Fundamentals
What changes for CBAM declarants from 1 January 2026?
What changes on 1 January 2026 when the CBAM definitive regime begins, including authorisation, certificates, and the annual declaration cycle.
Applies to EU CBAM declarants and importers of covered goods from 1 January 2026 onward, under Regulation (EU) 2023/956.
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Direct answer
On 1 January 2026, CBAM moves from quarterly reporting to a binding regime. Only authorised CBAM declarants may import covered goods from that date. CBAM certificates become available for purchase, and the first annual CBAM declaration, covering 2026 imports, is due by 31 May 2027.
What switches on 1 January 2026
- Authorisation requirement for any party importing covered goods.
- Issuance of CBAM certificates priced against the EU ETS allowance price.
- Restrictions on the use of default values in place of actual data.
- Phase-out of free EU ETS allowances for CBAM sectors begins.
First full cycle
Imports across calendar year 2026 are aggregated into the first annual CBAM declaration, due by 31 May 2027. Verified embedded emissions, certificates surrendered, and any third country carbon price adjustment are all reflected in that single submission.
Certificate purchase and pricing
CBAM certificates are sold by the common central platform run on behalf of Member States. The price for the calendar week is the average closing price of EU ETS allowances on the previous week on the common auction platform. Declarants must hold enough certificates on quarterly reference dates and surrender the definitive number at annual declaration.
Where default values still apply
In the definitive regime the use of default values is restricted to cases where the declarant cannot reasonably obtain actual data from the operator of the installation of origin. Default values come with a conservativeness mark-up so that relying on them is not advantageous. Embedded emissions from electricity follow the specific rules in Annex IV.
Verification by an accredited verifier
The annual declaration is supported by a verification report produced by an accredited verifier. The verifier examines the monitoring methodology, the embedded emissions data, the carbon price evidence, and the certificate position, and issues an opinion that accompanies the declaration on the CBAM Registry.
What to prepare now
Importers should confirm CN code coverage of their goods, identify whether they qualify under the Article 27a de minimis threshold, secure authorisation if not, and align with their non-EU suppliers on the data they need to provide using the Commission's communication templates.