CBAM Certificate Tracker Template 2026 (Free CSV Download)
Reviewed against current law:
General Summary
The CBAM certificate tracker is a CSV worksheet with two tables that produces a running record of how many CBAM certificates an importer needs, holds, surrenders and can sell back. Table 1 lists import lines and the certificates each one requires. Table 2 is a certificate ledger for purchases, quarter-end holdings, surrender, repurchase and cancellation. Finance and compliance teams at authorised CBAM declarants need it from February 1, 2027, when certificate sales start. It opens in Excel, Google Sheets or LibreOffice.
What This Tracker Covers
The tracker covers 25 columns in two tables.
| Table | Column | What it records |
|---|---|---|
| 1 | Product / CN code | The goods line, by CN code |
| 1 | Supplier | Producer or trader that supplied the goods |
| 1 | Country | Country of origin |
| 1 | Route | Production route, for example steel-bf-bof |
| 1 | Annual volume (t) | Net mass imported in the calendar year |
| 1 | Emission factor (tCO2e/t) | Specific embedded emissions, actual or default |
| 1 | Data basis (actual/default) | Which Article 7(2) route the factor comes from |
| 1 | Embedded emissions (tCO2e) | Volume multiplied by the emission factor |
| 1 | Free allocation adjustment (tCO2e) | Article 31 and IR (EU) 2025/2620: CBAM benchmark multiplied by the CBAM factor (97.5% for 2026) and the cross-sectoral correction factor, times the volume. Zero for electricity |
| 1 | Carbon price reduction (tCO2e) | Reduction for a carbon price effectively paid in a third country (Article 9) |
| 1 | Certificates required | Embedded emissions less the free allocation adjustment and the carbon price reduction (Article 6(2)(c)) |
| 1 | Notes | Open points, for example awaiting verified data |
| 2 | Purchase date | Sales start February 1, 2027 (Article 20(1)) |
| 2 | Certificates purchased | Number bought on that date |
| 2 | Price paid (EUR per certificate) | Article 21 price; also the repurchase price (Article 23(3)) |
| 2 | Emissions year covered | Separates certificates for 2026 emissions: quarterly price (Article 21(1a)), repurchase only in 2027 (Article 23(2a)), cancellation on November 1, 2027 (Article 24(2)) |
| 2 | Quarter-end checked | The quarter-end the row reconciles |
| 2 | Embedded emissions since January 1 (tCO2e) | All goods imported since the beginning of the calendar year, determined by default values without the mark-up (Article 22(2)(a)) or by the certificates surrendered for the preceding calendar year (Article 22(2)(b)) |
| 2 | Basis used (Article 22(2)(a) or (b)) | Which of the two bases the figure rests on. Basis (b) needs the same goods by CN code and countries of origin as the preceding declaration |
| 2 | Minimum holding, 50% (Article 22(2)) | At least 50% of those emissions, with the Article 31 free allocation adjustment taken into account. Applies from 2027 |
| 2 | Certificates on account | Balance in the CBAM Registry |
| 2 | Surplus or shortfall | Balance minus the minimum holding |
| 2 | Surrendered (date, number) | Surrender by September 30 for the preceding calendar year (Article 22(1)) |
| 2 | Repurchase requested (date, number) | Request by October 31 of the surrender year (Article 23(1)). Limited to the certificates the declarant had to purchase under Article 22(2) in the year of purchase (Article 23(2)) |
| 2 | Cancellation date (Article 24) | November 1, 2027 for certificates bought for 2026 emissions (Article 24(2)); otherwise November 1 of the second year after the year of purchase (Article 24(1)) |
How to Use It
- Fill Table 1. Enter one row per product, supplier and country, with the annual volume and the emission factor.
- Mark the data basis. Record whether each factor is verified actual data or a default value.
- Calculate certificates. Enter the free allocation adjustment and any carbon price reduction, then subtract both from the embedded emissions to get the certificates required.
- Log purchases. Add a ledger row for every certificate purchase with its date and price.
- Reconcile each quarter. At every quarter-end from 2027, compare the certificates on the account with the 50% minimum holding.
- Close the year. Record the surrender, any repurchase request and the cancellation date of what remains.
What the Regulation Requires Here
Article 22 of Regulation (EU) 2023/956 sets the two numbers this tracker follows: the annual surrender and the quarterly minimum holding.
Certificates are sold from February 1, 2027 (Article 20(1)) and surrendered by September 30 for the preceding calendar year (Article 22(1)). From 2027, the account must hold at the end of each quarter at least 50% of the embedded emissions in all goods imported since the beginning of the calendar year (Article 22(2)).
Article 22(2) determines those emissions by reference to either of two bases: default values without the mark-up, or the number of certificates surrendered for the preceding calendar year, provided the customs declarations refer to the same goods by CN code and countries of origin. The free allocation adjustment of Article 31 is taken into account.
Excess certificates are repurchased on request by October 31, up to the number the declarant had to purchase under Article 22(2) in the year of purchase (Article 23(2)). Certificates bought for 2026 emissions are cancelled on November 1, 2027 (Article 24(2)); later purchases on November 1 of the second year after the year of purchase (Article 24(1)).
Background reading: CBAM certificates guide and quarterly holding requirement. For the mechanism as a whole, start with the EU CBAM overview.
Related templates
- CBAM Cost Model Template 2026 (Free PDF Report)
- CBAM Declaration Checklist Template 2026 (Free PDF Download)
- CBAM Reporting Template 2026 (Free CSV Download)
- All CBAM templates and checklists
Frequently Asked Questions
How many CBAM certificates must be held at quarter-end?
From 2027, at least 50% of the embedded emissions in all goods imported since the beginning of the calendar year (Article 22(2)). Those emissions are determined by reference to either default values without the mark-up, or the number of certificates surrendered for the preceding calendar year where the imports are the same goods by CN code and countries of origin. The free allocation adjustment of Article 31 is taken into account.
What does a CBAM certificate cost?
The official price for Q3 2026 is EUR 82.32 per tonne of CO2e, published October 5, 2026. For 2026 embedded emissions the price is the quarterly average of EU ETS auction closing prices for the quarter of import (Article 21(1a)); for later years it is a weekly average (Article 21(1)).
Can unused CBAM certificates be sold back?
Yes, within the Article 23(2) limit and on request by October 31. Certificates purchased in 2027 for 2026 emissions may only be repurchased in 2027 (Article 23(2a)). What remains is cancelled without compensation under Article 24.
CBAM Brief (EUR 199 a month) emails you when a certificate price, default value, CN code or deadline changes.
This template is a starting point, not an official form, and not legal advice. The binding text is Regulation (EU) 2023/956 and its implementing acts. Content reviewed on October 12, 2026.