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.
A draft SOP would look something like the below:
Standard Operating Procedure (SOP): EU CBAM Compliance — Definitive Period
1. Purpose and Scope
This SOP outlines how the organisation will:
calculate and determine CBAM liability;
manage declarations, certificate procurement, reporting, and supplier engagement;
implement internal controls to prevent incorrect, illegal, or irregular CBAM transactions.
It applies to all imports of goods falling under CBAM-covered sectors (e.g. iron and steel, aluminium, cement, fertilisers, electricity, hydrogen, and any expanded scope) entering the EU under our importers or indirect customs representatives.
2. Definitions and Key Principles
CBAM Declarant: the authorised entity registered in the CBAM Registry, responsible for reporting and certificate surrender.
Embedded emissions: the total greenhouse gas emissions (direct and indirect) attributable to the production of the imported product within system boundaries defined by regulation.
Verification: in the definitive regime, emissions data must be verified by an accredited verifier, with an installation visit required unless a waiver applies.
Default values: emission factors published by the European Commission, to be used only where verified supplier data are unavailable and subject to strict limitations under the definitive regime.
CBAM certificate: the tradable instrument that must be surrendered annually to cover the CO₂ equivalent emissions of imported goods.
CarbonChain: a third-party software provider that facilitate sthe measurement and preparation of our CBAM Data management, liability calculations and reporting obligations.
3. Mechanisms to Calculate and Determine CBAM Liability
3.1 Data Collection and Emission Calculation
Obtain Actual Supplier Data
Request, collect and document actual emissions data (activity data, energy consumption, production yields) from non-EU suppliers or installation operators.
Use recognised monitoring systems (continuous measurement, mass balances, emission concentration methods) as prescribed by CBAM methodology.
For indirect emissions (electricity), use supplier-provided data or validated grid emission factors (where applicable).
Data is stored, managed and archived in CarbonChain.
Fallback to Default or Estimated Values (only as permitted)
Only where actual data cannot be obtained, use Commission default values or regional/industry averages, with justification and evidence of attempts to obtain actual data.
Under the definitive period, reliance on default values is heavily restricted; excessive use may expose the declarant to penalties.
This action is automatically performed via CarbonChain.
Calculate Embedded Emissions
Emissions intensity information is extracted from supplier data per CN Code and Product name in order to inform the total emissions imported.
Deduct any carbon costs already paid in the production country (if recognised under CBAM rules), subject to evidence and EU approval.
Verification of Emissions Data
Engage suppliers engage an accredited verifier to conduct verification with reasonable assurance (unless a waiver applies).
Verifier issues a formal verification report certifying the emissions data and any applied adjustments.
Include verification statement as part of CBAM declaration in the Definitive Period.
3.2 CBAM Liability (Certificate Requirement)
Annually, by 30 September, declare the embedded emissions associated with CBAM imports during the previous year and surrender the corresponding number of CBAM certificates.
Quarterly accruals are prepared via CarbonChain in order to ensure appropriate capital is provided for going into 2027.
This accruals will also take place during 2027 in order to ensure that the 50% on account requirement is met.
The number of certificates is equal to tonnes of CO₂e embedded (after deductions) × the price per tonne (quarterly average of EU ETS allowance auctions).
If carbon pricing was already paid abroad, deduct recognised amounts (with acceptable evidence).
Follow official timelines for certificate purchase, surrender, and repurchase, including any simplified procedures under the Omnibus amendments.
4. Roles, Responsibilities and Governance
Role / Function | Responsibilities | Escalation / Oversight |
CBAM Compliance Lead | Overall accountability; oversee registration of CBAM declarant status; maintain SOP; monitor regulatory updates | Reports to Head of Trade Compliance / CFO |
Reporting and Declarations Team | Prepare quarterly and annual CBAM reports; liaise with customs / registry; ensure timely and accurate submissions | Reviewed by Compliance Lead |
Supplier Engagement / Procurement Team | Request and track supplier data; embed emissions disclosure obligations in supplier contracts; support supplier readiness | Escalate non-response or disputes to CBAM Lead |
Data Quality and Verification Team | Perform data checks, reconcile inconsistencies, coordinate with external verifiers | Report anomalies or risks to Compliance Lead |
Finance / Treasury | Manage budget for CBAM certificate purchase; reconcile certificate surrender costs | Coordinate with CBAM Lead for forecasts |
Internal Audit / Risk and Control | Conduct audits, spot checks, review internal controls, and detect potential fraud or non-compliance | Report to Audit Committee / Board |
All staff in these roles must receive CBAM compliance training, including regulatory updates, emissions accounting, and data integrity procedures.
5. Internal Controls, Risk Mitigation and Audit Trail
5.1 Pre-Reporting Controls
Data Validation Checks: automated and manual checks on supplier data for consistency and plausibility.
Justification Logs: maintain written records for any use of estimates or defaults, with evidence of data collection attempts.
Review and Sign-off: all reports must be reviewed and approved by two senior compliance officers before submission.
Change Controls: any modification to calculation tools or templates must go through version control and testing before approval.
5.2 Certificate Procurement Controls
Budget Approval: certificate procurement requires dual authorisation within pre-approved budgets, based on historical accrued amount.
Reconciliation: reconcile surrendered certificates against declared emissions and investigate discrepancies promptly.
Custody and Security: maintain strong access controls to CBAM registry accounts ad CarbonChain platform.
5.3 Supplier and Data Integrity Controls
Supplier review: ensure suppliers undergo verification promptly in order to deliver verified emissions data for the calendar year early the following year.
Contractual Clauses: ensure reference to verification obligations and data retention requirements under EU CBAM in contracts with suppliers.
Escalation: escalate data quality issues or supplier non-cooperation to the CBAM Lead for resolution.
5.4 Post-Submission and Audit Trail
Record Retention: maintain all source data, working papers, verification reports, and correspondence for the regulatory retention period.
Internal Audits: conduct regular internal or external audits of CBAM reporting processes.
Corrective Actions: promptly correct errors and perform root-cause analyses.
Disclosure and Escalation: report any material non-compliance to senior management and the Board.
6. Key Transition and Readiness Steps
Secure CBAM Declarant Authorisation early to ensure timely registration.
Map supply chain emissions and ensure systems can capture and verify emissions data.
Engage accredited verifiers well in advance to guarantee verification capacity.
Model CBAM cost exposure and integrate it into product pricing and financial forecasts.
Monitor evolving EU CBAM rules and Omnibus amendments, updating this SOP as necessary.
Specific NCAs:
Poland is open - NCA guidance here.
Italy is open - NCA guidance here.
Hungary is open - NCA guidance is here.
Spain is open - NCA guidance is here.
Greece is open - NCA guidance is here.