CBAM compliance now carries 3 hard deadlines and 5 distinct obligation types that every EU importer of carbon-intensive goods must track from January 1, 2026 onward. The authorization deadline of March 31, 2026 has already passed for many companies, making the gap between compliant and non-compliant importers measurable and consequential. Understanding the full compliance chain (from authorization through annual declaration and certificate surrender) determines whether an importer pays the standard €100/tCO₂e penalty rate or faces the unauthorized importer penalty of €300–500/tCO₂e.
This hub maps every CBAM obligation, deadline, and process currently in force under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.
Caption: The CBAM compliance cycle runs from January 1 (calendar year opens) through October 31 (certificate buyback deadline) each year.
What CBAM Compliance Requires in Practice
CBAM compliance is the set of legal obligations under Regulation (EU) 2023/956 requiring EU importers to obtain authorization, calculate embedded emissions in covered goods, purchase certificates at the EU ETS price, hold at least 50% of cumulative embedded emissions quarterly, and submit an annual declaration by September 30 each year. Authorization is the gateway obligation: only authorized declarants can legally import CBAM goods during the definitive phase.
The full obligation chain consists of 5 sequential requirements. Authorization comes first, followed by emissions calculation, quarterly certificate holding, annual declaration, and certificate surrender. Each step connects to the next: an importer cannot surrender certificates without first purchasing them, and cannot purchase certificates until the CBAM registry opens for sales on February 1, 2027.
To understand the regulatory foundation before working through the obligations, read the EU CBAM overview on /learn/eu-cbam/, which covers the mechanism's legal basis under Article 192(1) TFEU and its relationship to the EU Emissions Trading System.
CBAM Compliance Obligations: Timeline and Key Dates
The 5 core CBAM compliance obligations follow a fixed annual cycle. The table below shows each obligation, its deadline, and the penalty for non-compliance.
| Obligation | Deadline | Penalty for Non-Compliance |
|---|---|---|
| Apply for authorized declarant status | March 31, 2026 | €300–500/tCO₂e (unauthorized rate) |
| Quarterly certificate holding (≥50% of cumulative emissions) | End of each quarter | €100/tCO₂e shortage |
| Purchase CBAM certificates | From February 1, 2027 | €100/tCO₂e (failure to hold) |
| Submit annual CBAM declaration | September 30, 2027 (first; then annually) | €100/tCO₂e uncovered |
| Certificate buyback (up to 50% of purchased) | October 31 of surrender year | No penalty; opportunity closes |
The de minimis threshold of 50 tonnes annual mass exempts the smallest importers from most obligations. Electricity and hydrogen are excluded from this de minimis provision and remain subject to full compliance requirements regardless of volume.
The 13 CBAM Compliance Topics This Section Covers
This section addresses 13 distinct compliance topics, each with its own page. The 13 topics cover every aspect of the CBAM compliance chain, from the technical calculation of embedded emissions to the legal consequences of non-compliance.
1. Embedded Emissions Calculation
Embedded emissions calculation determines the tCO₂e figure that drives every downstream CBAM obligation. Embedded emissions are the direct (and for certain sectors, indirect) greenhouse gas emissions released during the production of CBAM goods in the country of origin. Cement and fertilizers include both direct and indirect emissions; iron and steel, aluminium, and hydrogen include direct emissions only. The calculation method used (actual versus default) affects the final certificate purchase obligation.
For detailed methodology on how embedded emissions are calculated under each approach, the embedded emissions calculation methods page at /compliance/calculation/ covers the production-based formula, allocation rules for complex goods, and the transition between methods.
2. CBAM Certificates
CBAM certificate obligations govern the financial core of the mechanism. EU importers purchase certificates from the competent authority of their member state, with each certificate representing one tonne of CO₂ equivalent. Certificate prices are set quarterly in 2026 using the average of EU ETS auction clearing prices, then weekly from 2027 onward. At the current ETS price of approximately €70/tCO₂ (Q1 2026), the gross certificate cost for blast furnace steel runs approximately €140/tonne before free allocation adjustment.
The process of buying, holding, and surrendering certificates includes the quarterly holding check at ≥50% of cumulative embedded emissions since January 1, and the annual surrender of certificates covering the prior year's full declared emissions.
3. Default Values
CBAM default values are the Commission-published emission factors that importers use when actual production data from exporters is unavailable. Default values carry a mark-up above the calculated benchmark: 10% in 2026, 20% in 2027, and 30% from 2028 onward for steel, cement, aluminium, and hydrogen. Fertilizer default values carry a 1% mark-up in all years. Importers using defaults pay more in certificates than those with verified actual data, creating a direct financial incentive to obtain exporter data.
4. CBAM Registry and Portal
The CBAM registry and portal is the central IT system where importers create accounts, submit quarterly reports (historical), manage declarations, and transact certificates. The registry is administered by the European Commission and accessed through national competent authority portals. Verifier registration in the registry opens on September 1, 2026, ahead of the first certificate sales on February 1, 2027.
5. CBAM Reporting Requirements
CBAM reporting requirements cover the annual declaration submitted by September 30 each year. The declaration covers all CBAM goods imported during the prior calendar year and must include: the quantity of each good (in tonnes), the country of origin, the total embedded emissions, and the number of certificates surrendered. The first declaration, due September 30, 2027, covers calendar year 2026.
6. Authorized Declarant Authorization
Authorized declarant authorization is the legal status required to import CBAM goods during the definitive phase. Importers who applied by March 31, 2026 receive a decision within 120 days. The authorization assessment covers 5 years of customs and tax compliance history, financial standing, and operational capacity. Only one authorized declarant status is required per EU importer, covering all CBAM sectors in which they operate.
7. CBAM Verification
CBAM verification is the process by which an accredited verifier reviews and validates the emissions data reported in a CBAM declaration. Verification applies to actual (non-default) emissions data. Verifiers must be accredited under Regulation (EU) 2025/2083 and registered in the CBAM registry from September 1, 2026. Importers using default values do not require third-party verification of those values, though the declaration itself remains subject to authority scrutiny.
8. Article 9 Carbon Price Deduction
The Article 9 carbon price deduction allows importers to reduce their certificate surrender obligation by the amount of carbon price already paid in the country of production. The deduction applies where the exporting country has a carbon pricing mechanism (such as an ETS or carbon tax) and the carbon cost was actually borne by the producer. The deduction is calculated in certificates per tonne and reduces the net financial burden on imports from countries with carbon pricing.
9. CBAM Penalties
CBAM penalties apply at two rates depending on the importer's authorization status. Authorized declarants who fail to surrender sufficient certificates pay €100 per tonne CO₂e not covered. Importers who import CBAM goods without authorization pay €300–500 per tonne CO₂e, representing 3 to 5 times the standard rate. Both rates are subject to inflation adjustment from the base year. Penalties do not replace the obligation to surrender certificates: payment of the penalty does not discharge the certificate obligation.
10. De Minimis Threshold
The 50-tonne de minimis threshold exempts importers whose total annual mass of CBAM goods falls below 50 tonnes. The threshold is calculated per importer, not per consignment, and applies across all CBAM goods combined (excluding electricity and hydrogen). Importers below the threshold are exempt from authorization, declaration, and certificate obligations for that calendar year. The threshold resets annually: an importer who exceeded 50 tonnes in 2026 must comply in 2027 even if their 2027 volume subsequently falls below the threshold mid-year.
11. Anti-Circumvention Rules
Anti-circumvention rules address attempts to avoid CBAM obligations through artificial transaction structuring, country of origin manipulation, or product classification changes. The rules target 3 primary circumvention methods: routing goods through non-CBAM countries, misclassifying CBAM goods under alternative CN codes, and splitting shipments to fall below the de minimis threshold. Enforcement responsibility lies with member state customs authorities, with penalties aligned to the unauthorized importer rate.
12. CBAM Annual Declaration
The CBAM annual declaration is the cornerstone reporting document filed by September 30 each year. For the first declaration (September 30, 2027), importers report on all CBAM goods imported between January 1 and December 31, 2026. The declaration must match the certificates surrendered on the same date. Discrepancies between declared emissions and surrendered certificates trigger penalty assessments. Records supporting the declaration must be retained until the end of the 4th year following the declaration year.
Caption: The annual CBAM declaration filed by September 30 must reconcile declared embedded emissions with the certificates surrendered on the same date.
How CBAM Compliance Fits Into the Broader EU Importer Obligation Chain
CBAM compliance is one component of the broader set of obligations facing EU importers of carbon-intensive goods. The EU importer compliance track at /importers/ covers the full obligation chain, including customs classification, supply chain data collection from non-EU exporters, and member state competent authority interactions across all 27 EU member states.
The 6 CBAM sectors (iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen) each carry sector-specific calculation rules and default values. An importer handling goods across 2 or more sectors manages parallel compliance tracks with different emission factors, different default value mark-ups, and in the case of cement and fertilizers, different emissions scopes that include indirect emissions.
Frequently Asked Questions About CBAM Compliance
Is CBAM compliance mandatory for all EU importers?
CBAM compliance is mandatory for all EU importers of goods listed in Annex I of Regulation (EU) 2023/956, unless the importer's total annual import mass falls below the 50-tonne de minimis threshold. The threshold excludes electricity and hydrogen, which are subject to full compliance requirements at any volume. Importers above the threshold must obtain authorized declarant status, calculate embedded emissions, and surrender certificates annually.
What happens if an importer misses the March 31, 2026 authorization deadline?
An importer who did not apply for authorized declarant status by March 31, 2026 is not authorized to import CBAM goods during the definitive phase. Importing without authorization triggers the higher penalty rate of €300–500 per tonne CO₂e, which is 3 to 5 times the standard €100/tCO₂e rate. The importer must apply for authorization, and a complete application receives a decision within 120 days. Unauthorized imports made before authorization is granted remain subject to the higher penalty regardless of the subsequent authorization decision.