CBAM 2026: What actually changes for importers?

Everything about the transition from the CBAM transitional phase to the definitive regime: timeline, reporting requirements, financial impact and implementation steps.

Pillar context

The Carbon Border Adjustment Mechanism (CBAM) is no longer a future concern. After two years of transitional phase, 2026 marks the shift to the definitive regime. For European importers of steel, aluminium, cement, fertilisers, electricity and hydrogen, this represents a fundamental change: from quarterly reports without financial consequences to a system with certificate obligations, precise emission calculations and auditable dossiers.

This article walks through the key changes step by step. We cover the timeline, the new reporting requirements, the financial impact and the concrete steps you can take now to prepare your organisation.

The timeline: from transitional to definitive

The transitional phase (2023-2025)

The CBAM transitional phase ran from 1 October 2023 through 31 December 2025. During this period the following obligations applied:

  • Quarterly reports to the competent authority via the CBAM Transitional Registry
  • No financial obligations: no certificates needed to be purchased
  • Default values permitted: importers could use EU benchmarks or CBAM default values when supplier data was unavailable
  • No penalties for minor discrepancies or retroactive corrections

This phase was designed as a learning period. The European Commission collected data, tested the reporting system and gave importers the opportunity to set up their processes.

The definitive regime (from 2026)

From 1 January 2026 the definitive CBAM regime enters into force. The key changes are:

  1. Certificate obligation: importers must purchase CBAM certificates corresponding to the embedded emissions of their imported goods
  2. Authorised declarant status: only registered CBAM declarants may import goods in scope
  3. Annual CBAM declaration: a declaration covering the previous calendar year must be submitted by 31 May each year
  4. Verification obligation: embedded emissions must be verified by an accredited verifier
  5. End of unlimited default values: primary data from producers becomes the standard

What changes in practice?

1. From reporting to financial settlement

The most impactful change is the shift from purely informational reporting to actual financial obligations. Every tonne of CO2 equivalent embedded in imported goods must be covered by a CBAM certificate.

The price of a CBAM certificate is linked to the average closing price of EU ETS emission allowances in the week preceding the sale. In the first months of 2026 this price fluctuated around 65 to 75 euros per tonne of CO2. This means that an importer of 10,000 tonnes of steel with 1.8 tCO2e per tonne needs to reserve a certificate budget of approximately 1.17 to 1.35 million euros per year.

2. Stricter data requirements

During the transitional phase the use of default values was widely accepted. In the definitive regime the bar shifts considerably:

  • Primary data required: installation-specific emission data from the actual producer is the standard
  • Default values as exception: permitted only when it can be demonstrated that primary data is unavailable, and then only the strictest (highest) default values
  • Third-party verification: an accredited verifier must independently assess the emission data
  • Methodological consistency: the calculation method must align with the CBAM regulation and its implementing acts

3. Registration as authorised CBAM declarant

Importers wishing to import goods in CBAM scope must register as an authorised CBAM declarant with the competent authority of their Member State. This registration process includes:

  • Due diligence: the authority checks whether the applicant meets the requirements
  • Financial guarantees: security deposits may need to be posted
  • Ongoing obligations: registration brings annual reporting and certificate obligations
  • Revocation for non-compliance: the status can be revoked for repeated violations

4. Deduction for carbon prices in the country of origin

An important nuance in the definitive regime is the possibility of deducting carbon prices already paid in the country of production. If a steel producer in Turkey already pays a national carbon levy, the EU importer can deduct this amount from the number of CBAM certificates required.

However, this requires:

  • Documented evidence of the carbon price paid
  • Verification that the payment genuinely relates to the imported goods
  • No double-counting risk: the deduction must not lead to double compensation

Financial impact: a realistic estimate

Direct costs

The direct financial impact depends on three variables: the volume of your imports, the embedded emissions per product, and the price of CBAM certificates.

Product group Typical embedded emissions Certificate cost at EUR 70/tCO2e
Steel (hot-rolled) 1.6-2.1 tCO2e/tonne EUR 112-147/tonne product
Aluminium (primary) 6.0-16.0 tCO2e/tonne EUR 420-1,120/tonne product
Cement (clinker) 0.7-0.9 tCO2e/tonne EUR 49-63/tonne product
Fertilisers (urea) 1.5-2.5 tCO2e/tonne EUR 105-175/tonne product

Indirect costs

In addition to certificate costs you should factor in:

  • Verification costs: EUR 5,000 to 25,000 per year depending on complexity
  • System costs: investment in data infrastructure and compliance tooling
  • Personnel costs: expanding the compliance team or hiring specialists
  • Advisory costs: legal and technical advice during initial implementation
  • Opportunity costs: management time spent on CBAM compliance

CBAM certificate price development

The price of CBAM certificates is directly linked to EU ETS auctions. Historically emission allowances rose from around EUR 25 in 2020 to over EUR 90 at the 2023 peak, then stabilised around EUR 60-75. Scenario analyses by market analysts point to a range of EUR 55-100 per tonne for the 2026-2030 period.

For budgeting purposes we recommend a three-tier scenario:

  • Conservative: EUR 80/tCO2e
  • Base: EUR 70/tCO2e
  • Optimistic: EUR 55/tCO2e

Reporting requirements in the definitive regime

The annual CBAM declaration

The core of the definitive regime is the annual CBAM declaration, due by 31 May. This declaration contains:

  1. Total quantity of imported goods per category, expressed in tonnes
  2. Total embedded emissions of those goods, expressed in tonnes of CO2 equivalent
  3. Number of CBAM certificates surrendered to cover the emissions
  4. Verification reports from an accredited verifier
  5. Any deductions for carbon prices paid in the country of origin

Data architecture

To meet the reporting requirements you need a data architecture that can capture and link the following information:

  • Import transactions: HS code, volume, value, country of origin, supplier
  • Installation data: producer, production site, production method
  • Emission data: direct and indirect emissions per installation, calculation method
  • Certificate administration: purchase, inventory, surrender, expiry date
  • Verification dossiers: scope, conclusions, deviations, follow-up actions

Audit trail

A robust audit trail is essential. The competent authority can carry out inspections at any time. Your dossier must show an unbroken line from:

  • Import invoice and customs declaration
  • Through HS classification and supplier identification
  • To installation data and production records
  • All the way to emission calculation and certificate coverage

Implementation steps: a pragmatic roadmap

Step 1: Scope definition and inventory (month 1-2)

Start with a complete inventory of your import portfolio:

  • Which HS codes fall within CBAM scope?
  • What are the annual volumes per product group and supplier?
  • Which suppliers can provide primary emission data?
  • What data gaps exist and how large is the financial exposure?

Step 2: Supplier engagement (month 2-4)

Contact your suppliers and producers:

  • Communicate the CBAM requirements and your expectations
  • Request installation-specific emission data
  • Set deadlines and escalation procedures
  • Consider alternative suppliers for non-responsive parties

Step 3: Registration as authorised declarant (month 2-3)

Start the registration process with your national authority:

  • Gather the required documentation
  • Submit the application
  • Prepare for potential due diligence questions

Step 4: Set up data infrastructure (month 3-5)

Build your data infrastructure:

  • Choose a compliance platform that supports CBAM reporting
  • Connect your ERP system for automatic import of transaction data
  • Set up workflows for supplier data intake and validation
  • Implement an audit trail that records every data change

Step 5: Select a verifier (month 4-5)

Select and contract an accredited verifier:

  • Check accreditation with the national accreditation body
  • Discuss the scope and verification plan
  • Agree on timeline, costs and communication

Step 6: Trial run and optimise (month 5-6)

Execute a trial run of the full process:

  • Draft a concept CBAM declaration based on historical data
  • Have the verifier carry out a pre-assessment
  • Identify bottlenecks and optimise processes

Step 7: Certificate procurement and budget management (ongoing)

Establish a certificate procurement strategy:

  • Spread purchases across the year to limit price risk
  • Monitor the EU ETS market and anticipate price movements
  • Maintain a buffer for unexpected volume increases

Frequently asked questions

What happens if I do not purchase CBAM certificates?

Failing to surrender sufficient certificates results in penalties. The sanction amounts to three times the average certificate price for each missing certificate, plus the obligation to purchase the certificates regardless.

Can I resell CBAM certificates?

Yes, CBAM certificates are transferable. Unused certificates can be sold back to the competent authority. The buyback price equals the original purchase price.

How do I handle suppliers who refuse to provide data?

This is one of the biggest practical challenges. Options include:

  • Using the highest default values (but this maximises your certificate costs)
  • Switching to a supplier who does provide data
  • Collaborating through industry associations to exert collective pressure

What if my HS classification turns out to be wrong?

An incorrect HS classification can lead to under- or over-reporting of embedded emissions. Have your classifications independently reviewed and document the criteria applied.

The role of automation

Manual CBAM compliance is not sustainable for most importers in the long term. The complexity of data collection, emission calculations, certificate management and verification demands automated solutions that:

  • Centrally collect and validate supplier data
  • Automate emission calculations based on current methodologies
  • Monitor certificate positions and generate procurement advice
  • Automatically build audit trails with every data change
  • Generate reports that directly match the CBAM declaration format

Conclusion

CBAM 2026 marks the end of the transitional phase and the beginning of a new era for European importers. The shift from reporting to financial settlement brings significant operational and financial consequences. But with a structured roadmap, timely supplier engagement and the right tooling, it is possible to be compliant without compromising your competitive position.

The key is to act early. Importers who start building their data infrastructure, engaging suppliers and selecting a verifier now will be in a considerably stronger position by 2027 than organisations that wait until the first deadline approaches.

Next step

Request the CBAM impact analysis and receive:

  • A specific estimate of your certificate costs based on your import portfolio
  • A comparison of scenarios (conservative, base, optimistic)
  • A tailored implementation roadmap with concrete milestones and responsibilities

Related articles

Related downloads

Related definitions

  • CBAM: CBAM is the European mechanism linking emissions-related reporting and settlement to imported goods.
  • BOM: A BOM is the bill of materials: the structured composition of a product.
  • Audit trail: An audit trail records who did what, based on which source data, and with what decision logic.