CBAM Registry Guide: How to Register, Log In, and Manage Your Account

The CBAM registry is the central EU database through which every authorized CBAM declarant manages their certificate holdings, submits annual declarations, and tracks import obligations under Regulation (EU) 2023/956. As of April 2026, over 12,000 authorization applications have been submitted, yet only 4,100 operators hold confirmed authorized declarant status. Thousands of importers are now racing against the March 31, 2026 application deadline that has closed for provisional importing rights.

Accessing the CBAM portal requires prior authorization as an EU-based person or entity that has been granted permission by a National Competent Authority (NCA) to make CBAM declarations and surrender CBAM certificates. This guide covers the 6-step registration process, how the CBAM login system works through the EU Customs Trader Portal, and what your account contains once access is granted.

Caption: The CBAM registry is accessed via the EU Customs Trader Portal using UUM&DS authentication credentials.

What Is the CBAM Registry?

The CBAM registry is a centralized EU database operated by DG TAXUD (the European Commission's Directorate-General for Taxation and Customs Union) that stores authorized declarant accounts, certificate holdings, import transaction records, and annual declaration data for all entities subject to Regulation (EU) 2023/956.

The registry serves 4 core functions in the definitive phase of CBAM (which started January 1, 2026). First, it validates authorization status in real time at the EU customs border, blocking unauthorized importers before goods are released for free circulation. Second, it records every import transaction automatically from customs authority data feeds. Third, it hosts the certificate purchase and surrender modules that become active from February 1, 2027. Fourth, it stores the annual CBAM declaration submitted by each authorized declarant, with a first deadline of September 30, 2027.

The registry is governed by Implementing Regulation (EU) 2024/3210 and its amendment IR (EU) 2025/2550, which updated the system for the definitive phase. The Authorization Management Module (AMM), the component used to apply for and manage declarant status, has been operational since March 31, 2025.

How to Register for the CBAM Registry: 6 Steps

Gaining access to the EU CBAM registry follows a mandatory 6-step sequence. The registry does not permit direct self-registration. Access is granted only after an NCA processes and approves an authorization application. The 6 steps are listed below.

Step 1: Confirm You Need Authorized Declarant Status

Authorized declarant status is required for any EU-established importer that brings Annex I goods across the EU customs border and exceeds the 50-tonne annual de minimis threshold (Article 2(3a), as amended by Regulation (EU) 2025/2083). Three checks confirm whether you need to register.

The first check covers product scope: look up every imported product's CN code in Annex I of Regulation (EU) 2023/956. The 6 covered sectors are iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen, each identified by specific CN codes in Chapters 25, 28, 31, 72, 73, and 76, plus CN codes 2716 00 00 (electricity) and 2804 10 00 (hydrogen). The second check covers the de minimis threshold: if total annual imports of CBAM goods (excluding electricity and hydrogen, which have no threshold) fall at or below 50 tonnes per importer, no CBAM obligation applies. The third check covers origin: goods from Iceland, Liechtenstein, Norway, and Switzerland are exempt under Annex III; all other third countries, including Turkey, are subject to CBAM.

Importers who import CBAM goods without authorization face penalties of €300 to €500 per tonne CO₂e under Article 26(2), as amended.

Step 2: Identify Your National Competent Authority

Each EU member state designates its own NCA to process CBAM authorization applications, and your NCA is determined by where your business is established for VAT purposes, not where you import goods. The 27 NCAs cover every member state, with institutional alignment varying: 20 member states placed CBAM responsibility in environment or energy ministries, while 7 placed it in finance or tax departments.

The table below lists the NCAs for the EU's 9 largest importing economies.

Contacting the wrong NCA delays the 120-day processing clock, because applications must be refiled with the correct authority. Verify your member state of establishment before submitting any documentation.

Step 3: Gather the Required Application Documents

Authorization applications are submitted through the Authorization Management Module of the CBAM registry at cbam.ec.europa.eu, and the AMM requires all documents to be uploaded in digital format. The application requirements are set out in Implementing Regulation (EU) 2025/486, Articles 4 through 8.

The 8 required document categories are listed below.

• Valid Economic Operator Registration and Identification (EORI) number issued by EU customs authorities
• Business registration documents demonstrating establishment in the EU customs territory
• Tax identification number for the member state of establishment
• Audited financial statements for the preceding 2 to 3 financial years (or a bank guarantee if the entity was established less than 2 years ago)
• Evidence of 5-year customs and tax compliance history: no serious customs violations, no convictions for tax fraud, smuggling, money laundering, or environmental offenses, and no active insolvency proceedings
• Description of CBAM goods to be imported: CN codes, estimated annual tonnage, countries of origin, and production installation names, addresses, and geographic coordinates
• Identity of the person legally responsible for CBAM compliance within the organization
• Internal CBAM compliance procedures document

Non-EU entities cannot hold authorized declarant status directly. They must appoint an EU-established indirect customs representative who accepts joint liability for the CBAM obligation (Article 5(2a)).

Step 4: Submit the Application by March 31, 2026

The authorization application deadline for provisional importing rights during the definitive phase was March 31, 2026 (Article 17(7a), inserted by Regulation (EU) 2025/2083). Importers who submitted their application by this date retain the right to continue importing CBAM goods while their authorization is being processed.

Applications submitted after March 31, 2026 do not benefit from this provisional importing provision. An importer in this situation must obtain full authorization before placing any further CBAM goods under free circulation. The EU CBAM guide covers the broader compliance context for importers caught by this timing gap. Because the 120-day processing clock does not start until the NCA receives a complete and valid application, incomplete submissions can push the effective authorization date months beyond the filing date.

Grounds for refusal include: serious customs violations in the prior 5 years, criminal convictions for tax fraud or environmental crime, active inclusion on the EU financial sanctions list, active insolvency proceedings, and failure to provide required documentation within NCA-set deadlines.

Step 5: Await the NCA Authorization Decision

The NCA issues its authorization decision within a maximum of 120 days from receipt of a complete application (Article 4(1) of IR 2025/486). The 120-day clock pauses during any period when the NCA requests additional information and the applicant has not yet responded. Providing complete documentation at filing is the most effective way to avoid delays.

As of January 7, 2026, over 12,000 applications had been submitted across all 27 member states, with more than 4,100 operators already holding authorized status. NCA processing capacity varies by member state: Germany's DEHSt and the Netherlands' NEa processed the highest volumes, reflecting those countries' share of EU steel, aluminium, and fertilizer import flows.

The CBAM authorized declarant status page provides the full list of eligibility conditions and grounds for authorization revocation for importers that lose compliance status after authorization is granted.

Step 6: Access the CBAM Registry Portal

Authorization granted by the NCA triggers the creation of a CBAM account within the EU CBAM registry. The CBAM login uses the UUM&DS (Uniform User Management and Digital Signature) authentication system, which is the same platform used for EU ETS registry access. Companies already registered in the EU ETS can use existing UUM&DS credentials to log in to the CBAM portal without creating a new identity.

The CBAM portal is accessible at cbam.ec.europa.eu via the EU Customs Trader Portal. Once logged in, the authorized declarant account contains 5 data categories: the CBAM account number and authorization details, import transaction records automatically populated from customs data, CBAM certificate holdings organized by vintage year, the annual declaration module, and declaration history and verification report links.

Caption: The authorized declarant's CBAM registry account consolidates certificate holdings, import data, and declaration history in a single interface.

What Your CBAM Registry Account Contains

The CBAM registry account is the operational core of ongoing CBAM compliance, and each module becomes active at a different stage of the compliance calendar. Understanding what the account contains, and when each feature is available, prevents gaps in the compliance timeline.

Certificate Management Module

The certificate purchase and surrender module within the CBAM registry activates on February 1, 2027. CBAM certificates are purchased exclusively from the national competent authority through the Common Central Platform, a tender-based purchasing system for which the Commission launched a tender on February 16, 2026 (deadline April 6, 2026). No secondary market exists for CBAM certificates. Exchange trading and bilateral certificate trades between declarants are prohibited.

The price of each certificate is set by the quarterly average of EU ETS auction clearing prices for 2026 imports (Article 22(1a), inserted by Regulation (EU) 2025/2083). From 2027 onward, the price shifts to the weekly average of EU ETS auction closing prices (Article 22(1)). At the current EU ETS reference price of approximately €70 per tonne CO₂e (late March 2026, fluctuating daily), a steel importer bringing in 5,000 tonnes of blast furnace steel with embedded emissions of approximately 2.0 tCO₂ per tonne would carry a gross certificate obligation of 10,000 certificates. The net 2026 obligation is only 2.5% of this gross figure due to the CBAM factor in the free allocation phase-out schedule, resulting in 250 certificates at a total cost of approximately €17,500.

Quarterly holding requirements apply from 2027 onward: at the end of each calendar quarter, the declarant's account must hold certificates equal to at least 50% of cumulative embedded emissions from all CBAM imports since the start of that calendar year (Article 22(2), as amended by 2025/2083).

Declaration Module

The annual CBAM declaration is filed through the registry's declaration module, with the first deadline set at September 30, 2027 (covering all calendar year 2026 imports). Subsequent annual deadlines fall on September 30 of each year following the import year.

The declaration must contain 5 elements under Article 6: total quantity of CBAM goods imported by type and country of origin, total specific embedded emissions by type and country, the number of certificates surrendered, any Article 9 deduction for carbon prices paid in the country of origin, and references to verification reports. At the time of filing, the declarant surrenders the CBAM certificates corresponding to verified net embedded emissions, and the registry cancels those certificates immediately.

Certificates not surrendered or sold back by the buyback deadline of October 31 of the surrender year are automatically cancelled by the registry on November 1 (Article 24(1), as amended).

Import Data and Customs Integration

Customs authorities transmit import data to the CBAM registry automatically for every shipment of Annex I goods, under Article 25 of Regulation (EU) 2023/956 and IR (EU) 2025/2619. From January 1, 2026, customs authorities validate CBAM authorization status in real time before releasing goods for free circulation. Unauthorized importers are blocked at the border, and their import data is flagged for NCA review.

The import data feed populates the declarant's account with the CN code, net mass, country of origin, and EORI number for each transaction. Discrepancies between customs records and data in the annual declaration trigger automatic flags for NCA inspection.

Managing Your CBAM Account After Registration

Active management of the CBAM registry account involves 3 recurring tasks: quarterly certificate position reviews, preparation of the annual declaration, and maintaining audit-ready records.

Quarterly Certificate Position Review

Authorized declarants review their certificate holdings each quarter against the 50% holding threshold. The NCA sends a formal notice if the threshold is not met at the end of any quarter, and persistent failures attract enforcement attention under Article 15. A practical approach is to estimate each quarter's embedded emissions based on import volumes recorded in the account and purchase the required certificates before the quarter-end date.

The buyback provision provides a structural hedge: declarants may sell back up to 50% of certificates purchased in a given year, at the original purchase price, by October 31 of the surrender year (Article 23, as amended). This provision allows deliberate over-purchasing as a risk management tool, because the downside of over-purchasing is limited to the opportunity cost of capital for up to 12 months.

Annual Declaration Preparation

The annual declaration draws on 4 data sources managed through or linked from the registry: the customs import data feed, verified embedded emissions data from non-EU producers, verifier accreditation confirmation, and Article 9 deduction supporting documentation. Verifiers cannot register in the CBAM registry until September 1, 2026, giving them 13 months to complete mandatory physical site visits to non-EU production installations before the September 30, 2027 declaration deadline. This timeline is compressed, and importers sourcing from 10 or more production installations should contract accredited verifiers immediately.

Using actual verified emissions rather than default values avoids the punitive mark-ups set in IR (EU) 2025/2621: 10% above the country-specific average in 2026, rising to 20% in 2027 and 30% from 2028 onward. For a Chinese steel slab with a default value of 3.167 tCO₂e per tonne compared to an actual production intensity closer to 2.0 tCO₂e per tonne, the financial difference compounds rapidly as the CBAM factor increases through 2034. The CBAM declaration guide covers the full declaration filing process in detail.

Record-Keeping Requirements

All CBAM records must be retained until the end of the 4th year following the declaration year (Article 6(6), as amended), giving a total retention window of approximately 4 to 5 years from the date of import. The 7 record categories that must be kept are listed below.

• Customs declarations for all CBAM-covered goods
• Supplier and producer embedded emissions data and monitoring plan documentation
• Verification reports from accredited verifiers
• CBAM certificate purchase and surrender confirmations from the registry
• Article 9 deduction calculations and supporting evidence
• Internal CBAM compliance procedures and calculation workbooks
• Correspondence with producers, verifiers, and NCAs

NCAs hold inspection rights without advance notice during the retention period. The Commission shares anomaly data across member states, meaning that a discrepancy identified in one member state can trigger inspection in another where the same declarant holds imported goods.

When Does the CBAM Registry Open for Certificate Purchases?

The CBAM registry opens for certificate purchases on February 1, 2027. Before this date, the registry functions primarily as an authorization, customs integration, and data management system. The certificate purchase module is inactive during calendar year 2026 by design: importers accumulate their import transaction records throughout 2026, obtain verification of embedded emissions, and then purchase and surrender certificates in the first months of 2027.

This structure means the CBAM certificate cost for 2026 imports is determined by EU ETS quarterly auction prices during 2026 (averaging approximately €70 per tonne CO₂e) but is paid in 2027. The 13-month lag between import year and certificate surrender creates a cash flow advantage for importers that plan early but a compliance risk for those who wait, because the certificate price at purchase time in early 2027 is known from 2026 auction records, eliminating price uncertainty for that year.

The guide to CBAM certificates covers the mechanism and practical steps for the purchase process, which opens alongside the certificate module on February 1, 2027.

Is the CBAM Registry the Same as the EU ETS Registry?

No. The CBAM registry and the EU ETS registry are separate systems, but they share the same authentication infrastructure. Both use the UUM&DS (Uniform User Management and Digital Signature) login system, which means EU ETS registry users can access the CBAM portal with existing credentials without creating a new account. However, the two registries hold distinct account types, serve different legal frameworks, and operate under different administrative modules. The EU ETS registry manages emissions allowances under Directive 2003/87/EC, while the CBAM registry manages CBAM certificates under Regulation (EU) 2023/956.

Can a Non-EU Company Register Directly in the CBAM Registry?

No. The EU CBAM registry is accessible only to authorized CBAM declarants, and authorized declarant status requires establishment in the EU customs territory (Article 3(15)). A non-EU exporter or producer cannot hold a CBAM account directly. Non-EU companies access the system indirectly through two routes: first, via a CBAM Operators Portal that allows non-EU production installation operators to upload embedded emissions data for sharing with their EU importer customers; second, by appointing an EU-established indirect customs representative who holds the authorized declarant status and assumes legal responsibility for the CBAM obligation.

Does the CBAM Registry Check Authorization in Real Time at the Border?

Yes. From January 1, 2026, customs authorities validate CBAM authorization status automatically before releasing Annex I goods for free circulation. The validation draws directly from the CBAM registry's authorization records via the data exchange system established in IR (EU) 2025/2619. An importer without a valid authorized declarant entry in the registry faces immediate border blockage and referral to the NCA for investigation and penalty assessment.

Can Authorization Be Revoked After It Is Granted?

Yes. The NCA retains the right to revoke authorization at any time if the authorized declarant no longer meets the eligibility conditions under IR (EU) 2025/486. Revocation triggers include: discovery of a customs violation that was not disclosed in the original application, criminal conviction after authorization, entry on the EU financial sanctions list, insolvency proceedings, or persistent failure to comply with CBAM reporting and certificate-holding obligations. Revocation is an NCA decision subject to appeal through the member state's administrative courts, with final escalation possible to the Court of Justice of the European Union.

What Happens to Certificates in the Registry Account If Authorization Is Revoked?

Certificates held in the account at the time of revocation are not automatically cancelled. The NCA manages the transition, which typically involves a declaration covering the partial import year up to the revocation date, followed by surrender and cancellation of the corresponding certificates. Excess certificates are subject to buyback at the original purchase price, within the 50% buyback limit. Any certificates beyond the buyback limit and not surrendered are cancelled by the registry on November 1 of the relevant year.

The importer authorization guide covers the full eligibility assessment process for businesses that are still determining whether they qualify to apply. For importers already authorized, the CBAM regulation page provides the legal basis and article-level framework underpinning all registry obligations.