Transitional Period
1 October 2023 – 31 December 2025: Quarterly reporting of embedded emissions via the CBAM Transitional Registry. No financial obligations or certificate surrender. Reporting uses actual data where possible; defaults allowed with limits phasing out. Final quarterly CBAM declaration due 31 January 2026.
Definitive Period
From 1 January 2026: Full obligations apply. Only authorised CBAM declarants can import covered goods (if above 50 tonne annual threshold). Annual reporting, verified emissions data mandatory (otherwise defaults must be used), purchase of CBAM certificates from 2027 (priced on EU ETS averages: quarterly in 2026, weekly from 2027). No cashflow obligations in 2026 however, importers must accrue costs through 2026 for purchase of certificates in 2027.
First annual CBAM declaration and certificate surrender: By 30 September 2027 (covering 2026 imports).
Installations should look to undergo pre-verification in 2026 with subsequent verification over the calendar year 2026 data in early 2027 to meet the above timelines.
Phase-in alignment: CBAM ramps up as EU ETS free allowances phase out (full by ~2034).
Key updates from 2025 simplifications
A de minimis threshold exempts low-volume importers (below 50 tonnes of CBAM goods imported). Scope remains iron/steel, aluminium, cement, fertilisers, electricity, hydrogen - but the December 2025 anti-circumvention proposal suggests highly likely expansion to certain downstream products (e.g., steel/aluminium-intensive goods) from 2028, plus stronger anti-circumvention rules.
A note on deadlines
CBAM rules evolve via implementing/delegated acts (major package adopted December 2025). Monitor European Commission updates and your national competent authority for changes to methodologies, defaults, or scope.