Although the government has cancelled the 20% sales quota for 2026, it should maintain the 23% sales quota for 2027 and the sales quotas for each subsequent year. If the automakers made a legitimate effort, they could readily achieve these quotas.
Furthermore (and as noted above), the ZEV Regs already contain “compliance flexibility mechanisms” that make it easier for the automakers to achieve the sales quotas. One of these is the early ZEV credits:
Early ZEV credits
The [ZEV Regs] will allow a company to earn early ZEV credits for selling ZEVs in model years 2024 and 2025 within a specific threshold. Companies only earn early ZEV credits for the ZEV portion of their fleet offered for sale that is both below the 2026 target (20%) and above 8% in 2024 and 13% in 2025. The latter percentages were established based on analysis of current ZEV adoption trends in Canada and provincial ZEV regulatory requirements in 2024 and 2025. These credits are earned at the same rate as if they were sold in model year 2026, except there is no limit on the contribution of PHEVs towards the overall early ZEV credit allowance.
In addition, only regulatees in a deficit can use early ZEV credits, and they can only use them to offset their own deficits in model years 2026 and 2027, meaning they cannot be traded to other manufacturers. However, the combined contribution of early ZEV credits and ZEV charging station credits… that can be used to meet a company’s compliance obligation is capped at 10% per model year.1
The federal government should amend the ZEV Regs so the early credit compliance flexibility mechanism includes 2026 and so the benefit of it is extended into 2028.
1 RIAS, p. 4001. Canada Gazette Part II, Vol.157, No. 26, 20 December 2024. Retrieved on 14 September 2025 from https://gazette.gc.ca/rp-pr/publications-eng.html#a2