CBAM reporting requires every authorized CBAM declarant to submit one annual declaration by September 30, covering 5 categories of data for all goods imported under EU CBAM in the preceding calendar year. The first declaration covers calendar year 2026 imports and is due September 30, 2027, under Article 6 of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Getting the documentation chain right before that deadline depends on actions taken now, in 2026, while imports are occurring. This article covers each required data element, the verification standard attached to actual emissions values, and the 4-year record-keeping obligation that follows every declaration.
Caption: The CBAM reporting cycle runs from January 1 import date to September 30 declaration deadline, with certificate surrender occurring at the moment of filing.
What EU CBAM Reporting Requires in Summary
EU CBAM reporting is the annual obligation of an authorized CBAM declarant to declare, to their national competent authority, the total quantity, total embedded emissions, and corresponding certificates surrendered for all Annex I goods imported during the previous calendar year, supported by a verification report from an accredited verifier. The deadline is September 30 each year.
Five data categories make up every CBAM declaration filed under Article 6. These are total quantity of goods by CN code and country of origin, total specific embedded emissions per goods type and country of origin, CBAM certificates surrendered, any Article 9 deduction for carbon price paid in the country of origin, and a reference to the verification report covering the embedded emissions data. A declaration missing any one of these elements is incomplete and subject to the €100 per tonne CO₂e penalty for each tonne not properly covered.
The EU CBAM declaration is not a quarterly report or a customs form. It is a standalone annual compliance event filed through the CBAM Registry operated by DG TAXUD, distinct from and in addition to the ordinary customs declarations filed at import time.
For a complete overview of how the reporting obligation fits into the broader system, the EU CBAM guide covers the full regulatory structure, from scope and sectors to the free allocation phase-out schedule running through 2034.
The 5 Required Data Elements in a CBAM Declaration
The 5 required data elements in a CBAM declaration are established in Article 6 of Regulation (EU) 2023/956. Each element requires specific supporting documentation, and each has a different preparation lead time.
1. Total Quantity of Goods Imported per CN Code
The quantity of CBAM goods imported during the calendar year is reported by goods type and country of origin, expressed in net tonnes (or MWh for electricity). The country of origin is determined by EU customs rules, not by the country of shipment or the country of the last export invoice. CN codes matter here: if steel billets (CN 7207) and hot-rolled coil (CN 7208) are both imported, each is declared separately under its own CN code.
Authorized declarants collect this data throughout the year from their customs declarations, which are automatically transmitted to the CBAM Registry by national customs authorities under Article 25 and Implementing Regulation (EU) 2025/2619. Cross-checking registry import records against internal procurement data before the September 30 deadline is standard practice for importers managing CBAM reporting obligations across multiple product lines.
2. Total Specific Embedded Emissions per Goods Type
Specific embedded emissions are expressed in tonnes of CO₂e per tonne of goods (or per MWh for electricity). The declaration reports the total embedded emissions for each goods type by country of origin, calculated as the sum of (specific embedded emissions per tonne) multiplied by (total tonnes imported).
Two paths exist for calculating specific embedded emissions. The first path uses actual values obtained from the non-EU production installation, calculated using the methodology in Implementing Regulation (EU) 2025/2547, and verified by an accredited verifier before the declaration. The second path uses default values published by the Commission in Implementing Regulation (EU) 2025/2621, which are set at the country-specific average emission intensity with a mark-up: 10% above the calculated default in 2026, 20% in 2027, and 30% from 2028 onward. Fertilizers carry a smaller mark-up of 1% at all stages.
Using actual values requires more preparation time but avoids the punitive mark-up. Using default values requires no verification but applies an overstatement penalty by design. The choice has direct financial consequences: for Chinese BF-BOF steel, the default value is 3.167 tCO₂e per tonne versus an actual value that may be closer to 2.0 tCO₂e per tonne, a 58% difference in reported emissions and a proportional difference in certificate obligation.
3. CBAM Certificates Surrendered
At the moment the authorized CBAM declarant files the annual declaration, they surrender CBAM certificates equal to the net verified embedded emissions of their imports. Certificates surrendered are cancelled immediately in the CBAM Registry. Each certificate represents one tonne of CO₂e, in electronic format, as defined in Article 3(10) of Regulation (EU) 2023/956.
The net certificate obligation in 2026 is reduced by the SEFA (Specific Embedded Free Allocation) factor, because EU ETS free allocation for CBAM sectors is not yet fully phased out. In 2026, the CBAM factor is 2.5%, meaning only 2.5% of embedded emissions require certificate coverage. A declarant importing 10,000 tonnes of BF-BOF steel with 2.0 tCO₂e per tonne carries 20,000 tCO₂ gross embedded emissions, but surrenders certificates covering only 500 tCO₂ (20,000 × 2.5%). At the current EU ETS price of approximately €70 per tCO₂, that equals €35,000 in certificates for 2026. The CBAM factor rises steeply through 2034, reaching 100% as free allocation is eliminated entirely.
Certificate sales from the national competent authority begin February 1, 2027. For 2026 imports, the certificate price is set as the quarterly average of EU ETS auction clearing prices during each quarter of importation, meaning importers know the certificate price for 2026 before they purchase in early 2027.
For a full explanation of how CBAM certificates are priced, purchased, and surrendered, the guide to CBAM certificates covers the quarterly holding requirement, the buyback provision, and certificate cancellation rules.
4. Article 9 Deduction for Carbon Price Paid in Country of Origin
The CBAM declaration includes, where applicable, evidence of a carbon price effectively paid in the country of origin for the embedded emissions of the imported goods. Article 9 of Regulation (EU) 2023/956 allows this amount to reduce the number of certificates surrendered.
Three conditions must be met to claim an Article 9 deduction. First, the carbon pricing scheme must be legally binding and effectively enforced in the third country, not voluntary or nominal. Second, the carbon price must have been actually paid by the production installation, reduced by any free allocations or state compensation received. Third, the scheme must appear on the Commission's list of qualifying schemes, which the Commission will publish from 2027 onward. As of April 2026, South Korea's K-ETS is the scheme most likely to qualify. China's ETS, India's CCTS, and Russia's token carbon tax do not qualify currently.
Voluntary carbon offsets and internal corporate carbon prices are categorically excluded from Article 9 deductions under the regulation.
5. Verification Report from an Accredited Verifier
All actual embedded emissions data submitted in a CBAM declaration must be covered by a verification report issued by an accredited verifier under Delegated Regulation (EU) 2025/2551 and Implementing Regulation (EU) 2025/2546. The verifier must be accredited by a National Accreditation Body recognized by European Accreditation (EA) under EN ISO/IEC 14065, independent from the production installation, and registered in the CBAM Registry. Verifier registration opens September 1, 2026.
For the first verification period covering 2026 imports, a physical site visit to the non-EU production installation is mandatory. Remote verification is not permitted for the first period. This requirement applies regardless of the country of origin or the complexity of the facility. Verifier fees range from €5,000 to €50,000 per production installation depending on complexity, size, and the number of products being verified. An importer sourcing from 20 installations faces verification costs of €100,000 to €1,000,000 for the first cycle alone.
The 13-month window between verifier registration opening (September 1, 2026) and the first declaration deadline (September 30, 2027) is operationally tight. Importers should identify and contract accredited verifiers now, before the September 2026 registration queue opens.
If an importer cannot obtain verified actual emissions data, default values apply with the 10% mark-up for 2026. Default values do not require verification.
The September 30 Annual Reporting Deadline
The annual CBAM declaration deadline is September 30 of the year following the import year, under Article 6 of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. The Omnibus amendment extended this deadline from May 31 (under the original regulation) to September 30, providing an additional 4 months for importers to complete verification and prepare documentation.
The three key reporting dates in the CBAM cycle are set out in the table below.
| Event | Date | Regulation |
|---|---|---|
| First CBAM declaration (covering 2026 imports) | September 30, 2027 | Article 6, as amended by 2025/2083 |
| Annual declaration (subsequent years) | September 30 each year | Article 6 |
| Certificate buyback deadline | October 31 of each surrender year | Article 23, as amended |
| Certificate cancellation (prior year certificates) | November 1 each year | Article 24(1), as amended |
The declaration and certificate surrender are a single simultaneous act. Filing the declaration without sufficient certificates in the CBAM Registry account triggers the €100 per tonne CO₂e penalty for every tonne not covered. The penalty does not discharge the certificate obligation: the declarant still owes both the €100 penalty and the missing certificates purchased at market price, making total non-compliance cost approximately €170 per tonne CO₂e at current ETS prices.
Caption: All 5 declaration elements must be present at filing; a missing verification report or incomplete emissions data makes the declaration non-compliant.
The CBAM declaration article provides step-by-step guidance on filing the declaration through the CBAM Registry, including how to enter each data element and reconcile customs import records with the declaration totals.
Record-Keeping Requirements After the Declaration
CBAM reporting obligations do not end on September 30. All supporting documentation must be retained until the end of the 4th year following the declaration year, under Article 6(6) of Regulation (EU) 2023/956 as amended.
The documents retained for a 2026 declaration (filed September 30, 2027) must be held until December 31, 2031 at the earliest. The complete list of required records for each declaration year covers 7 document categories.
The 7 record categories that must be retained are listed below.
- Customs declarations for all imported CBAM goods
- Producer emissions data and monitoring plan documentation from each production installation
- Verification reports from accredited verifiers
- CBAM certificate purchase confirmations from the national competent authority
- Article 9 deduction calculations and supporting evidence, including proof of carbon price paid
- SEFA free allocation adjustment calculations
- Correspondence with producers, verifiers, and national competent authorities regarding emissions data
National competent authorities conduct risk-based inspections under Article 15 of the regulation. Inspectors may request any of these records at any time during the 4-year retention window without advance notice. The Commission conducts cross-border anomaly analysis and alerts national competent authorities to discrepancies detected across the EU.
Customs authorities automatically transmit import data to the CBAM Registry under Article 25 and IR 2025/2619. Discrepancies between customs records and CBAM declaration data are automatically flagged for review. This means records must be consistent with both the customs file and the registry declaration.
Who Is Required to Submit a CBAM Report
Does the Reporting Obligation Apply to All EU Importers?
No. The CBAM reporting obligation applies only to authorized CBAM declarants who import Annex I goods above the 50-tonne annual de minimis threshold. Three conditions determine whether the obligation applies.
First, the imported goods must be classified under CN codes listed in Annex I of Regulation (EU) 2023/956. Covered goods include iron and steel (Chapters 72 and 73), cement (CN 2523), aluminium (Chapter 76), fertilizers (Chapters 28 and 31), electricity (CN 2716), and hydrogen (CN 2804 10 00).
Second, the importer's total annual net mass of CBAM goods across all sectors must exceed 50 tonnes per calendar year. Electricity and hydrogen have no de minimis threshold; all volumes trigger the obligation regardless of quantity.
Third, the country of origin must not be exempt under Annex III. The exempt territories are Iceland, Liechtenstein, Norway, and Switzerland. All other third countries, including Turkey, are subject to CBAM despite Turkey's EU Customs Union relationship.
An importer who meets all three conditions must be an authorized CBAM declarant to file a declaration. Importing CBAM goods without authorization carries penalties of €300 to €500 per tonne CO₂e, three to five times the standard penalty rate.
Is Verification Required for Every CBAM Report?
Yes, with one exception. Verification by an accredited verifier is required for every CBAM declaration that uses actual embedded emissions values from production installations. The single exception is when default values from IR 2025/2621 are used for all goods in the declaration; those default values do not require verification.
In practice, most importers with significant CBAM exposure have a financial incentive to use actual values rather than defaults, because defaults include a punitive mark-up of 10% to 30% above the calculated country average. Understanding the CBAM embedded emissions calculation methodology is the prerequisite for obtaining actual values from non-EU producers.
What Are the Penalties for Late or Incomplete CBAM Reporting?
Late or incomplete CBAM reporting triggers a penalty of €100 per tonne CO₂e for every tonne of embedded emissions not covered by surrendered certificates at the September 30 deadline. The penalty is inflation-adjusted from a base year and set at €100 per tonne CO₂e under Article 26(1) as amended by Regulation (EU) 2025/2083. The penalty is identical in magnitude to the EU ETS excess emissions penalty, a deliberate design choice to equalize the cost of non-compliance across domestic and border carbon pricing.
The €100 penalty does not substitute for the certificate obligation. A declarant who owes 1,000 certificates and fails to surrender them pays €100,000 in penalties plus must still purchase and surrender the 1,000 certificates at market price (approximately €70,000 at current prices), for a total cost of approximately €170,000. Non-compliance is not a deferral. It is an additional financial burden on top of the original obligation.
For detailed guidance on penalty calculations, appeal rights, and the enforcement process, the CBAM regulation article covers the legal framework under Article 26.