CBAM Monitoring Plan Template 2026 (Free CSV Download)
Reviewed against current law:
General Summary
The CBAM monitoring plan template is a CSV worksheet that lists the 22 minimum elements of a monitoring plan, one row per element, and produces the skeleton an installation operator completes before verification. Operators of non-EU installations need it when their EU customers declare actual emissions instead of default values. Importers use it to check what a supplier's plan must contain. Each row has space for a description or document reference, the responsible person and the date of the last update.
What This Template Covers
The template covers the 22 minimum elements listed in Annex II, point A.5 of Implementing Regulation (EU) 2025/2547.
| No. | Minimum element of the monitoring plan |
|---|---|
| 1 | Date and version number |
| 2 | Installation and production processes |
| 3 | Goods by CN code and functional unit |
| 4 | CBAM production processes and routes |
| 5 | Non-CBAM goods per process |
| 6 | CBAM benchmarks for the free allocation adjustment |
| 7 | Monitoring methods per production process |
| 8 | Calculation factors and sampling plan |
| 9 | Source streams and emission sources |
| 10 | Streams under the standard or mass balance method |
| 11 | Sources under a measurement-based methodology |
| 12 | Perfluorocarbons from primary aluminium |
| 13 | Diagram and system boundaries |
| 14 | Precursors and their suppliers |
| 15 | Zero-rated fuels |
| 16 | Measurable heat flows |
| 17 | Electricity produced on site |
| 18 | Evidence for actual indirect emissions |
| 19 | Evidence for actual emissions of imported electricity |
| 20 | Waste gases |
| 21 | CO2 capture, storage or use |
| 22 | Control system for data quality |
The file holds the fuller wording of each element in 6 columns, with four identity rows on top: installation, operator, version number and date.
How to Use It
- Identify the installation. Download the CSV and enter the installation, the operator, and the version number and date of the plan.
- Mark what applies. Go through the 22 rows and mark each element as relevant or not. Perfluorocarbons, for example, concern primary aluminium only.
- Describe each method. Write the monitoring method for every relevant element, or reference the document that holds it.
- Write in English. Prepare the final plan in English, the language Article 5(6) requires.
- Hand it to the verifier. Give the plan to the accredited verifier and correct any misstatement or non-conformity it reports.
- Keep it current. Review the methods regularly and record each change under a new version number.
What the Regulation Requires Here
Article 5(5) of Implementing Regulation (EU) 2025/2547 requires operators to design and implement a monitoring plan containing at least the elements in point A.5 of Annex II.
The rule sits in the chapter on actual values, so it applies where embedded emissions are determined from actual emissions under Article 7(2)(a) of Regulation (EU) 2023/956. Article 5(6) requires the plan to be submitted in English. Point A.5 lists 22 minimum elements, from the date and version number to the control system for data quality.
Annex II, point A.2 adds two duties that shape the file: the operator keeps complete and transparent records at the installation for at least six years after the reporting period, and documents every change to the monitoring methodology. A summary of the plan is part of the operator's emissions report under Article 10 and Annex IV. The plan supports the verification of actual emissions under Article 8 of the basic regulation.
Background reading: embedded emissions guide and data requirements for exporters. For the mechanism as a whole, start with the EU CBAM overview.
Related templates
- CBAM Supplier Questionnaire Template 2026 (Free Generator)
- CBAM Internal Audit Checklist Template 2026 (Free PDF Download)
- CBAM Reporting Template 2026 (Free CSV Download)
- All CBAM templates and checklists
Frequently Asked Questions
Is a CBAM monitoring plan mandatory?
Yes, for operators whose goods are declared with actual emissions. Article 5(5) of Implementing Regulation (EU) 2025/2547 says operators "shall design and implement a monitoring plan". Where the importer declares default values, the chapter on default values applies instead.
In which language must the monitoring plan be written?
English. Article 5(6) of Implementing Regulation (EU) 2025/2547 requires the plan to be submitted in English, and Article 10(4) sets the same rule for the operator's emissions report.
How long must monitoring records be kept?
At least six years after the reporting period, at the installation. Annex II, point A.2 of Implementing Regulation (EU) 2025/2547 covers all data relevant for determining embedded emissions, including supporting documents.
Is this the official monitoring plan form?
No. Annex II, point A.5 sets the minimum elements; this worksheet arranges them in rows with abridged wording. Check the final plan against the regulation text.
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.