federal CCUS Investment Tax Credit. A refundable tax credit covering 50 percent of eligible carbon capture equipment costs and 37.5 percent of transportation and storage. “Refundable” means that even if a company owes no tax, the government writes a cheque. The PBO projects this credit alone will cost $12.4 billion through 2035 and $16 billion through its 2041 phase-out. [2] Bill C-15, which received Royal Assent on March 26, 2026, extended full credit rates by five years through 2035. [3] The April 2026 Spring Economic Statement expanded eligibility further by making enhanced oil recovery projects eligible at half the standard rates: 25 percent for non-DAC capture equipment and 18.75 percent for transportation, storage, and use equipment. [4] No updated cost projection has been published since either expansion. The credit is demand-driven: there is no legislative cap on total claims.
Channel 2: Alberta’s Carbon Capture Incentive Program (ACCIP). A 12 percent provincial capital cost grant that stacks on top of the federal ITC. Alberta projects the program will provide $3.2 to $5.3 billion from 2024 through 2035. [5] Combined with the federal credit, the documented public share of eligible CCS project capital costs reaches 62 percent before a project generates any revenue. However, the ACCIP has not launched. It is explicitly contingent on federal CCUS tax legislation being finalized. One of the eight channels through which billions in projected commitments flow does not yet formally exist.
Channel 3: The Canada Growth Fund. A $15-billion arm’s-length federal investment fund managed by the Public Sector Pension Investment Board (PSP Investments). Up to $7 billion of its capital is earmarked for carbon contracts for difference and carbon credit offtake agreements. As of May 2026, the CGF reports 23 transactions across 21 portfolio companies and projects, committing approximately $5.29 billion across six provinces. [6]
Channel 4: Carbon Contracts for Difference (CCfDs). These are binding contracts, not legislation, where the CGF guarantees a company a fixed carbon price floor. If the market price for carbon credits drops below the contracted strike price, the CGF pays the difference. Signed CCfD and offtake agreements include Entropy Inc. ($200 million investment plus up to 9 million tonnes of carbon credits over 15 years at an initial price of $86.50 per tonne, representing a maximum contractual exposure of approximately $778 million before escalation, though the initial Glacier Phase 2 allocation covers roughly 2.8 million tonnes or $242 million of that total), Varme Energy (up to 3 million tonnes at an initial price of $85 per tonne over 15 years, approximately $255 million before escalation), the City of Markham (more than 177,000 tonnes over 10 years at an initial $100 per tonne, approximately $18 million before escalation), and Strathcona Resources (a 50/50 capital partnership of up to $2 billion for CCS at thermal oil sands facilities). [7][8][9][10] Aggregate signed carbon credit liability across the first three deals totals approximately $1.05 billion. Budget 2024 explored a government backstop of the CGF’s CCfD liabilities, which would place taxpayers behind the fund’s contractual obligations. That backstop has not been formalized but remains under consideration. [11]
Channel 5: Carbon credit offtake agreements. Distinct from CCfDs in structure but similar in effect: the CGF commits to purchasing a fixed volume of carbon credits at a fixed price for terms of 10 to 15 years, regardless of the prevailing market price. These are 15-year purchase commitments that survive changes in government, changes in policy, and changes in market conditions.
Channel 6: Alberta legacy CCS spending. Alberta has spent approximately $970 million on carbon capture to date. Shell’s Quest CCS project received $745 million from Alberta and $120 million from the federal government against a total cost of $1.35 billion, making it 64 percent publicly subsidized. [12] The Alberta Carbon Trunk Line (ACTL) received $223 million from Alberta (mostly a repayable loan) and $96 million in federal funding. [13]
Channel 7: Alberta’s perpetual liability transfer. Under Section 121 of the Alberta Mines and Minerals Act, once a CCS storage site receives a closure certificate, the Crown assumes ownership of the stored CO₂ and all obligations of the lessee, including indemnification against liability for damages in tort. [14] Operators pay into a Post-Closure Stewardship Fund during operations. No public report discloses the fund’s current balance. No independent assessment estimates the total long-term monitoring and remediation liability the Crown is assuming. No closure certificate has been issued for any Alberta CCS project to date. Both operational sites (Quest and ACTL) are still active. The province’s ultimate fiscal exposure through this channel is real, legally defined, and entirely unquantified in public sources.
Channel 8: Potential operating cost subsidies and royalty adjustments. In January 2023, the Pathways Alliance (now the Oil Sands Alliance) privately requested Ottawa cover 50 percent of CCS operating costs, as reported by The Narwhal. [15] No public response has been issued. At full project scale of approximately 14 megatonnes per year, a 50 percent operating subsidy would represent roughly $350 to $700 million annually, depending on realized capture costs. Separately, the Globe and Mail reported in late June 2026 that oil sands executives may seek royalty deferrals from Alberta as part of the Pathways financing negotiation. [16] Neither request has been confirmed by any government. Both remain under negotiation or speculative. Oil sands royalties were approximately $17 billion in the most recent fiscal year, representing Alberta’s single largest revenue source.
That is the complete architecture. The PBO reports the $103-billion ITC total. The CGF reports its portfolio. Alberta reports the ACCIP parameters. The CCfD liabilities sit in the CGF’s books. The perpetual Crown liability has no published estimate. The operating cost request has no published response. No government document, at any level, aggregates these eight channels into a single number. [17]
How the Return Model Works
A carbon capture project in Canada does not have one revenue stream. It has up to five, and nearly all of them are created or guaranteed by government.
The first layer is the capital subsidy. The federal CCUS ITC returns 50 percent of eligible capture equipment costs. Alberta’s ACCIP returns another 12 percent. Combined, 62 percent of capital cost is returned to the project before it generates a dollar of operating revenue. Because the federal credit is refundable, the return is a direct government payment, not a tax offset.
The second layer is carbon credit revenue. Each tonne of CO₂ captured and permanently stored generates a carbon credit under Alberta’s Technology Innovation and Emissions Reduction (TIER) system. These credits can be sold to other large emitters who need them for compliance. This is the operating revenue stream.
The third layer is the CGF offtake guarantee. The CGF commits to purchasing carbon credits at a fixed price for 15 years. If the market price drops below the contracted rate, the CGF pays the difference. This eliminates downside price risk on the carbon credit revenue stream. The investor receives a guaranteed minimum revenue floor, funded by taxpayers.
The fourth layer is avoided compliance costs. For oil sands producers who are both the emitters and the CCS operators, capturing their own emissions reduces what they would owe under the carbon price. This is not a cash inflow but a reduction in regulatory liability that improves the company’s balance sheet.
The Entropy Inc. transaction illustrates how these layers stack. Brookfield Asset Management invested $300 million through its Global Transition Fund I. [18] The Canada Growth Fund then invested $200 million alongside Brookfield, plus committed to purchasing up to $778 million in carbon credits over 15 years at $86.50 per tonne. [7] The CGF’s funding draws proceed “in tandem” with Brookfield’s, using similar terms. The public fund and the private fund de-risk each other in lockstep. Entropy builds the CCS infrastructure, collects the ITC refund on capital costs, sells carbon credits at a guaranteed floor price to the CGF, and the returns flow back to Brookfield’s fund.
The Strathcona Resources partnership makes the structure even more explicit. The CGF committed up to $2 billion alongside Strathcona in a 50/50 capital split for CCS at thermal oil sands facilities. Strathcona builds, owns, and operates all infrastructure. Strathcona receives all the investment tax credits. The CGF takes half the capital risk but captures none of the tax credits; it expects a targeted return from project cash flows based on actual captured volumes, operating costs, and a fixed carbon price guaranteed by Strathcona. [10]
Who are the institutional investors in these funds? Canadian pension funds. The Caisse de dépôt et placement du Québec, Ontario Teachers’ Pension Plan, and Temasek are among the investors in Brookfield’s Global Transition Funds. PSP Investments manages the CGF itself. [19] The Canada Pension Plan Investment Board provided equity for the ACTL pipeline. The chain runs in a circle: Canadian taxpayers fund the de-risking through ITCs, grants, and CGF equity; Canadian pensioners capture the returns through the transition funds; Brookfield’s fund vehicles, registered in Bermuda, sit in the middle.
The full list of beneficiary companies, including the five Oil Sands Alliance members and the 18 projects that had filed for CCUS and clean hydrogen ITC claims as of January 2026, was documented in The Transfer. The additional finding here: no full engineering, procurement, and construction (EPC) contract has been awarded for the Pathways CCS project. Wood plc holds a $10-million engineering and design contract for the CO₂ pipeline. [20] No final investment decision has been made. The subsidy architecture, the return model, and the contractual guarantees are all in place for a project that has not been approved to build.
The Mechanism That Only Turns One Way
The carbon contract for difference is the structural feature that separates this architecture from every previous Canadian subsidy program. Understanding how it works requires understanding what happens when a government changes course.
When the federal government bailed out the auto sector in 2009 for $13.7 billion, the exposure was bounded. [21] A future government could have cancelled the program, and the obligation would have stopped growing. When film tax credits prove too generous, a government lowers the rate and costs decrease. When agricultural support programs no longer serve their purpose, a government tightens eligibility and savings are realized. In each case, the government retains the ability to reduce fiscal exposure by changing the policy. That is the normal relationship between policy and cost.
Carbon contracts for difference invert this relationship. The government enters a binding contract guaranteeing a company a specific carbon price for a specific term. If the market price stays above the guaranteed floor, the government may pay nothing or may even receive payments. If the market price falls below the floor, the government pays the difference. And here is the critical mechanism: the market price of carbon is a function of government policy. If a government weakens carbon pricing, eliminates the carbon levy, or softens compliance requirements, the market price of carbon drops. The gap between the market price and the contracted floor widens. Government payments increase.
The Canada-Alberta Implementation Agreement, signed May 15, 2026, makes this explicit. The agreement provides that should each level of government fail to maintain their commitments or repeal their respective climate policies, each would assume sole liability for the contracts. [22] This is not a penalty clause triggered by breach. It is the contract operating as designed. The CCfD was built to make policy retreat expensive. That is its stated purpose.
Long-term procurement contracts have created expensive exit conditions for Canadian governments before. Ontario’s Feed-in Tariff contracts under the Green Energy Act locked in above-market electricity prices for decades, and cancellation proved costly. But the CCfD mechanism is structurally distinct: the policy variable the government controls, the carbon price, is the same variable that determines the contractual payment. Weakening the policy does not merely leave the contract in place at its original cost. It increases what the contract costs, through a formula tied to the policy signal itself. We have not identified a close Canadian fiscal-policy analogue in which the act of weakening a policy directly increases public contractual payments under a formula tied to that same policy variable. The $103-billion ITC commitment is large, but it is legislative: a future Parliament could prospectively repeal the credit for new claims. The ACCIP is a provincial program that could be cancelled. Legacy CCS spending is sunk cost. The CCfDs are contracts that activate when the policy shifts.
The maximum annual payout exposure on currently signed CCfD and offtake agreements, if the carbon price fell to zero, would be approximately $70 million per year across the Entropy, Varme, and Markham deals. [7][8][9] That figure is modest against the broader commitment. But the CGF has $7 billion earmarked for these instruments. As the portfolio grows, so does the aggregate contractual liability, and so does the fiscal consequence of any future policy retreat.
Already in Motion
The scenario the CCfDs were designed to protect against is not a hypothetical future government. It is the current one.
The direct fiscal trigger for CCfD payments runs through Alberta’s TIER industrial carbon market, the federal industrial-pricing backstop, and the commitments embedded in the Canada-Alberta Implementation Agreement. Since taking office, Prime Minister Carney’s government has slowed the industrial carbon pricing trajectory through the Alberta agreement, directly affecting the market against which CCfD strike prices are measured. It has also made enhanced oil recovery projects eligible for the CCUS ITC at half the standard rates, widening the pool of claimants for a credit with no cap on total cost. [4]
Other policy shifts are adjacent rather than direct. Scrapping the consumer carbon price does not mechanically alter the TIER industrial credit price. Scrapping the proposed oil and gas emissions cap, expanding LNG exports, and backing a new West Coast pipeline are evidence of a broader policy posture, not automatic CCfD trigger events. But they are relevant context: the Canada-Alberta Implementation Agreement states that if either government fails to maintain its climate commitments, it assumes sole liability for the CCfD contracts. [22] The aggregate direction, across both direct and adjacent policy changes, moves away from the climate-policy trajectory that was in place when the CCfD terms were set.
On June 30, in his second “Forward Guidance” video, Carney stated that the climate plan he inherited was “well-intentioned and well-suited for the times in which it was designed,” but that “the certainties of the world of 2015 are long gone.” He acknowledged that “our emissions will be higher in the next few years” than projected under the previous plan. [1] Two days later, on July 2, his government signed a memorandum of understanding with the Oil Sands Alliance and Alberta for a new one-million-barrel-per-day pipeline to the West Coast, with the Pathways CCS project positioned as a linked commitment. [23]
This article does not allege that the government intends to trigger CCfD payments. It does not allege corruption, conflict of interest, or bad faith. It documents that the policy direction announced by the current government is structurally in tension with the contractual obligations signed by the same government. The mechanism does not require intent to function. It operates automatically, based on the relationship between the policy-determined market price and the contractually guaranteed floor price. If the distance between those two numbers continues to grow, the fiscal consequence follows from the contract itself.
The Cost of Compliance vs. the Cost of the Architecture
The Transfer documented who benefits from this architecture and how much they report in quarterly profits. This section asks a different question: does the scale of the architecture match the scale of the problem it was built to solve?
The Canadian Climate Institute has estimated that oil sands producers would pay less than 50 cents per barrel by 2030 under a $130-per-tonne carbon credit price. [24] That is less than one percent of the value of a barrel of oil. It is, as the Institute noted, comparable to the price of a Timbit. The compliance cost the architecture was built to address is, by the government’s own advisory body’s analysis, negligible relative to the industry’s revenue.
The architecture built to support that compliance, by contrast, is the largest fiscal commitment to a single industrial technology in Canadian history. End-to-end CCS costs are estimated at $120 to $326 per tonne of CO₂ abated, according to European Union estimates. [25] Renewable energy alternatives abate CO₂ at under $50 per tonne, and in many cases under $20 per tonne, according to the International Energy Agency. [26] The public is funding the most expensive abatement pathway available while the compliance cost it offsets amounts to less than a dollar per barrel.
Capital Power’s Genesee CCS project provides a documented precedent. In May 2024, the company cancelled the $2.4-billion project even with both federal ITC and provincial ACCIP support committed, calling it “not economically feasible.” [27] If a CCS project cannot proceed with 62 percent of its capital costs covered by public money, that documents a gap between what the subsidy architecture promises and what the technology currently delivers.
The return loop closes through pension funds. Canadian pension funds, including the Caisse de dépôt, Ontario Teachers’, and PSP Investments, are investors in the transition funds and vehicles that finance CCS projects. [19] Those projects are de-risked by taxpayer-funded ITCs, taxpayer-backed CGF equity, and taxpayer-guaranteed CCfD floor prices. The returns flow back through the fund vehicles to the pension plans that serve Canadian workers. Canadians fund the de-risking as taxpayers and capture some returns as pension beneficiaries, through two separate channels. The pension exposure to these specific transition vehicles is likely a small fraction of total pension assets, and the return to individual beneficiaries is indirect. The taxpayer exposure, by contrast, is direct, legislated, and contractually guaranteed.