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Internal Carbon Pricing

Technical Guide • Intermediate • 2 min read

Audience
CFOs • Investment Committees • Model Developers
Last Reviewed
July 2026
Updated
Version 1.0

Executive Summary

Internal carbon pricing applies a company-determined carbon price, either as a notional shadow price used in investment appraisal or as an actual internal fee charged to business units, to inform capital allocation ahead of, or independent of, an external compliance carbon price. This guide covers the distinction between the shadow price and internal fee mechanisms, how the price level should be set and justified, and how it should be applied consistently across capital expenditure decisions.

Key Takeaways

  • Internal carbon pricing applies a company-determined carbon price to inform capital allocation, either as a notional shadow price used only in investment appraisal, or as an actual internal fee charged to business units, and the two mechanisms have materially different behavioural and cash flow effects.
  • A shadow price affects which projects are approved by raising the effective hurdle for emissions-intensive capital expenditure in the appraisal calculation, without generating any actual cash flow or fund.
  • An internal fee generates an actual cash flow, typically pooled into a fund used to finance abatement investment or offset other business unit costs, and therefore has a real balance sheet and incentive effect a shadow price does not.
  • The internal price level should be set with an explicit, disclosed justification, commonly benchmarked against an external compliance price forecast or a target consistent with the entity's own decarbonisation commitments, rather than an arbitrary figure.
  • The internal price should be applied consistently across all capital expenditure decisions it is intended to inform, not selectively to some business units or project types and not others, since selective application undermines its purpose as a capital allocation signal.

Objective

This guide covers applying internal carbon pricing within Climate Finance & Climate Financial Modelling, to inform capital allocation ahead of or independent of external compliance carbon pricing.

Shadow Price Versus Internal Fee

A shadow price affects which projects are approved by raising the effective hurdle for emissions-intensive capital expenditure in the appraisal calculation, without generating any actual cash flow. An internal fee generates an actual cash flow, typically pooled into a fund used to finance abatement investment (see Emissions Reduction Models) or offset other business unit costs, and therefore has a real balance sheet and incentive effect a shadow price does not.

Setting the Price Level

The internal price level should be set with an explicit, disclosed justification, commonly benchmarked against an external compliance price forecast (see Carbon Pricing Models) or a target consistent with the entity's own decarbonisation commitments, rather than an arbitrary figure with no stated basis.

Consistent Application Across Capital Expenditure

The internal price should be applied consistently across all capital expenditure decisions it is intended to inform, not selectively to some business units or project types and not others. Selective application undermines the price's purpose as a genuine capital allocation signal and can be used, whether deliberately or not, to favour specific projects rather than consistently reflect carbon cost across the portfolio.

Common Construction Pitfalls

Shadow price and internal fee conflated. Treating the two mechanisms as interchangeable overlooks their materially different cash flow and incentive effects.

Price level set without disclosed justification. An arbitrary internal price undermines the credibility of the capital allocation signal it is meant to provide.

Selective application across business units or project types. Undermines the price's purpose as a consistent capital allocation signal.

  • State explicitly whether the internal carbon price operates as a shadow price, an internal fee, or both.
  • Disclose the basis for the internal price level, benchmarked against compliance forecasts or decarbonisation targets.
  • Apply the internal price consistently across all capital expenditure decisions it is intended to inform.

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Frequently Asked Questions

What is internal carbon pricing?

The practice of applying a company-determined carbon price to inform capital allocation, either as a notional shadow price used only in investment appraisal, or as an actual internal fee charged to business units, ahead of or independent of any external compliance carbon price the entity may also face.

What is the difference between a shadow price and an internal fee?

A shadow price affects which projects are approved by raising the effective hurdle for emissions-intensive capital expenditure in the appraisal calculation, without generating any actual cash flow, while an internal fee generates an actual cash flow, typically pooled into a fund financing abatement investment, and therefore has a real balance sheet and incentive effect a shadow price does not.

How should the internal carbon price level be set?

With an explicit, disclosed justification, commonly benchmarked against an external compliance price forecast or a target consistent with the entity's own decarbonisation commitments, rather than an arbitrary figure with no stated basis.

Why does consistent application matter?

Because the internal price should be applied across all capital expenditure decisions it is intended to inform, not selectively to some business units or project types and not others, since selective application undermines its purpose as a genuine capital allocation signal and can be used to favour specific projects rather than consistently reflect carbon cost across the portfolio.

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