CBAM 2026:
Compliance Requirements Under the EU Carbon Border Adjustment Mechanism
As of 1 January 2026, the definitive phase of CBAM 2026 is in force under Regulation (EU) 2023/956. The transitional reporting period (2023–2025) has ended. Importers of covered goods must now comply with financial and reporting obligations linked to embedded greenhouse gas emissions.
CBAM integrates carbon pricing into EU import procedures, aligning imported goods with the carbon cost applied to EU producers under the EU Emissions Trading System (EU ETS).
What CBAM 2026 Covers
Understanding which sectors and goods are affected is essential for compliance. High-emission goods imported into the EU are now subject to CBAM requirements, and importers must account for their carbon footprint.
CBAM 2026 applies to high-emission sectors considered at risk of carbon leakage. Covered goods include:
- Iron and steel
- Aluminium
- Cement
- Fertilisers
- Electricity
- Hydrogen
The scope is defined through CN codes listed in Annex I of Regulation (EU) 2023/956. Only goods released for free circulation in the EU fall within the CBAM framework.
Authorised CBAM Declarant Requirement
To import CBAM goods, companies must hold the proper authorisation. Being an Authorised CBAM Declarant is not automatic, and timely registration is crucial for uninterrupted imports.
From 2026 onward, only Authorised CBAM Declarants may import CBAM goods into the EU. Obtaining this status requires a formal application via the CBAM AMM Portal, and importers must submit it before their first import or by the end of March to avoid being blocked.
Carbon Complete can manage the application process on behalf of companies, helping gather and submit all required financial, operational, and compliance information so that the application meets CBAM requirements seamlessly.
Annual Reporting and Certificate Surrender
Compliance involves both accurate reporting and the proper surrender of CBAM certificates. Understanding what needs to be reported ensures that importers remain fully compliant.
Authorised declarants must submit an annual CBAM declaration by 31 May each year for imports made during the previous calendar year.
The declaration must include:
- Total quantity of imported CBAM goods
- Verified embedded direct emissions
- Verified embedded indirect emissions, where applicable
- Carbon price effectively paid in the country of origin, if applicable
Following submission, importers must surrender CBAM certificates corresponding to the declared embedded emissions. The number of certificates required reflects verified emissions data and is adjusted where a carbon price has already been paid abroad. Certificate pricing is linked to the weekly average auction price of EU ETS allowances.
Embedded Emissions Calculation
Proper calculation of direct and indirect emissions is key to accurate CBAM reporting and cost management.
Key elements include:
- Direct emissions from production processes
- Indirect emissions from electricity consumption, where required
- Independent verification under accredited bodies
- Default values applied where verified data is unavailable
If verified emissions data is not provided, default values may apply, which may increase certificate liability.
50-Tonne De Minimis Threshold
Smaller importers benefit from exemptions under the 50-tonne annual threshold, which reduces the administrative burden.
Importers introducing less than 50 tonnes per year of covered goods are exempt from:
- Authorisation requirements
- Annual CBAM declarations
- Certificate surrender obligations
This threshold reduces administrative burden for smaller importers while maintaining coverage of the majority of embedded emissions addressed by CBAM.
Cost Exposure and Supply Chain Impact Under CBAM 2026
CBAM introduces direct cost implications linked to carbon intensity, making supplier emissions performance commercially relevant.
Higher verified emissions mean more CBAM certificates must be surrendered. If emissions data is missing or unverified, default values may apply, potentially increasing financial exposure.
Procurement decisions increasingly factor in:
- Verified emissions data
- Production methods
- Transparency and data reliability
CBAM now connects carbon accounting with customs compliance and cost planning. Coordinating customs declarations and CBAM reporting through a single point of contact, with support from its sister company Customs Complete, allows companies to:
- Gain clear visibility of certificate-related costs with aligned import and emissions data
- Ensure accurate reporting, with customs data feeding directly into CBAM submissions
- Reduce compliance risk by preventing mismatches between imported quantities and surrendered certificates
This integrated approach ensures that all CBAM and customs obligations are fully managed, enabling your teams to focus entirely on developing your business, while compliance is handled seamlessly.
Carbon Complete’s Support on CBAM 2026
CBAM compliance requires structured internal processes and technical understanding of emissions methodologies. Carbon Complete supports companies with:
- CBAM Training and Capacity Building: Tailored sessions for management and operational teams to understand CBAM requirements, including how to manage emissions data, calculate certificate obligations, and comply effectively with EU regulations
- CBAM Reporting and Certificate Management: Preparing and verifying annual CBAM declarations, managing certificate obligations, and ensuring alignment with customs data for accurate compliance
- Embedded Emissions Assessment: Evaluating direct and indirect emissions from imported goods and suppliers to provide reliable data for reporting and strategic decision-making
Our focus is on regulatory accuracy, cost forecasting, and improving carbon performance across supply chains, so companies can focus entirely on developing their business.
CBAM 2026 is now an operational regulatory framework. Importers of covered goods must manage verified emissions data, certificate purchasing, and annual declarations as part of routine trade compliance.
Accurate data collection, clear internal processes, and forward cost modelling are essential to maintaining competitiveness in a carbon-priced EU market.
Contact us today to ensure your company is fully prepared for CBAM 2026 and can manage compliance efficiently with Carbon Complete’s integrated reporting, training, and support solutions.
