CBAM Compliance Timeline
Key deadlines and requirements for EU Carbon Border Adjustment Mechanism compliance in the definitive phase (2026 onwards).
🔴 Mandatory Since January 1, 2026: Authorized CBAM Declarant
As of January 1, 2026, only companies registered as Authorized CBAM Declarants may import CBAM-covered goods into the EU. Importing without this status is non-compliant and may result in penalties or refusal of goods.
How to apply:
- Contact your country's National Competent Authority (NCA)
- Submit EORI number + company registration
- Prove annual import volume exceeds 50 tonnes
- Receive Authorized Declarant status in the CBAM registry
De Minimis Exemption:
Importers with < 50 tonnes/year total of CBAM goods (excl. electricity & hydrogen) are exempt from the Authorized Declarant requirement and certificate obligations.
Key Deadlines
October 1, 2023
Transitional Phase Begins
CBAM reporting requirements started. Quarterly reports required.
December 31, 2025
Transitional Phase Ends
Final quarterly report submitted. Transitional phase closed.
January 1, 2026
Definitive CBAM Phase + Authorized Declarant Requirement
Certificate purchase obligations begin. Only Authorized CBAM Declarants may now import CBAM goods. 10% markup on default values applies.
February 1, 2027
Certificate Sales Begin
CBAM certificates available for purchase from national competent authorities.
September 30, 2027
First Annual CBAM Declaration & Certificate Surrender
Submit 2026 full-year import declaration and surrender matching CBAM certificates via the EU CBAM registry. Under the Omnibus Regulation both the declaration and surrender deadline fall on the same date — one annual declaration covers all 2026 imports (this replaced the earlier 31 May declaration date).
January 1, 2027
20% Default Value Markup
Markup on default emission values increases to 20%.
January 1, 2028
30% Default Value Markup
Markup on default emission values increases to 30%.
Compliance Checklist
Immediate Actions (Q1 2026)
- !Become an Authorized CBAM Declarant — mandatory to import CBAM goods
- !Register in the EU CBAM registry via your National Competent Authority
- !Map all imports to CBAM-covered HS codes
- !Verify you exceed (or are under) the 50 tonne de minimis threshold annually
- •Request verified emission data from your suppliers
- •Set up internal tracking systems
Ongoing Requirements
- !Track all imports by quantity and origin throughout the year
- !Document embedded emissions per shipment
- •Record any carbon prices paid at origin country
- •Maintain supplier emission certifications and verifier reports
- ○Prepare one annual internal compliance report (no quarterly reports)
Before First Annual Declaration (2027)
- !Verify all 2026 import data is complete and verified
- !Calculate total embedded emissions for all 2026 CBAM imports
- !Purchase sufficient CBAM certificates from national authority
- !Submit annual declaration and surrender certificates by September 30, 2027
📋 Definitive Phase: Annual Reporting Only
The transitional phase (Oct 2023 – Dec 2025) required quarterly reports. That is now over. In the definitive phase (2026 onwards), importers submit one annual CBAM declaration per year:
❌ Old (Transitional Phase)
4 quarterly reports per year, reporting only — no certificate purchase
✅ Now (Definitive Phase, 2026+)
1 annual declaration per year + certificate purchase & surrender
Default Value Markup Schedule
If you use EU default emission values instead of verified actual data from your suppliers, a markup penalty is added to encourage transition to actual emissions reporting.
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