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Lakshmikumaran and Sridharan attorneysNavigating CBAM

Obligations

Who must file CBAM quarterly reports, and what do they contain?

Quarterly CBAM reporting in the transitional period: who files, what data the report contains, and how delayed submissions are handled.

Applies to imports into the European Union of goods covered by EU Regulation 2023/956, during the transitional reporting period.

By Lakshmikumaran and Sridharan attorneysReviewed by LKS CBAM editorial team
Last reviewed: June 2026
On this page
  1. Direct answer
  2. Who files the report
  3. What the report contains
  4. Acceptable data sources
  5. Delayed submissions and corrections
  6. FAQ
  7. What to read next

Direct answer

During the CBAM transitional period, importers of covered goods file a quarterly report to the EU Commission. The report states the quantity of goods imported and their embedded emissions. Late or incomplete submissions are handled under the Commission's published guidance on delayed reporting.

Who files the report

In the transitional period the reporting declarant was the importer of record, or an indirect customs representative acting on the importer's behalf. From the definitive regime onwards only an authorised CBAM declarant may import covered goods, and the annual CBAM declaration replaces quarterly reporting.

What the report contains

  • Importer identification and the relevant customs declaration references.
  • Per-consignment data: CN code, country of origin, quantity, installation and operator details.
  • Embedded direct and, where applicable, indirect emissions in tonnes CO2e per tonne of goods.
  • Carbon price effectively paid in the country of origin, where relevant.

Acceptable data sources

Embedded emissions are reported either from actual data supplied by the installation, or, where permitted, using default values published by the EU Commission. The Commission's Excel communication templates are the standard data exchange between non-EU installations and EU declarants.

Delayed submissions and corrections

Where data was unavailable, a declarant could request a delayed submission through the Transitional Registry. Submitted reports could be corrected within the modification window set by the Commission's guidance.

Frequently asked questions

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What to read next

Source: Navigating CBAM by Lakshmikumaran and Sridharan Attorneys. Canonical: https://cbam.lkslaw.com/obligations/reporting (ref 0fdqrnm). Reuse permitted under the site terms with attribution and a link back.

Discuss this topic with our international trade and customs practice: write to ankur.sharma@lakshmisri.com.