CBAM Declarant Services 2026: Who Can File for You and What They Cost

CBAM declarant services exist because only an authorised CBAM declarant may import goods covered by Regulation (EU) 2023/956 (Article 4, with a de minimis exemption in Article 2a), and an importer that is not established in a Member State must act through an indirect customs representative that holds that status (Article 5(2)).

This directory names 17 organisations that state a declarant, representation or filing offering for EU CBAM on their own websites, each checked on October 12, 2026. Five say they act as the authorised declarant or as an indirect customs representative, eight sell filing or report preparation as a service, and four sell software that the importer files with. The EU CBAM rules decide what each type can take off an importer's desk, and where the Article 26 penalty lands.

General Summary

CBAM declarant services are third-party services that either hold authorised CBAM declarant status for an importer's goods or prepare and submit the importer's own annual declaration.

The seven facts that frame the choice are listed below.

• 17 providers are named, each sourced to a page on its own website; 13 remain when the four software entries are left out
• 5 providers state that they act as the authorised declarant or as an indirect customs representative; the other 12 state filing support only, eight as a service and four as software
• EUR 100 per tonne CO2e, increased in line with the European index of consumer prices, is the penalty for each certificate not surrendered, and it falls on the authorised CBAM declarant (Article 26(1); Article 16(3) and (4) of Directive 2003/87/EC)
• Three to five times that penalty applies to a person other than an authorised CBAM declarant who brings goods in without complying (Article 26(2))
• March 31, 2026 was the application date that allowed provisional importing (Article 17(7a)); it has passed
• September 30, 2027 is the first CBAM declaration deadline, covering 2026 imports (Article 6(1))
• 0 providers publish a fee for acting as declarant or for filing

What CBAM Declarant Services Actually Cover

CBAM declarant services cover six tasks, from the authorisation application to the annual declaration, and providers differ on how many of the six they take on.

The legal status at the centre of all six is the CBAM authorized declarant (authorised CBAM declarant in the Regulation's spelling), defined in Article 3(17) as a person authorised by a competent authority under Article 17. Every task below is an obligation of that person. A provider that is not itself the CBAM authorized declarant for the goods can prepare a filing, but it does not own the obligation behind it.

The six tasks, with providers whose own pages state each one, are listed below.

• Scope and classification checks: Gaston Schul, Customs Support Group, Fiscalead, Easyfrontier
• Authorisation application support: ECUS, Fiscalead
• Supplier emissions data collection: Kuehne+Nagel, Fiscalead, Carbon Complete, Dubrink, CarbonChain
• Report or declaration preparation: Kuehne+Nagel, Gaston Schul, Tandem HSE, Fiscalead
• Submission to the registry or the authority: ASD Group, Gaston Schul, Carbon Complete, Embassy Freight, ECUS
• Certificate purchasing: Deloitte Netherlands states that it can handle certificate purchases; Easyfrontier states support for the purchase

What the Regulation Allows a Third Party to Do

Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, allows a third party two roles: an indirect customs representative can become the authorised CBAM declarant for a client's goods, and any authorised declarant can delegate the submission of its CBAM declaration.

Article 5(1) requires an importer established in a Member State to apply for the status before importing. Article 17(2) sets the criteria, which include establishment in the Member State of application and an EORI number. The competent authority assesses the application within 120 calendar days of receiving it (Article 4(1) of Implementing Regulation (EU) 2025/486), a period that can be extended where it asks for more information.

Article 17(7a), inserted by Regulation (EU) 2025/2083, let an importer or an indirect customs representative that applied by March 31, 2026 keep importing until the decision. That date has passed, so as of October 12, 2026 a new applicant has no provisional right to import.

The three lawful routes are compared in the table below.

The Indirect Customs Representative Route

An indirect customs representative is the only third party that can hold the CBAM obligation in place of the importer.

Where the importer is not established in a Member State, Article 5(2) says the indirect customs representative "shall obtain the status of authorised CBAM declarant". An EU-established importer may also appoint one, and under Article 5(1a) that representative becomes the declarant only where it "agrees to act as authorised CBAM declarant".

The representative needs the status whether or not its client is exempt under the 50-tonne de minimis threshold of Article 2a. Where it acts as authorised CBAM declarant on behalf of an importer, Article 5(2a) makes it "subject to the obligations applicable to the importer" for the goods it imports on that importer's behalf. Recital 8 of Regulation (EU) 2025/2083 names the declaration and the certificate surrender, and adds the penalties.

What Cannot Be Delegated

Responsibility cannot be delegated.

Article 5(7a) lets an authorised declarant delegate "the submission of CBAM declarations" to a person acting on its behalf and in its name. It then states: "The authorised CBAM declarant shall remain responsible for compliance with the obligations applicable to it under this Regulation." Recital 14 of Regulation (EU) 2025/2083 adds that the delegate should hold an EORI number and be established in a Member State.

The four things that stay with the authorised declarant are listed below.

• The status itself: Article 17(2)(c) ties it to establishment in the Member State of application, so a non-EU company cannot hold it
• The certificate obligation: paying a penalty does not release the declarant from surrendering the outstanding certificates (Article 26(3))
• The quarterly holding: from 2027, at least 50% of cumulative embedded emissions, held on the declarant's own registry account (Article 22(2)); a shortfall brings a notification and one month to top up (Article 22(3))
• The accuracy of the declaration: whoever prepared the figures

CBAM Declarant Service Providers

Seventeen organisations state a CBAM declarant, representation or filing offering for EU importers on their own websites as of October 12, 2026, and five of them state the declarant or indirect representative role.

A provider is listed only where its own page, fetched on October 12, 2026, states the offering described and that offering serves importers into the EU. A provider that acts as declarant holds its own account in the CBAM registry. Ask for that CBAM account number, which Article 17(4) requires every authorisation decision to carry. Our CBAM registry guide explains the accounts.

Inclusion is editorial and unpaid: cbamguide.com accepts no payment, commission or sponsorship from any provider named on this page. Order is not a ranking, a listing is not an endorsement, and "not stated" means the source page is silent on that point.

No provider's authorisation has been confirmed against a competent authority record. The third column records only what each provider's own page says.

Last checked: October 12, 2026.

Indirect Customs Representatives

Four customs firms state the representative or declarant role. ASD Group says it "holds authorised CBAM declarant status" and takes care of "the preparation and filing of your declarations". ALS Customs Services writes: "At ALS, we can act as your indirect customs representative, helping non-EU businesses comply with CBAM."

Three of the four entries carry a caveat. ASD Group's page lists the service for France and says: "To date, ASD Group can support you if your company imports less than 50 tonnes of products subject to CBAM (Carbon Tax)", plus hydrogen and electricity imports.

Remant Customs states that it, "as an indirect customs representative, offers the service to file these reports", in a news item dated October 1, 2023 about the transitional reports. The page says nothing about the definitive period. Customs Support Group's page still says CSG "will be getting their authorisation well ahead of the 2026 start date", so it states no authorisation held today.

Customs Brokers and Freight Forwarders

Four brokers and forwarders state filing support without stating the declarant role. Gaston Schul says it will "prepare the required CBAM declaration, and submit it through the Trader Portal on your behalf". Kuehne+Nagel says "we will generate your CBAM report in XML format, fully prepared for submission to the CBAM registry", a file the customer retrieves from its platform. ECUS states that it reports in the CBAM registry, and Embassy Freight lists timely submission of data to the competent authorities.

A broker that clears goods is not a declarant by default. Transuniverse Forwarding tells customers: "We cannot assume responsibility for the validity of CBAM authorizations, certificates, or associated emission reporting; these obligations rest entirely with the CBAM importer."

Trade Advisory and Big 4 Practices

Deloitte Netherlands is the one Big 4 page found that states the declarant role: "We act as your authorised CBAM declarant (agent), optionally combined with customs brokerage for seamless import handling." The same page offers "CBAM delegated party services".

Three other firms state filing work. Fiscalead lists "Annual CBAM declaration preparation and filing". Carbon Complete, with an office in Galway, states "We draft and submit reports on your behalf". Easyfrontier lists "Registering and managing profiles in the CBAM registry", and its list still includes "Collecting and reporting quarterly data on embedded emissions", wording from the transitional period.

Software-Led Managed Filing

One vendor sells managed filing next to its own platform. Tandem HSE offers a "Full Service" tier that runs "from preliminary consulting to the registration and follow-up of the declaration", alongside its CBAMate software.

Four entries are software, not agents. Dubrink adds support engineers to its platform, and its CBAM Success Engineer page states: "We walk you through your first official report submission". The importer still makes that submission.

CarbonChain says its software will "Generate CBAM reports that follow EU templates and methodologies". CBAMBOO said in a press release of July 8, 2025 that its platform "generates XML reports that are compatible with the EU's CBAM registry". With Dubrink, CarbonChain, CBAMBOO and kolum, the importer's own staff submit the declaration.

What CBAM Declarant Services Cost

No provider in this directory publishes a fee for acting as declarant or for filing a declaration, as of October 12, 2026.

The one price list found on the provider sites is for software. Dubrink's pricing page, read on October 12, 2026, shows under its EU CBAM tab a Starter plan at EUR 1,990 a year for up to 1,000 tonnes a year and a Premium plan at EUR 2,990 a year for up to 15,000 tonnes a year. Its UK CBAM tab shows the same numbers in pounds. Deloitte Netherlands states only that "Costs depend on scope and service level (software only versus managed services)".

The three engagement models, with the fee data that exists for each, are compared below.

The four cost drivers to raise in a quote request are listed below.

1. Installations and CN codes: emissions data is collected for each production installation, and each CN code adds classification work
2. Verification: actual emissions need an accredited verifier, quoted by vendors at EUR 5,000 to 50,000 per installation, a market estimate and not a Commission figure
3. Liability: a representative that acts as declarant buys and surrenders the certificates itself, so expect a request for prepayment or security
4. Volume and entities: annual tonnage and the number of importing legal entities

Certificate cost sits on top of any service fee. The official quarterly certificate price for Q3 2026 is EUR 82.32 per tonne CO2e, published October 5, 2026. CBAM Brief, EUR 199 a month, emails each price, default-value, CN-code and deadline change.

How to Choose a CBAM Declarant Service

Choose by establishment first: an importer not established in a Member State needs an indirect customs representative with authorised declarant status, while an EU-established importer can hold the status itself and outsource the filing.

The six steps for selecting a provider are listed below.

1. Confirm where the importing entity is established, because that decides whether Article 5(1) or Article 5(2) applies
2. Check annual tonnage against the 50-tonne threshold of Article 2a
3. Ask a provider that claims declarant status for its CBAM account number
4. Match the provider's stated scope against the six tasks listed earlier on this page
5. Fix the liability split in the contract before the first shipment
6. Start before certificate sales open on February 1, 2027

CBAM consultants are a different purchase: they advise without filing, and our directory of CBAM consultants lists them.

Questions to Ask Before Engaging

The five questions that separate a declarant from a filing agent are listed below.

• Which legal entity will be named as authorised CBAM declarant for my goods?
• Do you act as indirect customs representative under Article 5(1a) or 5(2), or as my delegate under Article 5(7a)?
• Who buys the certificates, and on whose registry account are they held at each quarter end?
• Who contracts the accredited verifier, and is verification inside your fee?
• What happens to my records and registry access when the contract ends?

Who Carries the Penalty If the Filing Is Wrong?

EUR 100 per tonne of CO2e, increased in line with the European index of consumer prices, is the penalty for each CBAM certificate not surrendered by September 30, and the authorised CBAM declarant carries it (Article 26(1)).

Article 26(1) sets no figure of its own. It applies the excess emissions penalty of Article 16(3) of Directive 2003/87/EC, EUR 100 for each tonne of CO2e, as increased under Article 16(4) of that Directive, at the level applicable in the year of importation.

Where the importer holds the status and a provider submits under Article 5(7a), the importer pays, because the declarant "shall remain responsible". Where an indirect customs representative acts as authorised CBAM declarant, the representative pays. Article 5(2a) places the importer's obligations on it, and recital 8 of Regulation (EU) 2025/2083 states that "it should be the indirect customs representative that is subject to penalties".

The same recital marks the limit: a representative of an EU-established importer that "has not agreed to act as an authorised CBAM declarant" should not be subject to penalties. Article 26(1) names only the authorised CBAM declarant, so a provider that prepares or submits without holding the status for those goods is not the person it penalises. Engaging a provider never removes the penalty. The contract decides who reimburses whom.

CBAM penalties are imposed by the competent authority, and Article 26(1a) allows a reduction only where the error came from "an operator, a verifier or an independent person certifying the carbon price documentation". A filing agent is not on that list. A person other than an authorised CBAM declarant who brings goods in without complying faces three to five times that penalty under Article 26(2). Our guide to CBAM penalties covers the mechanics.

When to Become an Authorised Declarant Yourself

Become the authorised declarant yourself when the importing entity is established in a Member State and imports more than 50 tonnes of CBAM goods a year.

Above that threshold the status is mandatory for an EU-established importer, unless an indirect customs representative agrees to act as declarant under Article 5(1a). Electricity and hydrogen have no threshold.

The importer authorization process runs through the competent authority of the Member State of establishment. Our importer authorization guide sets out each step.

Filing can still be outsourced afterwards under Article 5(7a), so holding the status and buying CBAM compliance support are not alternatives.

Frequently Asked Questions About CBAM Declarant Services

Can a Non-EU Company Use a CBAM Declarant Service Instead of Setting Up an EU Entity?

Yes. Article 5(2) of Regulation (EU) 2023/956 requires an importer not established in a Member State to act through an indirect customs representative that holds authorized CBAM declarant status. The representative then carries the declaration, certificate and penalty obligations for those goods under Article 5(2a). ALS Customs Services states this role specifically for non-EU businesses.

Does a CBAM Declarant Service File the CBAM Declaration for Me?

It depends on the provider. Gaston Schul, Carbon Complete, Embassy Freight and Fiscalead state submission or filing of the CBAM declaration or report, while Kuehne+Nagel and the four software platforms produce a registry-ready file and do not state that they submit it. The first CBAM declaration is due September 30, 2027. Under Article 5(7a) the authorised declarant stays responsible for it even when another party submits it.

Does the March 31, 2026 Deadline Still Matter When Choosing a CBAM Provider?

Yes. Article 17(7a) allowed provisional importing only for an importer or indirect customs representative that applied by March 31, 2026.

A representative that applied later cannot import CBAM goods for a client until it is authorised. Ask each provider for the date of its application and the status of the decision.

What CBAM Data Requirements Does a Declarant Service Still Need Me to Meet?

The CBAM data requirements do not shrink when a provider files. A provider needs the CN code, net mass, country of origin and producing installation for each import, plus embedded emissions from the producer or a decision to use default values. Our page on CBAM data requirements lists what to collect from every supplier.

Does This Directory Cover UK CBAM Services?

No. UK CBAM is a tax that starts on January 1, 2027 under the Finance Act 2026, with its own rules and its own providers.

UK CBAM services are a separate market from the EU CBAM compliance services listed here. The authorised CBAM declarant status in this directory is an EU status, recognised in all Member States under Article 17(1).

Is CBAM Software a Substitute for a CBAM Declarant Service?

No. CBAM software produces the calculations and the registry-ready file, while the importer remains the authorised declarant and submits the declaration. Four of the 17 entries are software. Our CBAM software reviews compare the platforms.