CBAM Compliance Timeline
The definitive regime is live. Actual emissions now need robust monitoring, source evidence and independent verification. Here are the dates and thresholds that drive the work.
Last verified: 25 August 2026 — always confirm against official EU sources before acting
Definitive regime live
The authorised declarant regime and financial obligations begin. CBAM moves from a transitional reporting exercise to an operating requirement.
Authorisation threshold
EU importers above a single mass-based threshold of 50 tonnes per calendar year must hold authorised CBAM declarant status. Authorisation applications were due before 31 March 2026, with importing permitted while a decision was pending. Hydrogen and electricity are handled separately.
Certificate sales open
CBAM certificates covering 2026 obligations become purchasable through a common central platform. Pricing is based on EU ETS allowance auction prices — a quarterly average in 2026, moving to a weekly average from 2027.
First declaration + surrender
The first annual declaration covers 2026 imports, with corresponding certificate surrender due the same day. This reflects a four-month extension from the originally planned 31 May 2027 deadline.
Penalty for non-surrender
A penalty of €100 per tonne applies to uncompensated emissions where required certificates are not surrendered. Paying the penalty does not discharge the underlying obligation to surrender the outstanding certificates.
What these dates mean operationally
Actual vs. default values is now a business decision
Where actual emissions are used rather than default values, the non-EU installation operator must provide verified emissions data. That shifts the data burden upstream into factories and suppliers — which is why evidence readiness at the production site, not just filing capability at the importer, determines what figure ends up on the declaration.
Evidence is collected long before it is filed
A declaration due in September 2027 rests on operational documents generated throughout 2026 — electricity bills, fuel invoices, production logs and supplier declarations. Evidence that was never captured at the time is difficult to reconstruct afterwards, which makes the collection workflow the real deadline, not the filing date.
Verification requires traceability, not just numbers
Reported emissions data is subject to verification by accredited verifiers. A number that cannot be traced back to its source document, calculation logic, assumptions and review history is hard to defend under review — regardless of whether it is correct. More on audit-ready data →
CBAM timeline FAQ
The CBAM definitive regime applies from 1 January 2026. This marked the shift from the transitional reporting period to an operating regime carrying authorisation requirements and financial obligations.
A single mass-based de minimis threshold of 50 tonnes per calendar year applies. EU importers of CBAM goods above this threshold require authorised CBAM declarant status. Hydrogen and electricity are treated separately from the mass-based threshold.
CBAM certificate sales open on 1 February 2027 via a common central platform. Certificates are purchased by authorised CBAM declarants from the national competent authority in their EU country of establishment. Certificate pricing is based on EU ETS allowance auction prices — as a quarterly average in 2026 and a weekly average from 2027 onwards.
The first annual CBAM declaration covers 2026 imports and is due by 30 September 2027. Certificate surrender is due on the same date. This deadline reflects an extension from the originally planned 31 May 2027 date, granting an additional four months.
A penalty of EUR 100 per tonne applies to uncompensated emissions where required certificates are not surrendered. Paying the penalty does not remove the obligation to surrender the outstanding certificates.
Actual emissions are installation-specific figures derived from real operational data at the production site. Default values are fallback figures applied where verified actual data is unavailable. Because defaults are set conservatively, using them generally results in a higher emissions figure — and therefore a larger certificate obligation — than well-evidenced actual data. Using actual values requires the non-EU installation operator to provide verified emissions data.
Sources
- European Commission — CBAM definitive regime
- DEHSt — CBAM definitive regime from 2026 (authorisation guidance)
- Regulation (EU) 2023/956 as amended, including the CBAM simplification / Omnibus amendments
This page is provided for general information and reflects our reading of publicly available EU guidance as at the date above. CBAM rules continue to be amended — it is not legal or compliance advice, and you should confirm current requirements against official EU sources or your own advisors before acting.
See how CBAM Copilot handles the evidence behind these deadlines — for exporters and for EU importers and verifiers.