CBAM entered its definitive phase on 1 January 2026. The transitional reporting period (October 2023 to December 2025) only required quarterly emission reports with no financial obligation. From 2026, you buy certificates and surrender them. The clock is running.
The 2026 CBAM calendar
| Date | Obligation | Who it applies to |
|---|---|---|
| Before first import | Register as authorised CBAM declarant | All importers of CBAM goods above 50 t/year |
| Throughout 2026 | Purchase CBAM certificates as needed to cover expected embedded carbon | All authorised declarants |
| 30 September 2027 | Submit annual CBAM declaration for 2026 imports | All authorised declarants with 2026 imports |
| 30 September 2027 | Surrender CBAM certificates equal to declared embedded carbon | All authorised declarants with 2026 imports |
What the annual declaration requires
The annual CBAM declaration must cover every import of CBAM goods during the calendar year. For each import, you must report the total quantity imported (in tonnes of net mass), the country of origin, and the embedded greenhouse gas emissions per tonne of goods. Emissions can be reported based on actual verified data from the producer, or using CBAM default values published by the European Commission.
The declaration is submitted through the CBAM Registry. You need your annual import data consolidated before submission, which means you should be tracking CBAM-relevant imports throughout the year, not assembling them in April 2027.
Certificate purchasing: how it works in practice
CBAM certificates are denominated in tonnes of CO2 equivalent embedded carbon. You buy them through the CBAM Registry at a price linked to the EU ETS auction price: one quarterly price per quarter in 2026, weekly prices from 2027. Prices fluctuate. You are not required to hold all certificates upfront, but you must have enough to cover what you surrender at the 30 September deadline.
Certificates purchased but not surrendered can be repurchased by the competent authority, up to one third of the total you bought in the year. You cannot carry certificates forward to the next year. This creates a matching obligation: buy enough to cover actual emissions, not more, not less.
Penalties for missing the 30 September deadline
Article 26, Regulation (EU) 2023/956 (CBAM Regulation): where an authorised declarant has not surrendered the required number of CBAM certificates by 30 September, a penalty applies. The base rate is EUR 100 per tonne of CO2 equivalent not covered, with multipliers up to five times that amount depending on duration, gravity, intentional nature, and repetition of the non-compliance. The competent authority may also suspend or revoke authorised declarant status.
The penalty structure makes late surrender expensive. At the base rate of EUR 100 per tonne, with a maximum multiplier of five, each uncovered tonne can cost EUR 500 in penalties. For a mid-size steel importer with 5,000 tonnes of embedded carbon, a missed deadline at maximum multiplier costs EUR 2.5 million in penalties alone, before the obligation to still surrender the certificates.
Penalties for importing without authorised declarant status
If you import CBAM goods without registering as an authorised declarant first, the competent authority can impose penalties for each individual import transaction made without status. These are assessed per shipment, not per year, which makes the accumulation rapid if you have been importing without registering for several months.
There is no grace period for late registration if you were already importing CBAM goods before registering. Dutch Customs takes the view that the obligation arose from the first import, not from the date of registration.
What to do if you have missed a deadline
File the late declaration and surrender the certificates as quickly as possible. The penalty for late compliance is significantly lower than continued non-compliance. Contact the competent authority proactively. In practice, authorities are more likely to apply minimum penalties to companies that self-report and remediate than to those who ignore the obligation until audited.
If the late filing is due to genuine force majeure (a system outage in the CBAM Registry, for example), document it and notify the competent authority in writing immediately. Force majeure provisions exist but are interpreted narrowly.