CBAM has not been delayed. The definitive phase of the Carbon Border Adjustment Mechanism, established by Regulation (EU) 2023/956 and amended by Regulation (EU) 2025/2083, entered into force on January 1, 2026, and every authorized declarant already carries live reporting and financial obligations today. Searches for "is cbam delayed," "cbam postponed," and "cbam 2026 or 2027" spike because CBAM rolls out across several dates at once: the regime started in 2026, the certificate market opens in 2027, the first bill is due in late 2027, a scope expansion is proposed for 2028, and a separate UK mechanism begins on its own 2027 date. This guide separates what is legally in force now from what is merely scheduled or proposed.
Is CBAM Delayed to 2027? The Direct Answer
No, CBAM is not delayed to 2027. The definitive regime began exactly on schedule on January 1, 2026, under Article 36(2) of Regulation (EU) 2023/956, applying to all six covered sectors at once rather than phasing in sector by sector. What shifted, through the October 2025 Omnibus amendment, are two operational dates inside a regime already running: certificate sales, originally planned for January 1, 2026, now start February 1, 2027, and the first annual declaration deadline moved from May 31 to September 30, 2027. Both reschedule steps happen after the regime is already in force; neither delays CBAM's start. The European Commission confirms the definitive period began on January 1, 2026 and has announced no postponement.
What Applies Right Now, in 2026
Five CBAM obligations are already active in 2026, more than a year before certificate sales even open. Knowing which rules bite today, not in 2027, is the difference between a compliant importer and an exposed one.
- Authorized declarant status. Since January 1, 2026, only importers holding authorized status may legally bring covered goods into the EU, or face the elevated penalty below.
- Emissions data collection and record keeping. Declarants must already gather shipment-level and supplier emissions data for every 2026 import, since the first declaration must reconstruct the full calendar year.
- The de minimis threshold test. Importers must track cumulative annual mass against the 50-tonne exemption threshold now, since crossing it mid-year triggers full obligations for that year.
- The €100/tCO2e penalty regime. The harmonized penalty for declarants who fail to cover their emissions is €100/tCO2e; unauthorized importers face €300 to 500/tCO2e, both in force under Article 26 as amended.
- The free allocation offset. Because 97.5% of free EU ETS allocation remains in place in 2026, the net certificate obligation is only 2.5% of gross embedded emissions, even though the reporting obligation is at full strength.
One exception: the quarterly certificate-holding requirement (Article 22(2), as amended by Regulation (EU) 2025/2083) takes effect from 2027, once certificate sales open on February 1, since certificates cannot be held before they exist. 2026 emissions still accrue in full and must be covered in the September 30, 2027 declaration.
4 "CBAM Delay" Myths, Debunked
Four misreadings account for most of the "is cbam delayed" confusion online, each starting from a correct fact and drawing the wrong conclusion from it.
Myth 1: "CBAM Was Postponed From 2026 to 2027"
False. CBAM's definitive phase started on time, on January 1, 2026, and has not moved. The myth confuses the regime's start date with the certificate market's start date. Reporting, authorization, and financial liability all began in January 2026; what starts in 2027 is the certificate-buying mechanism, a downstream step, not the regime's launch.
Myth 2: "The September 30, 2027 Deadline Means CBAM Doesn't Start Until 2027"
False. September 30, 2027 is a filing deadline for 2026 obligations, not a start date. Regulation (EU) 2025/2083 moved the first declaration deadline from May 31 to September 30, 2027, aligned with the September 1, 2026 opening of verifier registration. That declaration still covers calendar year 2026 imports and surrenders certificates for emissions accrued in 2026. Reading the Omnibus's regulatory changes as a delayed launch mistakes a rescheduled deadline for a rescheduled regime.
Myth 3: "UK CBAM Was Delayed"
False. The UK CBAM remains confirmed for January 1, 2027, per HMRC's policy summary, which states plainly that "CBAM will commence on 1 January 2027." Two things get conflated: the UK CBAM is a separate, tax-based mechanism under UK law, so its start is not a delay of EU CBAM at all, and HMRC's secondary legislation remained in technical consultation through mid-2026, pushing registration to Q4 2026 rather than Q3, a timing refinement, not a postponed start date. See the UK CBAM guide and the UK CBAM versus EU CBAM comparison for both systems side by side.
Myth 4: "CBAM Downstream Products Start in 2027"
False. The proposed downstream expansion targets January 1, 2028, and is not yet adopted law. The Commission proposed roughly 180 finished steel and aluminium products, such as fasteners and household appliances, in COM(2025)989. The Council widened that to roughly 200 on June 12, 2026, and Parliament's ENVI committee went further, to roughly 457, on July 6, 2026. None of this is final: trilogues have not started, and the current six-sector scope stays unchanged until a final text is adopted. Full detail is in the CBAM downstream expansion tracker.
CBAM Timeline: What Applies When
The table below separates in-force dates from scheduled and proposed ones, as of July 11, 2026.
| Date | What Happens | Status (as of July 11, 2026) | Legal Basis |
|---|---|---|---|
| January 1, 2026 | Definitive phase begins; reporting, authorization, and penalties active for all 6 sectors | In force | Article 36(2), Reg. (EU) 2023/956 |
| March 31, 2026 | Deadline for provisional authorization applications | Passed | Article 17(7a), Reg. (EU) 2025/2083 |
| September 1, 2026 | Verifier registration opens in the CBAM Registry | Scheduled | DR (EU) 2025/2551 |
| January 1, 2027 | UK CBAM starts (separate, tax-based mechanism) | Scheduled | UK Finance Act 2026 |
| February 1, 2027 | EU CBAM certificate sales begin via the Common Central Platform | Scheduled | Reg. (EU) 2025/2083 |
| September 30, 2027 | First EU CBAM declaration due, covering 2026 imports | Scheduled | Article 6, as amended |
| January 1, 2028 | Proposed downstream expansion (roughly 180 to 457 products, institutions still negotiating) | Proposed, not adopted | COM(2025)989, pending trilogue |
Two patterns stand out. Only January 1, 2028 carries genuine uncertainty; every other date has passed or is fixed in adopted law. And three 2027 dates belong to three separate obligations: UK CBAM's start, EU certificate sales, and the EU's first declaration. Treating "2027" as one event is where most "cbam 2026 or 2027" confusion originates.
Why the "CBAM 2026 or 2027" Confusion Keeps Coming Up
The confusion has one structural cause: CBAM is not one start date, it is five schedules running in parallel: the regime's 2026 launch, 2027 certificate sales, the 2027 first declaration, a proposed 2028 expansion, and a separate 2027 UK start. A source naming only one of these five reads as contradicting a source naming a different one, even when both are accurate.
What Should Importers Do If They Think CBAM Is Delayed?
Five actions protect an importer regardless of which claim they encountered.
- Confirm authorized declarant status now. It has applied since January 1, 2026, and unauthorized imports already carry penalty exposure.
- Keep collecting 2026 emissions data, since the September 2027 declaration needs a full calendar year of records.
- Track cumulative import mass against the 50-tonne de minimis threshold on a rolling basis, not just at year-end.
- Budget for certificate purchases starting February 1, 2027; the 2.5% offset in 2026 does not preview the 2027 cost.
- Check UK CBAM exposure separately for goods moving into Great Britain; it runs on a different legal track.
Frequently Asked Questions About the CBAM Delay Confusion
Is CBAM Delayed to 2027?
No. The definitive phase began January 1, 2026, exactly as scheduled. What moved to 2027 under the Omnibus is certificate sales (February 1) and the first declaration deadline (September 30), both downstream steps in an already-active regime.
Why Did the CBAM Declaration Deadline Move to September 2027?
To give declarants more time to obtain verified emissions data. Regulation (EU) 2025/2083 moved the deadline from May 31 to September 30, 2027, aligning it with the September 1, 2026 opening of verifier registration.
Is CBAM Postponed for Importers Below the 50-Tonne Threshold?
No, the exemption is not a postponement. Importers who stay below 50 tonnes of covered goods per calendar year, excluding electricity and hydrogen, are permanently exempt under the de minimis threshold. Crossing 50 tonnes at any point brings full obligations for that entire year.
Is UK CBAM Delayed?
No. HMRC's policy summary confirms the UK CBAM "will commence on 1 January 2027," with no delay announced. Registration is now expected in Q4 2026 rather than Q3, a technical-consultation refinement that does not affect the January 1, 2027 start date.
Will CBAM's Downstream Expansion Start in 2027 or 2028?
Neither is confirmed; January 1, 2028 is the proposed target, and it is not adopted law. The Commission, Council, and Parliament's ENVI committee back three different product lists, from roughly 180 to 457 items, and trilogue talks had not started as of July 2026. The six-sector scope remains unchanged until a final text is adopted.