To submit an application to the EU NCA in your country to become an authorised declarant, please access the EU's portal here.
The EU Commission recently released guidance on becoming an Authorised CBAM Declarant, but like all EU Commission publications, it’s difficult to parse. Here, we’ve simplified the guidance, explaining what steps businesses need to take to become Authorised CBAM Declarants, key compliance considerations, and what to do before the January 1, 2026 deadline, when CBAM officially comes into full effect.
Why do importers need Authorised CBAM Declarant status?
CBAM’s goal is to prevent carbon leakage—ensuring that emissions-intensive production does not simply shift to regions with weaker environmental regulations. By requiring importers to hold an Authorised CBAM Declarant status, the EU is ensuring that only verified entities can manage CBAM certificate purchases, emissions reporting, and compliance monitoring.
Failure to obtain this status will result in import restrictions for covered goods, effectively barring non-compliant businesses from selling into the EU.
How to become an Authorised CBAM Declarant
The application process has five key steps, outlined in Commission Implementing Regulation (EU) 2025/486:
1. Submit an application
Businesses must apply electronically via the CBAM registry in the EU Member State where they are established. The application must include:
Company details (legal name, registered address)
EORI number (Economic Operators Registration and Identification number)
Estimated import volumes of CBAM-covered goods
Proof of financial and operational capacity to comply with CBAM obligations
For companies not based in the EU, applications must be submitted through a representative authorised to act on their behalf within an EU Member State.
2. Application review and additional information requests
Authorities will have up to 120 days (or 180 days for applications submitted before June 15, 2025) to review the submission.
If additional details are required, businesses may receive an extension of up to 30 additional days.
During this period, applicants may also adjust submitted information if necessary, provided justification is given.
3. Compliance checks & risk assessment
Applicants must demonstrate:
Financial stability (no ongoing bankruptcy proceedings, ability to pay CBAM certificate costs)
Legal compliance (no history of serious or repeated tax/customs infringements)
Administrative capacity (sufficient internal controls to manage CBAM declarations)
To demonstrate these qualities, you’ll need:
An administrative organisation that can fulfill the estimated obligations for CBAM certificates
Internal controls that can prevent, detect, and correct errors in CBAM declarations and identify and prevent illegal/irregular transactions
You’ll also need to establish key internal documents and processes, including:
Standard Operating Procedures
Mechanisms to calculate and determine CBAM liability
Clearly defined roles and responsibilities for managing CBAM declarations, CBAM certificate procurement, reporting, and supplier engagement
Internal controls to identify, manage, and mitigate incorrect, illegal, or irregular transactions
For new businesses or those deemed high-risk, additional guarantees may be required.
4. Decision and authorisation
If approved, the declarant will receive a CBAM account number and be registered in the CBAM database.
If rejected, applicants have the right to appeal.
5. Ongoing compliance & monitoring
Authorised CBAM Declarants must ensure continuous compliance with CBAM rules.
EU authorities may reassess authorisation status at any time.
Non-compliance or major infringements can result in revocation of authorisation.
Key deadlines for importers
March 28, 2025 – CBAM Authorised Declarant applications open
June 15, 2025 – Early application deadline for 180-day review period
March 31, 2026 – Authorised CBAM Declarant application deadline; beyond this date you risk penalties for importing CBAM goods if you fail to obtain the Authorised Declarant Status on retrospective application.
What happens if an application is rejected?
If a company is denied Authorised CBAM Declarant status, it has two options:
Appeal the decision and provide additional supporting documentation.
Reapply with corrected or additional information.
Businesses without authorisation by March 31, 2026, risk penalties on import CBAM-covered goods into the EU should they fail to obtain the authorisation on retrospective application.