CBAM Declaration Checklist Template 2026 (Free PDF Download)
Reviewed against current law:
General Summary
The CBAM declaration checklist is a PDF with 22 tick-box items in 5 sections that produces a printable readiness record for the annual CBAM declaration. An authorised CBAM declarant, or the customs and compliance team working for one, completes it before filing in the CBAM Registry. The sections follow the order of the work: scope, supplier data, calculation and certificates, filing, and the steps after filing. The first declaration covers goods imported in 2026 and is due September 30, 2027.
What This Checklist Covers
The checklist covers 5 sections, each tied to an article of Regulation (EU) 2023/956.
| Section | Items | What you confirm |
|---|---|---|
| 1. Scope and authorisation | 4 | Annex I scope, the 50 tonne threshold, authorised CBAM declarant status, account details |
| 2. Supplier and emissions data | 5 | Installation and operator, actual or default data, verification report, carbon price evidence |
| 3. Calculation and certificates | 7 | Annex IV calculation, free allocation adjustment, certificate number and price, 50% quarterly holding |
| 4. Filing | 3 | September 30 deadline, the four Article 6(2) contents, surrender |
| 5. After filing | 3 | Repurchase request and its cap, cancellation dates, record retention |
How to Use It
- Assign owners. Download the PDF and give each of the five sections a named owner.
- Confirm scope. Check every CN code against Annex I and total the net mass of the year against the 50 tonne threshold.
- Collect supplier data. Send data requests to suppliers and log whether each figure is verified actual data or a default value.
- Calculate the obligation. Work out the embedded emissions, the free allocation adjustment and the number of certificates to surrender for each type of goods.
- File and surrender. Submit the declaration and surrender the certificates in the CBAM Registry by September 30.
- Close out. Request repurchase of excess certificates by October 31 and archive the checklist with the records.
What the Regulation Requires Here
Article 6 of Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, creates the duty this checklist serves.
Each authorised CBAM declarant submits a CBAM declaration through the CBAM Registry by September 30 for the preceding calendar year, for the first time in 2027 for the year 2026 (Article 6(1)). Article 6(2) fixes four contents: the total quantity of each type of goods, the total embedded emissions, the number of CBAM certificates to surrender after the Article 9 reduction and the Article 31 free allocation adjustment, and copies of verification reports where actual emissions are used.
Certificates are surrendered by the same date under Article 22(1). The de minimis exemption in Article 2a removes importers whose goods do not exceed, in the calendar year, the threshold of 50 tonnes of net mass set in Annex VII, point 1. It never covers electricity or hydrogen.
Background reading: CBAM declaration guide and importer compliance checklist. For the mechanism as a whole, start with the EU CBAM overview.
Related templates
- CBAM Reporting Template 2026 (Free CSV Download)
- CBAM Certificate Tracker Template 2026 (Free CSV Download)
- CBAM Internal Audit Checklist Template 2026 (Free PDF Download)
- All CBAM templates and checklists
Frequently Asked Questions
When is the first CBAM declaration due?
September 30, 2027, for goods imported in calendar year 2026. Article 6(1) of Regulation (EU) 2023/956 sets September 30 of the following year as the deadline for every later declaration.
Who has to submit a CBAM declaration?
The authorised CBAM declarant. An importer established in a Member State applies for that status before importing (Article 5(1)); an indirect customs representative holds it for an importer established outside the EU (Article 5(2)). An importer that stays within the 50 tonne threshold is exempt under Article 2a.
Does the checklist cover CBAM certificates?
Yes. It includes the free allocation adjustment of Article 31, the 50% quarter-end holding from 2027 with the two bases Article 22(2) allows, surrender by September 30, the repurchase request by October 31 with its Article 23(2) cap, and the cancellation dates of Article 24.
Is this checklist an official EU form?
No. It is a working document from cbamguide.com. The declaration itself is filed in the CBAM Registry, and the binding text is the regulation.
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.