CBAM authorization is a legal prerequisite for every EU importer of carbon-intensive goods under Regulation (EU) 2023/956, and the deadline to submit a complete application was March 31, 2026. Importers who missed that date or have not yet received a decision face penalties of €300 to €500 per tonne of CO₂e for importing CBAM goods without authorization. This guide covers the 8-step application process, the exact documents required under Implementing Regulation (EU) 2025/486, the National Competent Authority (NCA) submission workflow, the 120-day decision timeline, and what happens after approval or rejection. Understanding the full EU CBAM framework is useful context before beginning the authorization process.
What Is CBAM Authorized Declarant Status?
Authorized CBAM declarant status is the legal designation granted by a member state competent authority that permits a company established in the EU customs territory to import Annex I goods and submit CBAM declarations. The definition is established by Article 3(15) of Regulation (EU) 2023/956. Authorization is not optional: only companies holding this status can legally import iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen above the 50-tonne annual de minimis threshold during the definitive phase (from January 1, 2026 onward).
The authorized CBAM declarant is the entity that carries the certificate obligation. This obligation includes purchasing CBAM certificates from the NCA, holding at least 50% of cumulative embedded emissions as certificates at each quarter-end, and submitting the annual CBAM declaration by September 30 each year (first deadline: September 30, 2027 for calendar year 2026 imports).
EU importers who do not hold authorized CBAM declarant status but continue importing covered goods are subject to the unauthorized importer penalty: €300 to €500 per tonne of CO₂e, which is 3 to 5 times the standard certificate surrender penalty of €100 per tonne. Authorization is therefore the foundational step in the entire EU CBAM compliance chain, and the CBAM authorized declarant status page provides the full regulatory definition and obligations associated with this role.
Caption: The CBAM authorization process runs from eligibility check through NCA submission to registry access, with up to 120 days for a decision.
Who Is Eligible to Apply for CBAM Authorization?
Three eligibility conditions must all be satisfied before submitting a CBAM authorization application.
The 3 eligibility requirements for CBAM authorization are listed below.
- EU establishment: The applicant must be established in the customs territory of the European Union. Non-EU importers cannot hold authorized declarant status directly; they must appoint an indirect customs representative established in the EU (Article 5(2a) of Regulation (EU) 2023/956).
- CBAM-covered imports above the de minimis threshold: The applicant must import at least one good listed in Annex I of Regulation (EU) 2023/956, with annual net mass exceeding 50 tonnes per calendar year. Electricity and hydrogen have no de minimis threshold, so any volume of these goods requires authorization.
- Clean compliance history over 5 years: The applicant must demonstrate 5 years without serious customs violations, convictions for tax fraud, smuggling, money laundering, or environmental offenses, and no active insolvency proceedings (Article 5(5) of Regulation (EU) 2023/956 and Articles 4 to 8 of IR 2025/486).
Companies established for fewer than 12 months in some member states face additional scrutiny; national rules may require a bank guarantee where audited financial statements covering at least 2 years are unavailable. Checking the specific requirements of the relevant NCA before submitting is advisable.
The 8 Steps to Apply for CBAM Authorization
CBAM authorization follows a defined 8-step sequence governed by Article 17 of Regulation (EU) 2023/956 and IR 2025/486, as amended by IR 2025/2549.
Step 1: Confirm Your Imports Are Above the CBAM De Minimis Threshold
The de minimis threshold for CBAM authorization is 50 tonnes of annual net mass per importer, across all Annex I goods combined, excluding electricity and hydrogen. Confirm this threshold is exceeded before investing time in the full application. Calculate total annual tonnage for all CBAM-classified CN codes imported. If the total falls at or below 50 tonnes per year, CBAM obligations do not apply, and authorization is not required.
Step 2: Obtain a Valid EORI Number
An Economic Operators Registration and Identification (EORI) number is a mandatory requirement for the CBAM authorization application (IR 2025/486, Article 4). EORI numbers are issued by the customs authority of the member state of establishment. EU companies already active in customs procedures typically hold an EORI number; those without one must register with the relevant customs authority before submitting a CBAM application. The EORI number links the CBAM account to the applicant's customs identity and feeds into the automatic data exchange between customs authorities and the CBAM Registry under IR 2025/2619.
Step 3: Identify Your National Competent Authority
The NCA responsible for processing the CBAM authorization application is determined by the member state in which the applicant is established, specifically where it is registered for VAT or holds its principal place of business. The 15 key NCAs by country are shown in the table below.
| Member State | National Competent Authority (NCA) |
|---|---|
| Germany | Deutsche Emissionshandelsstelle (DEHSt), Federal Environment Agency |
| France | Direction Générale de l'Énergie et du Climat (DGEC) |
| Netherlands | Nederlandse Emissieautoriteit (NEa) |
| Italy | Comitato nazionale per la gestione CBAM (ISPRA / Ministry of Environment) |
| Spain | Oficina Española de Cambio Climático |
| Belgium | SPF Santé publique, Climate Change Service |
| Poland | KOBiZE (National Centre for Emissions Management) |
| Austria | Amt für den nationalen Emissionszertifikatehandel (AnEH) |
| Sweden | Naturvårdsverket (Environmental Protection Agency) |
| Denmark | Erhvervsstyrelsen (Danish Business Authority) |
| Finland | Energiavirasto (Energy Authority) |
| Ireland | Environmental Protection Agency (EPA) |
| Czech Republic | Ministry of Finance |
| Portugal | Agência Portuguesa do Ambiente |
| Greece | Ministry of Environment and Energy, Directorate of Climate Change |
Companies importing through a member state other than their state of establishment must still apply to the NCA of the member state of establishment, not the member state of import.
Step 4: Gather the Required Documentation
Seven categories of documentation are required for a complete CBAM authorization application under IR 2025/486, Articles 4 to 8.
- EORI number: Valid and registered in the EU Customs Trader Portal.
- Business registration documents: Current company registration certificates, articles of association, or equivalent national documents proving establishment in the EU customs territory.
- Tax identification number: VAT registration number in the member state of establishment.
- Audited financial statements: Covering the preceding 2 to 3 financial years. Companies established for fewer than 2 years must provide a bank guarantee or equivalent financial security acceptable to the NCA.
- 5-year compliance evidence: Documentation confirming no serious customs violations, no relevant criminal convictions, and no active insolvency or bankruptcy proceedings over the preceding 5 years.
- Import data and production installation details: CN codes of goods to be imported, estimated annual tonnage by good type and country of origin, and the names, postal addresses, and geographic coordinates of the production installations supplying those goods.
- Internal CBAM compliance procedures: A document describing how the company will collect embedded emissions data from suppliers, manage records, and meet quarterly holding requirements. The identity of the person legally responsible for CBAM compliance within the organization must also be named.
Incomplete applications reset the 120-day processing clock only from the date the NCA receives all required documents. Submitting a complete application on the first submission is critical to meeting the timeline.
Step 5: Submit the Application to the NCA Before March 31, 2026
Applications are submitted through the Authorization Management Module (AMM) of the CBAM Registry, accessible at cbam.ec.europa.eu. Authentication requires EU Customs Trader Portal credentials linked to the EORI number, using the UUM&DS system (the same authentication platform as the EU ETS Registry).
The application deadline of March 31, 2026 was established by Article 17(7a), inserted into Regulation (EU) 2023/956 by the Omnibus amendment, Regulation (EU) 2025/2083. Applicants who submitted by this date retain provisional importing rights while their application is under review. As of early January 2026, over 12,000 applications had been submitted, with over 4,100 operators already authorized. Importers who have not yet applied face the unauthorized importer penalty on any CBAM goods imported after the deadline without authorization.
Step 6: Respond to Any NCA Requests for Additional Information
NCAs may request additional information or documents during the review period. The 120-day decision clock pauses from the date the NCA issues the information request until the date the complete response is received (Article 4(1) of IR 2025/486). Respond within the deadline specified in the NCA's request. Failure to respond within the stated period is a ground for rejection on procedural grounds.
Step 7: Receive the NCA Decision Within 120 Days
The NCA issues a decision within 120 days of receiving a complete application. The decision is either approval, with conditions if applicable, or rejection with stated grounds. Approval results in a CBAM account being created in the EU CBAM Registry, a CBAM account number being assigned, and authorization details being recorded in the Registry.
Grounds for rejection include serious customs violations in the prior 5 years, criminal convictions for tax fraud or environmental offenses, active insolvency proceedings, and failure to provide complete documentation. The rejection decision must state the specific grounds.
Step 8: If Approved, Access the CBAM Registry and Begin Compliance
After authorization, the NCA activates the CBAM account in the Registry. The account holds the authorization details, import transaction records (automatically populated from customs data via IR 2025/2619), certificate holdings, and declaration history. Certificate purchases begin February 1, 2027 through the national competent authority platform. The first annual CBAM declaration is due September 30, 2027, covering all calendar year 2026 imports. The CBAM declaration page covers the full content requirements and calculation methodology for the annual submission.
Caption: The CBAM Registry account activated after authorization holds import records, certificate holdings, and the annual declaration submission module.
What Documents Are Needed for CBAM Authorization?
The complete documentation list for a CBAM authorization application under IR 2025/486 is summarized in the table below.
| Document | Purpose | Source |
|---|---|---|
| EORI number | Links application to customs identity | EU Customs Trader Portal |
| Company registration | Proves EU establishment | National business registry |
| VAT / tax identification number | Links to tax compliance history | National tax authority |
| Audited financial statements (2–3 years) | Demonstrates financial solvency | Company accounts / auditor |
| Bank guarantee (if <2 years established) | Substitutes for financial statements | Bank or financial institution |
| Customs compliance certificate or declaration | Evidences 5-year compliance history | Customs authority |
| CN code and tonnage data for intended imports | Defines scope of authorization | Internal import records |
| Production installation details | Links imports to specific facilities | Supplier contracts / customs data |
| Internal CBAM compliance procedures | Demonstrates operational readiness | Internal document |
| Responsible person identification | Names legal signatory for CBAM compliance | Internal corporate decision |
What Happens After CBAM Authorization Is Granted?
After CBAM authorization, 4 ongoing obligations attach to the authorized declarant status immediately.
Authorization activates 4 compliance obligations from the first import of CBAM goods. First, all import shipments of Annex I goods must be classified with CN code, net mass, country of origin, and production installation details at the time of import. Second, from the first calendar quarter of 2027, the quarterly holding requirement applies: the authorized declarant must hold CBAM certificates equal to at least 50% of cumulative embedded emissions of CBAM goods imported since January 1 of that year. Third, embedded emissions data must be collected from suppliers or, where actual data is unavailable, replaced by default values from IR 2025/2621 with a 10% mark-up in 2026, a 20% mark-up in 2027, and a 30% mark-up from 2028 onward. Fourth, actual emissions data requires third-party verification by an accredited verifier; verifier registration in the CBAM Registry opened September 1, 2026.
Authorization can be revoked if the conditions that qualified the applicant cease to apply: for example, if the company enters insolvency proceedings, is convicted of a relevant offense, or ceases importing CBAM goods. The NCA conducts risk-based inspections under Article 15 and can request any retained document within the 4-year record-keeping period.
For the complete set of ongoing obligations after authorization, the CBAM importers hub consolidates all post-authorization compliance steps, including the quarterly holding workflow, verifier engagement, and declaration filing.
What Happens If a CBAM Authorization Application Is Rejected?
Rejected CBAM authorization applicants have the right to appeal the NCA decision through the administrative or judicial review procedures established in their member state. The grounds for rejection are stated in the NCA decision and must relate to one of the legally defined bases under Article 17 of Regulation (EU) 2023/956 and IR 2025/486.
Can a Rejected Applicant Reapply for CBAM Authorization?
Yes. Rejection does not permanently bar reapplication. Applicants can address the specific grounds for rejection stated in the NCA decision and submit a new application. A new application restarts the 120-day review clock from the date the NCA receives the complete resubmission. However, importing CBAM goods during the period without authorization, including during the appeal or reapplication period, remains subject to the €300 to €500 per tonne penalty. Halting CBAM-covered imports until authorization is secured or continuing only non-CBAM imports is the operationally compliant approach during any gap.
Does CBAM Authorization Expire?
Authorization does not expire on a fixed date under normal circumstances. It remains valid until revoked by the NCA or voluntarily surrendered by the authorized declarant. The NCA reviews compliance on a risk-based basis and can initiate revocation proceedings if conditions change. Maintaining the 5-year clean compliance record, current financial solvency, and updated production installation data in the Registry reduces revocation risk.
How Does CBAM Authorization Relate to the CBAM Registry and Declaration?
Authorization is the gateway to the CBAM Registry account. The CBAM registry operates as the central platform for all certificate and declaration activity, but Registry access is only granted following NCA authorization. Authorization defines the scope of goods the declarant is permitted to import under CBAM; the annual declaration confirms the actual quantities and emissions for that scope. The two processes are sequential: authorization first, then Registry access, then declarations and certificate obligations. Completing the full compliance cycle is covered in the CBAM compliance checklist, which positions authorization as step 2 in the end-to-end importer workflow.