EU CBAM Authorised Declarant
Who Must Register, How to Apply, and Stay Compliant Under the Definitive Regime (2026–2027 Guide)
The Executive Compliance Guide to Registration, Authorisation, and Ongoing Regulatory Obligations Under the EU CBAM Definitive Regime
Scope and Disclaimer
This report is produced by CBAM Journal, operated by Sekason Research Limited (Company No. 14339910), London. It is intended for informational purposes only. Nothing in this report constitutes legal, financial, investment, engineering, or safety-certification advice. Readers should obtain independent professional advice before acting on any information contained herein.
Where company-claimed figures are referenced, they are labelled as such. No endorsement of named companies, products, or services is intended or implied. Readers should not rely solely on this report in making compliance, commercial, or regulatory decisions.
Regulatory guidance in this field is subject to change. Readers are responsible for verifying current requirements with the European Commission, relevant National Competent Authorities, and their own legal advisers.
1. Executive Summary
This report consolidates the complete compliance lifecycle into a single operational reference for Compliance Managers: eligibility determination, the AMM application process, ongoing certificate and reporting obligations, enforcement powers of National Competent Authorities, sector-specific data challenges, and a 90-day action plan. It draws on Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, Commission Implementing Regulation (EU) 2025/486, and Commission guidance published through July 2026.
The UK CBAM commences separately on 1 January 2027 under Finance Act 2026 and does not create an equivalent Authorised Declarant mechanism. Organisations trading in both jurisdictions must operate two distinct compliance programmes and cannot apply EU authorisation to UK obligations.
Item | Detail |
Legal Basis | Regulation (EU) 2023/956 (as amended by Reg. (EU) 2025/2083), Arts. 4–9, 20–22; Implementing Regulation (EU) 2025/486 |
Registration Required From | 1 January 2026 |
Application Route | CBAM Registry Authorisation Management Module (AMM) — opened 31 March 2025 |
Annual Mass Threshold | More than 50 tonnes of CBAM goods per year (single mass-based threshold) |
First Declaration Deadline | 30 September 2027 (covering 2026 imports) |
Quarterly Certificate Holding | ≥50% of expected embedded emissions at end of each quarter (from 2027) |
Annual Certificate Surrender | 30 September each year — first surrender: 30 September 2027 |
Record Retention | Until end of fourth year after the declaration year (Art. 9) |
Key Risk | Import prohibition; administrative penalties; suspension or revocation of Authorised Declarant status |
UK Position | No equivalent Authorised Declarant regime — UK CBAM is a domestic tax administered by HMRC from 1 January 2027 |
2. Regulatory Context
2.1 Why the EU Created the Authorised CBAM Declarant
FINDING: Regulation (EU) 2023/956, in force from 1 January 2026, designates the Authorised CBAM Declarant as the sole legal entity permitted to import covered goods into the EU customs territory under the definitive regime (Article 4).
SO WHAT: Any importer without this status cannot lawfully import steel, aluminium, cement, fertilisers, hydrogen, or electricity into the EU — import prohibition is the immediate consequence, not a fine that can be absorbed into operating costs.
NOW WHAT: Importers must determine their eligibility and submit an application through the AMM immediately — the definitive regime obligation under Article 4 applies from 1 January 2026, and every import of covered goods without authorisation after that date is a potential infringement.
The EU CBAM was established to prevent carbon leakage — the risk that carbon-intensive production migrates to jurisdictions with weaker climate policy, undermining EU decarbonisation targets while retaining access to the EU market. By requiring importers of carbon-intensive goods to pay a carbon price equivalent to what EU producers pay under the EU Emissions Trading System (EU ETS), the regulation levels the competitive playing field without imposing trade barriers that would conflict with WTO obligations.
The Authorised Declarant mechanism is the regulatory instrument that operationalises this objective. Customs authorities enforce it at the point of import: covered goods cannot cross the EU border unless the importer holds current Authorised Declarant status, in the same way that excise goods require a licensed trader. The mechanism places carbon pricing responsibility on EU-based compliance teams, not on overseas suppliers — making the compliance function, not the logistics function, the primary regulatory actor.
Phase | Period | Mechanism | Importer Obligation |
EU ETS (domestic) | Ongoing | EU producers purchase ETS allowances | No import obligation — domestic producers only |
CBAM Transitional | Oct 2023 – Dec 2025 | Quarterly embedded emissions reporting | Report only — no certificates, no authorisation required |
CBAM Definitive | 1 Jan 2026 onwards | Full financial obligation — certificates and authorisation | Must hold Authorised CBAM Declarant status before importing |
2.2 Legal Framework Governing Registration
FINDING: Commission Implementing Regulation (EU) 2025/486, adopted on 17 March 2025, establishes the specific conditions and procedures for obtaining, maintaining, suspending, and withdrawing Authorised CBAM Declarant status.
SO WHAT: Registration is a structured legal process governed by specific eligibility criteria — including financial standing and compliance history — not an open self-registration accessible to any importer on request; importers with a record of customs or tax infringements may face rejection.
NOW WHAT: Compliance Managers must review both Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/486 before initiating the application — failure to meet the eligibility conditions set out in the Implementing Regulation will result in rejection by the National Competent Authority with no provisional import right during the review period.
Four legal instruments govern the Authorised Declarant regime in its current form:
Legal Instrument | Date | Role in Authorised Declarant Framework |
Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 | 10 May 2023; amended 20 Oct 2025 | Primary legislation. Articles 4–9 establish the Authorised Declarant requirement, application process, annual declaration obligations, and record-keeping rules. Articles 20–22 govern certificate purchase, holding, and surrender. Regulation (EU) 2025/2083 reduced the quarterly holding threshold from 80% to 50% and introduced the 50-tonne de minimis threshold. |
Commission Implementing Regulation (EU) 2025/486 | 17 March 2025 | Sets eligibility conditions (financial standing, compliance history), application procedures, approval process, monitoring, suspension, and revocation by NCAs. |
National Competent Authorities (NCAs) | Designated per member state | Each EU Member State designates an NCA responsible for receiving applications, conducting due diligence, granting authorisation, and exercising enforcement powers. |
CBAM Registry / Authorisation Management Module (AMM) | Opened 31 March 2025 | The electronic platform through which all applications are submitted. The AMM is the single point of entry for authorisation requests across all EU member states — there is no paper alternative and no national portal substitute. |
The legal hierarchy determines which instrument to consult at each stage. The CBAM Regulation defines what is required; the Implementing Regulation defines how compliance is achieved. For eligibility, documentation, and approval process questions, Implementing Regulation (EU) 2025/486 governs. For post-authorisation obligations — annual declarations, certificate surrender, record-keeping — Articles 6–9 of the CBAM Regulation apply directly.
2.3 EU CBAM vs UK CBAM: Two Different Compliance Models
FINDING: The UK CBAM, which commences on 1 January 2027 under Finance Act 2026, does not establish an Authorised Declarant mechanism, a CBAM Registry, or an Authorisation Management Module — it is structured as a domestic carbon border tax administered through HMRC, not a pre-import authorisation regime.
SO WHAT: Multinational importers trading in both jurisdictions cannot apply their EU CBAM compliance programme to UK obligations — the two regimes have different legal structures, different triggering mechanisms, and different administrative systems, and they must be governed by separate internal compliance programmes.
NOW WHAT: Compliance teams must establish separate governance procedures for EU CBAM and UK CBAM before 1 January 2027, ensuring that EU Authorised Declarant management does not crowd out preparation for the UK HMRC obligation, which carries its own registration and reporting requirements.
Feature | EU CBAM | UK CBAM |
Legal instrument | Regulation (EU) 2023/956 (as amended) | Finance Act 2026, Schedule 17 |
Start date | 1 January 2026 (definitive regime) | 1 January 2027 |
Importer authorisation | Required — Authorised CBAM Declarant status | No equivalent registration/authorisation mechanism |
Administrative system | CBAM Registry / AMM (EU-operated) | HMRC — administered as a domestic tax |
Annual mass threshold | 50 tonnes (single cumulative threshold, all covered goods) | £50,000 of CBAM goods over 12-month rolling period |
First declaration deadline | 30 September 2027 (covering 2026 imports) | To be confirmed by HMRC — see GOV.UK for current guidance |
Certificate mechanism | CBAM certificates linked to EU ETS weekly average price | UK ETS-linked — HMRC mechanism details to be confirmed |
Covered sectors | Steel, aluminium, cement, fertilisers, hydrogen, electricity | Steel, aluminium, cement, fertilisers, hydrogen (electricity not yet confirmed) |
Enforcement authority | National Competent Authorities (per member state) | HMRC |
3. Compliance Obligations
3.1 Who Must Register?
FINDING: Under Regulation (EU) 2023/956 Article 5 as amended by Regulation (EU) 2025/2083, every importer established in an EU Member State that imports more than 50 tonnes of CBAM goods annually must apply for Authorised CBAM Declarant status through the CBAM Registry before importing — this single mass-based threshold applies cumulatively across all covered goods, not per sector or per shipment.
SO WHAT: Importers below the 50-tonne annual threshold are currently exempt from registration, but any business that regularly trades in covered commodities must assess its position conservatively — the threshold aggregates all CBAM goods across all sectors, so an importer active in multiple covered commodities can breach the threshold without exceeding it in any single sector.
NOW WHAT: Every EU-established importer of covered goods must conduct an annual import volume assessment against the 50-tonne threshold before the start of each calendar year, to determine whether Authorised Declarant status is legally required for that year's imports.
Question | Yes | No |
Do you import goods classified under steel, aluminium, cement, fertilisers, hydrogen, or electricity CN codes into the EU? | Proceed to next question | No CBAM obligation applies |
Are you established in an EU Member State as the importer of record? | You must apply for Authorised Declarant status if annual volumes exceed 50 tonnes | You may use an EU-established indirect customs representative who holds Authorised Declarant status |
Do your annual imports of CBAM goods exceed 50 tonnes (cumulative across all covered goods)? | Authorised Declarant registration is legally required | Registration not currently required — monitor volumes annually |
Are you a non-EU importer using an EU-established indirect customs representative? | The indirect customs representative must hold Authorised Declarant status and applies on your behalf | You must establish an EU indirect customs representative before importing covered goods |
Indirect customs representatives — EU-established freight forwarders, customs agents, or brokers acting on behalf of non-EU importers — may apply for and hold Authorised Declarant status. When they do, they assume the full legal obligations of the Authorised Declarant: annual declaration, certificate surrender, and record-keeping. This does not relieve the underlying importer of responsibility for providing accurate embedded emissions data, which must flow from the overseas supplier through the supply chain.
3.2 How the Registration Process Works
FINDING: The Authorisation Management Module (AMM), opened by the European Commission on 31 March 2025, is the sole electronic route for submitting Authorised CBAM Declarant applications — there is no paper process and no national portal alternative to the CBAM Registry.
SO WHAT: An incomplete or inaccurate application will be rejected by the National Competent Authority; the importer cannot lawfully import covered goods until authorisation is granted, meaning any delay in approval directly suspends import operations for covered goods.
NOW WHAT: Importers must prepare all required documentation before opening the AMM application, since incomplete submissions trigger rejection rather than a request for supplementary information from the NCA — preparation must precede submission, not accompany it.
Step | Action | System / Authority | Output |
1 | Determine eligibility: confirm annual import volumes exceed 50-tonne threshold and identify all EU legal entities requiring separate registration | Internal assessment | Eligibility confirmed per legal entity |
2 | Identify the relevant National Competent Authority for each EU Member State of establishment | European Commission NCA list — CBAM Registry page | NCA contact and process requirements confirmed |
3 | Create or access an EU Login account (the Commission's single sign-on portal for all EU digital services) | EU Login (login.ec.europa.eu) | Verified EU Login credentials |
4 | Access the CBAM Registry and navigate to the Authorisation Management Module (AMM) | CBAM Registry (cbam.ec.europa.eu) | AMM application interface accessible |
5 | Prepare all required documentation (see Table 7) | Internal / legal / finance teams | Documentation package complete and ready |
6 | Complete and submit the electronic application through the AMM | AMM — CBAM Registry | Application submitted; NCA reference number generated |
7 | NCA conducts due diligence review against eligibility conditions in Implementing Regulation (EU) 2025/486 | National Competent Authority | NCA review underway — processing time varies by member state |
8 | Respond to any NCA requests for additional information within the specified timeframe | NCA / AMM | Supplementary information submitted |
9 | Authorisation granted or refused by the NCA | National Competent Authority | Authorised CBAM Declarant status confirmed (or refusal notified) in CBAM Registry |
10 | Access CBAM Registry as Authorised Declarant — begin certificate procurement and prepare for annual declaration cycle | CBAM Registry | Full Authorised Declarant operational access |
Implementing Regulation (EU) 2025/486 does not prescribe uniform processing timelines across EU Member States. NCAs conduct independent due diligence reviews under their own administrative procedures. Applicants should contact their NCA directly — contact details are published on the European Commission CBAM Registry page — to establish current processing times before committing import schedules or supplier delivery dates.
Document Category | Detail |
Legal identity | Legal name, EU establishment address, EORI number, VAT registration |
Authorised representative | Identity and authority of the person submitting the application |
Financial standing | Evidence of financial solvency — specific requirements per Implementing Regulation (EU) 2025/486 |
Compliance history | Customs and tax compliance record — a history of infringements may affect eligibility or trigger additional scrutiny |
Import activity | Description of CBAM goods to be imported; estimated annual volumes per sector and CN code |
Indirect customs representative mandate (where applicable) | Written mandate from the non-EU importer authorising the EU representative to act as Authorised Declarant |
3.3 Ongoing Compliance Obligations
FINDING: Under Regulation (EU) 2023/956 Article 6, Authorised CBAM Declarants must submit their first annual CBAM declaration — covering all CBAM goods imported during 2026 — by 30 September 2027, and surrender a corresponding number of CBAM certificates by the same date.
SO WHAT: Missing the 30 September 2027 deadline exposes the importer to administrative penalties determined by their EU Member State and triggers NCA monitoring that could lead to suspension of Authorised Declarant status — cutting off the legal right to import covered goods entirely.
NOW WHAT: Compliance Managers must establish internal reporting systems capable of capturing verified embedded emissions data at shipment level throughout 2026, since the 30 September 2027 declaration covers the full prior calendar year and cannot be reconstructed retrospectively from incomplete records
Period | Obligation | Legal Basis | Key Risk if Missed |
Throughout the year (from 2027) | Maintain quarterly certificate holdings representing at least 50% of expected embedded emissions at end of each quarter | Art. 22(2), Regulation (EU) 2023/956 as amended by Reg. (EU) 2025/2083 | NCA regulatory intervention; potential suspension of Authorised Declarant status |
Throughout the year | Collect verified embedded emissions data from suppliers for each import shipment | Art. 6, Regulation (EU) 2023/956 | Default values applied — structurally higher certificate cost than importers using actual emissions data |
Throughout the year | Retain records supporting emissions data, carbon pricing evidence, and verification documentation | Art. 9, Regulation (EU) 2023/956 | Audit non-compliance; penalty risk on NCA inspection |
By 30 September annually (first: 2027) | Submit annual CBAM declaration covering quantities imported, embedded emissions, verified emissions, and certificates to be surrendered | Art. 6, Regulation (EU) 2023/956 | Administrative penalties; NCA enforcement action |
By 30 September annually (first: 2027) | Surrender CBAM certificates equal to total embedded emissions declared | Arts. 20–22, Regulation (EU) 2023/956 | Enforcement action; potential revocation of Authorised Declarant status |
Until end of fourth year after declaration year | Retain all compliance records — records for 2026 imports must be kept until end of 2031 | Art. 9, Regulation (EU) 2023/956 | Audit exposure; penalties on NCA inspection |
3.4 Governance Responsibilities
FINDING: Commission Implementing Regulation (EU) 2025/486 defines legal obligations at the entity level but does not prescribe internal governance — the regulation specifies what must be done, not which organisational function must own each obligation.
SO WHAT: Without defined ownership, CBAM obligations fall into gaps between Compliance, Customs, Finance, and Procurement teams — the most common failure mode in trade compliance programmes where multi-function coordination is required but never formally assigned.
NOW WHAT: Executive-level ownership of the CBAM programme must be assigned and documented before commencing imports under the definitive regime, with formal accountability in place before the 30 September 2027 declaration deadline.
Obligation | Accountable | Responsible | Consulted | Informed |
Authorised Declarant application and renewal | Head of Compliance / CCO | Compliance / Customs team | Legal, Finance | Board / CFO |
Annual CBAM declaration preparation and submission | Head of Compliance | Compliance + Finance | External verifier, Legal | CFO, Board |
CBAM certificate purchase and quarterly balance management | CFO / Finance Director | Treasury / Finance | Compliance | Board |
Embedded emissions data collection from suppliers | Head of Procurement / Supply Chain Director | Procurement | Compliance, Sustainability | Finance |
Verifier appointment and verification management | Head of Compliance | Compliance | Legal | CFO |
Record retention and audit readiness | Head of Compliance / Legal Counsel | Compliance | Finance, Customs | Audit Committee |
Monitoring regulatory updates and implementing changes | Head of Compliance | Compliance / Legal | Finance, Procurement | Board |
4. Key Dates and Deadlines
4.1 Complete Compliance Timeline
FINDING: The EU CBAM definitive regime commenced on 1 January 2026 under Regulation (EU) 2023/956, and the first annual declaration and certificate surrender deadline falls on 30 September 2027 — an implementation window of under 21 months from regime start to first financial settlement.
SO WHAT: Organisations that deferred preparation during the transitional phase (October 2023 – December 2025) now face a compressed timeline in which authorisation, supplier data collection, embedded emissions verification, and certificate procurement must all be operational before 30 September 2027.
NOW WHAT: Compliance Managers must complete an internal project plan mapped to the statutory milestones below and present it to the CFO and Board by the end of Q3 2026 at the latest, to secure budget and resource allocation for the first full declaration cycle.
Date | Milestone | Legal Basis | Action Required |
1 October 2023 | CBAM transitional regime begins — quarterly emissions reporting only, no financial obligation | Reg. (EU) 2023/956; Implementing Reg. (EU) 2023/1773 | Historical — transitional reporting should now be completed |
17 March 2025 | Implementing Regulation (EU) 2025/486 adopted — Authorised Declarant eligibility conditions published | Reg. (EU) 2025/486 | Review eligibility conditions and begin documentation preparation |
31 March 2025 | CBAM Registry Authorisation Management Module (AMM) opens for applications | European Commission announcement | Submit application immediately if not yet done |
20 October 2025 | Regulation (EU) 2025/2083 in force — quarterly holding reduced to 50%; 50-tonne de minimis threshold introduced | Reg. (EU) 2025/2083 | Update internal compliance parameters to reflect 50% quarterly holding and 50-tonne threshold |
1 January 2026 | CBAM definitive regime starts — import of covered goods prohibited for non-Authorised Declarants | Art. 4, Reg. (EU) 2023/956 | Must hold Authorised CBAM Declarant status before this date to continue importing |
7 January 2026 | Over 12,000 applications submitted; over 4,100 authorisations already granted | European Commission implementation update | If not yet authorised, application is urgently overdue |
Throughout 2026 | Quarterly certificate holding monitored at ≥50% of expected embedded emissions (obligation commences 2027, but planning starts now) | Art. 22(2), Reg. (EU) 2023/956 as amended | Establish certificate monitoring and procurement process |
30 June 2026 | Commission publishes new verification rules for embedded emissions | European Commission — June 2026 guidance | Update verification arrangements to comply with new rules; confirm verifier meets updated accreditation standards |
6 July 2026 | Q2 2026 CBAM certificate price published | European Commission — CBAM Communication and News | Use for certificate cost planning for 2026 imports |
30 September 2027 | First annual CBAM declaration due; first certificate surrender deadline — covers all 2026 imports | Art. 6, Reg. (EU) 2023/956 | File declaration; surrender certificates covering all 2026 embedded emissions |
1 January 2027 | UK CBAM commences under Finance Act 2026 (no Authorised Declarant equivalent) | Finance Act 2026 | Separate UK HMRC compliance programme required |
4.2 Critical Deadlines Compliance Managers Cannot Miss
FINDING: The AMM opened on 31 March 2025, and by 7 January 2026 — nine days into the definitive regime — more than 4,100 authorisations had been granted to importers who applied early, demonstrating that NCA processing is operational but that late applications carry direct import risk.
SO WHAT: Every import of covered CBAM goods from 1 January 2026 without Authorised Declarant status is a potential infringement of Article 4 of Regulation (EU) 2023/956 — each shipment is a separate potential infringement, not a single cumulative event.
NOW WHAT: Any importer that has not yet submitted an AMM application must do so immediately — the Article 4 obligation is current, and each week of delay represents further potential infringement exposure that compounds rather than caps.
Deadline | Obligation | Consequence of Failure |
Immediate (if not yet applied) | Submit Authorised CBAM Declarant application through AMM | Every import of covered goods without authorisation is a potential infringement of Art. 4 |
Throughout 2026 / from 2027 | Maintain ≥50% quarterly certificate holding at each quarter end | NCA regulatory intervention; potential suspension of Authorised Declarant status |
Throughout 2026 | Collect verified embedded emissions data at shipment level | Default values applied at declaration — structurally higher certificate cost |
30 September 2027 | Submit annual CBAM declaration for all 2026 imports | Administrative penalties; NCA enforcement action; potential import prohibition |
30 September 2027 | Surrender CBAM certificates covering 2026 embedded emissions | Enforcement action; potential revocation of Authorised Declarant status |
Until end of 2031 | Retain records for 2026 imports (four-year retention under Art. 9) | Audit non-compliance; penalty risk on NCA inspection |
5. Financial Exposure and Compliance Risk
5.1 Financial Consequences of Failing to Register
FINDING: Under Article 4 of Regulation (EU) 2023/956, only Authorised CBAM Declarants may import covered CBAM goods into the EU customs territory from 1 January 2026 — import prohibition is the direct legal consequence of non-registration, not merely a financial penalty that can be absorbed into operating costs.
SO WHAT: Import prohibition is a compound risk: it disrupts supply chains, breaches procurement contracts, damages customer relationships, and — where the importer subsequently applies but the NCA identifies prior infringements — may impose additional conditions on the authorisation or increase regulatory scrutiny going forward.
NOW WHAT: Before entering into any procurement contract for delivery of CBAM goods into the EU after 1 January 2026, every importing entity must confirm Authorised Declarant status is current and in good standing with the relevant NCA.
Risk | Likelihood | Business Impact | Mitigation |
Importing without Authorised Declarant status (Art. 4 infringement) | High for late applicants | Severe — import prohibition; NCA enforcement action; each shipment is a separate infringement | Apply immediately through AMM if not yet authorised |
Application rejected by NCA | Medium | High — import operations unlawful until successful re-application; processing delay adds to infringement exposure | Pre-application compliance review; address any customs/tax infringement history before applying |
Missing 30 September 2027 annual declaration deadline | Medium | High — administrative penalties; intensified NCA monitoring | Establish internal reporting calendar now; assign accountable function by Q4 2026 |
Incorrect embedded emissions reporting | Medium | High — certificate shortfall; potential penalties; reputational exposure | Appoint Commission-accredited verifier consistent with June 2026 verification guidance |
Quarterly certificate holding falls below 50% | Medium | High — NCA regulatory action; potential suspension of Authorised status | Monthly monitoring of certificate balance against projected imports |
Authorised Declarant status suspended or revoked | Low (compounds above risks) | Severe — import operations cease; contractual obligations breached; re-application required | Treat authorisation as a regulated licence requiring active and continuous maintenance |
5.2 Enforcement Powers of National Competent Authorities
FINDING: Commission Implementing Regulation (EU) 2025/486 establishes the full regulatory lifecycle for Authorised Declarant status, including NCA powers to grant, monitor, suspend, and revoke authorisation — status is a regulated licence, not a permanent administrative registration.
SO WHAT: An NCA that identifies non-compliance — through monitoring, investigation, or annual declaration review — can suspend or revoke Authorised Declarant status, immediately prohibiting that importer from importing covered goods until the status is restored or re-granted through a fresh application.
NOW WHAT: Every compliance failure that comes to NCA attention is a threat to the legal right to import, not an isolated administrative issue — organisations must treat ongoing compliance as a licence maintenance obligation, not a one-time registration exercise.
Stage | NCA Action | Importer Consequence | Legal Basis |
Application | Reviews eligibility against conditions in Implementing Reg. (EU) 2025/486 | Authorisation granted or refused | Reg. (EU) 2025/486 |
Ongoing monitoring | Monitors compliance with declaration, certificate, and record-keeping obligations | Compliance failures logged; investigation may be triggered | Reg. (EU) 2023/956, Arts. 6–9; Reg. (EU) 2025/486 |
Investigation | Investigates suspected infringement of Art. 4 or ongoing obligations | Importer required to provide information and evidence | Reg. (EU) 2025/486 |
Suspension | Suspends Authorised Declarant status pending outcome of investigation | Import of covered goods prohibited during suspension period | Reg. (EU) 2025/486 |
Revocation | Revokes status for serious or persistent infringement | Permanent loss of status — re-application required; prior infringement recorded and may affect re-application | Reg. (EU) 2025/486 |
Appeal | Importer may appeal NCA decision under national administrative law | Appeal process and timeline varies by member state — no EU-wide standard procedure | National administrative law; Reg. (EU) 2025/486 |
Member States are required by Regulation (EU) 2023/956 to establish penalties that are effective, proportionate, and dissuasive. There is no single EU-wide financial penalty schedule — specific monetary amounts are set at national level. However, Regulation (EU) 2025/2083 introduced a harmonised penalty of €100 per tonne CO₂e for Authorised Declarants who fail to surrender sufficient certificates (Article 26(1) as amended). Compliance Managers operating in multiple EU Member States should establish the applicable national penalty provisions in each jurisdiction of establishment.
5.3 Commercial Risks Beyond Regulation
FINDING: The European Commission's June 2026 factsheet confirmed that default values — applied when suppliers cannot provide verified embedded emissions data — carry a cost mark-up relative to actual values, meaning importers without robust supplier data pipelines pay a structurally higher certificate cost on every tonne of covered goods imported.
SO WHAT: Supply chain disruption is the most operationally significant commercial risk: an importer whose Authorised Declarant status is suspended cannot receive covered goods at the EU border regardless of the contractual obligations in place with overseas suppliers, exposing the importer to breach of contract claims it cannot cure until status is restored.
NOW WHAT: Procurement contracts for CBAM goods delivered into the EU after 1 January 2026 must include provisions confirming Authorised Declarant status, specifying data obligations on the overseas supplier, and allocating CBAM certificate cost risk between the parties — existing contracts without these provisions carry unquantified financial exposure.
6. Sector-Specific Impact Analysis
6.1 Which Sectors Require Authorised Declarant Status?
FINDING: Regulation (EU) 2023/956 applies the Authorised CBAM Declarant requirement to six sectors from 1 January 2026: steel, aluminium, cement, fertilisers, hydrogen, and electricity — all defined at Combined Nomenclature (CN) code level in Annex I of the Regulation.
SO WHAT: The obligation applies at CN code level, not at sector level — some products within a broader commodity category are out of scope, meaning importers cannot assume CBAM applicability from sector membership alone and must map their specific product lines against Annex I.
NOW WHAT: Every importing entity must complete a CN code mapping exercise against CBAM Regulation Annex I before importing, and update that mapping if the product scope is expanded through the Council legislative process that agreed a negotiating position on 12 June 2026.
Sector | Covered Under EU CBAM | Auth. Declarant Required | Embedded Emissions Scope | UK CBAM (from Jan 2027) |
Steel (iron and steel) | Yes — Annex I, Reg. (EU) 2023/956 | Yes — above 50-tonne threshold | Direct emissions (Scope 1); some indirect emissions vary by CN code | Covered — no Authorised Declarant mechanism |
Aluminium | Yes — Annex I, Reg. (EU) 2023/956 | Yes — above 50-tonne threshold | Direct emissions only — indirect/electricity emissions not included under EU CBAM for aluminium | Covered — no Authorised Declarant mechanism |
Cement | Yes — Annex I, Reg. (EU) 2023/956 | Yes — above 50-tonne threshold | Direct emissions; clinker content is the primary driver | Covered — no Authorised Declarant mechanism |
Fertilisers | Yes — Annex I, Reg. (EU) 2023/956 | Yes — above 50-tonne threshold | Direct emissions; nitrogen content central to the calculation | Covered — no Authorised Declarant mechanism |
Hydrogen | Yes — Annex I, Reg. (EU) 2023/956 | Yes — above 50-tonne threshold | Direct emissions; production pathway determines carbon intensity | Covered — no Authorised Declarant mechanism |
Electricity | Yes — Annex I, Reg. (EU) 2023/956 | Yes — above 50-tonne threshold | Dedicated calculation methodology — no single intensity benchmark applies | Included in proposed scope — final confirmation pending |
6.2 Operational Challenges by Sector
FINDING: Regulation (EU) 2023/956 applies the same Authorised Declarant registration requirement across all six covered sectors, but the operational complexity of collecting verified embedded emissions data varies significantly by sector and production pathway — a uniform legal obligation produces materially unequal compliance burdens.
SO WHAT: Importers in sectors with complex or fragmented supply chains — hydrogen and speciality steel in particular — face a higher data collection burden than importers of standardised commodity products from large integrated producers, creating cost divergence within the same regulatory framework.
NOW WHAT: Compliance Managers must conduct a sector-specific data readiness assessment for each covered commodity line before the end of 2026, identifying which supplier relationships can provide verified actual emissions data and which will default to Commission default values in the 30 September 2027 declaration.
6.3 EU vs UK Sector Comparison
FINDING: The UK CBAM commences on 1 January 2027 and covers steel, aluminium, cement, fertilisers, and hydrogen — but does not establish an Authorised Declarant mechanism and is administered by HMRC as a domestic tax instrument, not a pre-import authorisation system.
SO WHAT: Businesses importing covered goods into both the EU and UK face distinct compliance obligations in each jurisdiction that cannot be satisfied by a single compliance programme — EU CBAM requires Authorised Declarant status and a 30 September annual declaration, while UK CBAM requires HMRC engagement under a domestic tax framework.
NOW WHAT: Multinational importers must establish jurisdiction-specific compliance procedures for both regimes before 1 January 2027, the UK start date, and must not assume that EU Authorised Declarant status satisfies any UK CBAM obligation.
Feature | EU CBAM | UK CBAM |
Sector: Steel | Covered from 1 January 2026 | Covered from 1 January 2027 |
Sector: Aluminium | Covered from 1 January 2026 | Covered from 1 January 2027 |
Sector: Cement | Covered from 1 January 2026 | Covered from 1 January 2027 |
Sector: Fertilisers | Covered from 1 January 2026 | Covered from 1 January 2027 |
Sector: Hydrogen | Covered from 1 January 2026 | Covered from 1 January 2027 |
Sector: Electricity | Covered from 1 January 2026 | In proposed scope — final confirmation pending |
Import authorisation | Required — Authorised CBAM Declarant status before import | Not required — no equivalent mechanism |
Annual declaration deadline | 30 September each year (first: 30 September 2027) | To be confirmed by HMRC — see GOV.UK for current guidance |
Administrator | National Competent Authorities (per EU Member State) | HMRC |
Annual mass threshold | 50 tonnes (cumulative across all covered goods) | £50,000 of CBAM goods over 12-month rolling period |
Certificate system | CBAM certificates — EU ETS weekly average price | UK ETS-linked — HMRC mechanism details to be confirmed |
7. Practical Action Framework
7.1 Registration Roadmap
FINDING: The CBAM Registry AMM has been open since 31 March 2025, and by 7 January 2026 more than 4,100 authorisations had been granted to importers who applied before the definitive regime commenced — importers who have not yet applied are importing without authorisation in a regime where every such shipment is a potential Article 4 infringement.
SO WHAT: Each additional import shipment of covered CBAM goods made without Authorised Declarant status is a distinct potential infringement of Article 4 — the risk compounds with each shipment rather than crystallising as a single penalty event.
NOW WHAT: Any importer that has not yet submitted an AMM application must initiate the process immediately, completing all documentation preparation before opening the application to avoid rejection and the additional delay that follows.
7.2 Internal Governance Model
FINDING: Authorised CBAM Declarant obligations under Regulation (EU) 2023/956 span at least six organisational functions — Compliance, Finance, Customs, Procurement, Legal, and Sustainability — and the annual declaration cycle requires coordinated output from all of them by the 30 September deadline each year.
SO WHAT: Organisations without a defined governance model will discover ownership gaps under deadline pressure — the pattern that characterises late-stage compliance failures in trade and environmental reporting regimes where multi-function coordination was assumed rather than assigned.
NOW WHAT: Executive-level ownership of the CBAM programme must be assigned and documented before the end of Q3 2026, with the responsible function delivering the first compliance status report to the CFO and Board before year end 2026 to confirm readiness for the 30 September 2027 declaration.
Function | Primary CBAM Responsibilities |
Compliance / Regulatory Affairs | Owns the Authorised Declarant application and ongoing status. Coordinates annual declaration preparation. Monitors regulatory updates and updates internal procedures. Appoints and manages the Commission-accredited verifier. |
Finance / Treasury | Manages CBAM certificate procurement and quarterly balance monitoring. Accounts for CBAM liability in financial reporting. Provides financial standing documentation for initial application and renewals. |
Customs / Trade Operations | Confirms CBAM applicability for each import shipment at CN code level. Integrates CBAM status checks into import clearance procedures. Liaises with customs brokers and freight forwarders on emissions documentation requirements. |
Procurement / Supply Chain | Leads supplier engagement on embedded emissions data. Integrates CBAM data requirements into supplier onboarding and contract terms. Tracks supplier data quality and escalates gaps to Compliance. |
Legal | Advises on contract provisions for CBAM cost allocation and data obligations. Reviews NCA correspondence and decisions. Manages appeals if enforcement action is initiated. |
Sustainability / ESG | Supports embedded emissions methodology for complex product lines. Contributes to supplier decarbonisation strategy, reducing long-term certificate costs. Aligns CBAM reporting with wider Scope 3 emissions disclosures. |
7.3 Supplier Engagement Framework
FINDING: The Commission's June 2026 factsheet confirmed that default values — applied when suppliers cannot provide verified embedded emissions data — carry a cost mark-up relative to actual values, meaning importers without structured supplier data pipelines pay a structurally higher certificate cost on every tonne of CBAM goods imported.
SO WHAT: Every tonne of covered goods for which the importer uses default values rather than verified actual emissions represents a measurable financial disadvantage relative to an importer with equivalent supply chain but better supplier data — the gap is not a regulatory technicality but a direct operating cost difference.
NOW WHAT: Importers must implement a structured supplier emissions data request process before the end of 2026, targeting all suppliers of covered CBAM goods, to ensure that verified actual emissions data is available for the 30 September 2027 annual declaration.
Stage | Action | Output |
1. Supplier identification | Map all suppliers of covered CBAM goods against CN codes in Annex I of Regulation (EU) 2023/956 | Prioritised supplier list by volume and CBAM sector |
2. Data request issuance | Issue formal embedded emissions data request to each supplier, specifying the required format consistent with Commission methodology | Supplier data request documentation; response tracking established |
3. Supplier capability assessment | Assess each supplier's ability to provide verified actual emissions data versus Commission default values | Gap register: suppliers who can provide actual data versus those who cannot |
4. Verification arrangement | Confirm supplier-provided data meets Commission accredited verification requirements consistent with June 2026 verification guidance | Verifier appointed; verification scope and timeline agreed |
5. Contract update | Update procurement contracts to include: data provision obligations, audit rights over emissions data, CBAM cost allocation clause, representation of importer's Authorised Declarant status | Updated contract template; priority contracts revised |
6. Default value management | For suppliers unable to provide actual data: identify applicable Commission default values and factor the cost mark-up into procurement cost modelling | Default value register; financial model updated |
7. Data validation | Validate received emissions data against Commission methodology before use in annual declaration | Validated data set ready for declaration submission |
7.4 Compliance Readiness Checklist
FINDING: The first annual CBAM declaration and certificate surrender deadline is 30 September 2027, covering all imports of covered CBAM goods made during 2026 under the definitive regime that commenced on 1 January 2026.
SO WHAT: An organisation that reaches September 2027 without collected supplier emissions data, purchased certificates, or an appointed verifier cannot file an accurate declaration — late or inaccurate filing carries administrative penalties and NCA enforcement attention, not an extension of time.
NOW WHAT: Compliance Managers should complete the readiness assessment below by the end of Q4 2026 at the latest, with findings reported to the CFO and Board to allow sufficient time to close gaps before the 30 September 2027 deadline.
# | Check | Status |
1 | *Identified all EU legal entities importing CBAM goods above the 50-tonne annual threshold? | ☐ |
2 | *Each applicable entity submitted an Authorised CBAM Declarant application through the AMM? | ☐ |
3 | *Authorised Declarant status confirmed by the relevant NCA for each entity? | ☐ |
4 | Authorised Declarant status current and in good standing with the NCA? | ☐ |
5 | Dedicated CBAM programme owner assigned at executive level? | ☐ |
6 | RACI matrix documented and communicated across all relevant functions? | ☐ |
7 | *All imported CBAM goods mapped against CN codes in Annex I of Regulation (EU) 2023/956? | ☐ |
8 | Supplier list compiled for all CBAM goods by sector and CN code? | ☐ |
9 | Formal embedded emissions data request issued to all suppliers? | ☐ |
10 | Each supplier's ability to provide verified actual emissions data assessed? | ☐ |
11 | Commission default values identified for suppliers unable to provide actual data? | ☐ |
12 | *Commission-accredited verifier appointed for the annual declaration? | ☐ |
13 | Verifier appointment consistent with June 2026 Commission verification guidance? | ☐ |
14 | *CBAM certificate procurement process established with the NCA or designated authority? | ☐ |
15 | *Quarterly certificate holding monitored against the 50% requirement (from 2027)? | ☐ |
16 | Certificate purchasing integrated into the Treasury financial planning cycle? | ☐ |
17 | Embedded emissions data being collected at shipment level throughout 2026? | ☐ |
18 | Customs import records retained to support the annual declaration? | ☐ |
19 | *Record-keeping system compliant with the four-year retention requirement (Art. 9)? | ☐ |
20 | The 30 September 2027 annual declaration deadline entered into the compliance calendar? | ☐ |
21 | Internal deadline accountability for the 2027 declaration formally assigned? | ☐ |
22 | Existing procurement contracts reviewed for CBAM data and cost provisions? | ☐ |
23 | New procurement contracts updated to include CBAM data obligations? | ☐ |
24 | Customer contracts reviewed for CBAM cost pass-through provisions? | ☐ |
25 | CBAM financial exposure included in the next budget cycle? | ☐ |
26 | UK CBAM obligation (commencing 1 January 2027) scoped separately from EU CBAM? | ☐ |
27 | HMRC UK CBAM registration requirement assessed for applicable entities? | ☐ |
28 | Compliance team monitoring the Commission CBAM Communication and News page for updates? | ☐ |
29 | Council's June 2026 position to strengthen and expand CBAM assessed for future scope impact? | ☐ |
30 | Board or senior leadership CBAM briefing scheduled before end of 2026? | ☐ |
8. Strategic Outlook (2026–2027)
8.1 Expected Regulatory Evolution
FINDING: On 12 June 2026, the Council of the EU agreed its negotiating position to strengthen CBAM, including expansion to selected downstream goods, stronger anti-circumvention rules, and improved enforcement — this position has not yet become law, but signals the legislative direction of the regime through the 2027–2028 period.
SO WHAT: An importer whose compliance programme is calibrated only to the current six-sector scope faces the risk of material revision to both product coverage and enforcement intensity within the planning horizon of current procurement and supply chain decisions.
NOW WHAT: Compliance Managers must design the CBAM governance programme to be scalable — capable of absorbing new sectors or CN codes without a fundamental redesign — and must monitor the Council-Commission legislative process through 2026 and 2027 for confirmation of scope changes.
Development | Status | Potential Impact | Action |
Council position to expand CBAM to downstream goods | Council agreed negotiating position — 12 June 2026. Not yet law. | Material if enacted — additional product lines, potentially wider importer population | Monitor Commission-Council legislative process; assess downstream product exposure now |
Anti-circumvention rule strengthening | Included in Council position — 12 June 2026. Not yet law. | Enhanced NCA scrutiny of import structures and country-of-origin declarations | Review supply chain routing and country-of-origin documentation for potential circumvention risk |
Enforcement improvements | Included in Council position — 12 June 2026. Not yet law. | Higher probability of NCA investigation for importers with compliance gaps | Treat compliance programme as enforcement-ready, not only declaration-ready |
CBAM certificate price trajectory | Q2 2026 price published 6 July 2026; linked to EU ETS — no official forward price published | EU ETS price subject to market movements; certificate cost planning requires scenario modelling | Incorporate EU ETS price scenarios into financial planning for 2027 and beyond |
UK–EU ETS linkage | Industry call — April 2025 (50+ companies and trade groups). No agreement reached. | Linkage would reduce cross-border compliance cost divergence between UK and EU | Do not assume linkage in planning — treat as separate obligations until formally confirmed |
New verification rules | Published 30 June 2026 by Commission | Affects accreditation requirements for verifiers and evidence standards for annual declarations | Confirm appointed verifier meets June 2026 standards; review and update any existing verification arrangements |
8.2 What Compliance Managers Should Do Next
FINDING: The CBAM Registry AMM has been open since 31 March 2025, the definitive regime commenced on 1 January 2026, and the first annual declaration and certificate surrender deadline is 30 September 2027 — fewer than 15 months from the date of this report remain before the first financial settlement event.
SO WHAT: A Compliance Manager without Authorised Declarant status faces three compounding risks simultaneously: ongoing import infringement under Article 4, an accumulating emissions data gap forcing reliance on higher-cost default values in the 2027 declaration, and a certificate procurement shortfall that may not be recoverable before the 30 September 2027 surrender deadline.
NOW WHAT: Authorised Declarant status must be secured immediately if not already in place — every week of delay adds a further week of Article 4 infringement exposure and a further week of embedded emissions data uncollected at shipment level.
Timeframe | Priority Action | Owner | Output |
Week 1 | Confirm Authorised Declarant status for every EU importing entity. If not yet authorised, initiate AMM application immediately and document the submission date. | Head of Compliance | Status confirmed or application submitted with reference number |
Week 1–2 | Brief CFO and Board on CBAM financial exposure: certificate costs, the 50% quarterly holding requirement from 2027, and the 30 September 2027 first declaration deadline. | Head of Compliance + CFO | Board briefing delivered; budget allocation initiated for certificate procurement and compliance programme |
Month 1 | Assign RACI ownership across Compliance, Finance, Customs, Procurement, Legal, and Sustainability using Table 16 as the starting framework. | Head of Compliance | Governance matrix documented, signed off, and communicated across functions |
Month 1 | Issue formal embedded emissions data requests to all suppliers of covered CBAM goods, specifying required format and response deadline. | Head of Procurement | Supplier data requests issued; response tracker established; gap register initiated |
Month 1–2 | Appoint Commission-accredited verifier consistent with June 2026 verification guidance. Agree verification scope, timeline, and fee. | Head of Compliance | Verifier appointed and engaged |
Month 2 | Establish quarterly certificate balance monitoring process. Purchase initial certificates to prepare for the 50% quarterly holding requirement applicable from 2027. | Treasury / Finance | Certificate procurement process operational; monitoring cadence established |
Month 2 | Review and update procurement contracts to include CBAM data obligations, cost allocation clauses, and Authorised Declarant status representations. | Legal + Procurement | Updated contract template adopted; priority existing contracts revised |
Month 3 | Complete the 30-Point Compliance Readiness Assessment (Table 18) and report all open items to the CFO and Board with closure dates. | Head of Compliance | Readiness report delivered; gap closure plan with named owners and dates |
Month 3 | Scope UK CBAM obligation (commencing 1 January 2027) separately and initiate HMRC registration assessment for all applicable entities. | Compliance + Tax | UK CBAM scoping report; HMRC registration timeline confirmed for each entity |
9. Frequently Asked Questions
Q1: Who must register as an Authorised CBAM Declarant under the EU CBAM?
Every importer established in an EU Member State that imports more than 50 tonnes of CBAM goods annually must apply for Authorised Declarant status through the CBAM Registry AMM before importing. Where the importer is not EU-established, an EU-based indirect customs representative — freight forwarder, customs agent, or broker — may hold the status and apply on the importer's behalf, assuming the full legal obligations of the Authorised Declarant. The 50-tonne threshold is cumulative across all covered goods (steel, aluminium, cement, fertilisers, hydrogen, and electricity) — it is not assessed per sector or per shipment.
Key Takeaway: Importers trading across multiple covered sectors must aggregate volumes to determine threshold breach. A business importing 30 tonnes of steel and 25 tonnes of cement in a year exceeds the 50-tonne threshold even though neither commodity exceeds it individually.
Q2: How do I apply for Authorised CBAM Declarant status through the CBAM Registry?
Applications are submitted electronically through the Authorisation Management Module (AMM) within the CBAM Registry at cbam.ec.europa.eu, which opened on 31 March 2025. Applicants must first access EU Login, then navigate to the AMM and complete the application with documentation of legal identity, financial standing, compliance history, and import activity as specified in Implementing Regulation (EU) 2025/486. The application is reviewed by the National Competent Authority for the applicant's EU Member State of establishment — NCA processing timelines vary by member state and applicants should contact their NCA directly for current estimates before committing to import schedules.
Key Takeaway: Prepare all required documentation before opening the AMM application. Incomplete submissions trigger rejection, extending the period of potential Article 4 infringement while a corrected application is prepared and resubmitted.
Q3: Can CBAM goods be imported before the authorisation application is approved?
No. Article 4 of Regulation (EU) 2023/956 prohibits import of covered CBAM goods by any entity that does not hold Authorised Declarant status from 1 January 2026. There is no provisional import right during the NCA review period. The only alternative is to route imports through an EU-established indirect customs representative who already holds Authorised Declarant status and can import covered goods on behalf of the applicant while the application is under review.
Key Takeaway: Build authorisation lead time into import schedules and supplier delivery commitments. Each import of covered goods without authorisation is a potential infringement of Article 4 — NCA enforcement compounds with each shipment, not at year end.
Q4: What documents should be prepared before submitting an AMM application?
Implementing Regulation (EU) 2025/486 requires evidence of legal identity (including EORI number and VAT registration), financial standing, and customs/tax compliance history. Applicants should prepare: legal name and EU establishment address; financial solvency evidence; a compliance history declaration; a description of CBAM goods to be imported with estimated annual volumes; and — where applicable — a written mandate from the non-EU importer authorising the indirect customs representative to act. Organisations with complex group structures must identify every legal entity requiring separate registration before initiating any application.
Key Takeaway: Documentation preparation spans Legal, Finance, and Customs teams. Allow several weeks for preparation before the planned AMM submission date — do not attempt to prepare and submit in the same session.
Q5: What ongoing obligations apply after becoming an Authorised CBAM Declarant?
Authorised CBAM Declarants must: maintain quarterly certificate holdings of at least 50% of expected embedded emissions at each quarter end (from 2027); collect verified embedded emissions data from suppliers at shipment level throughout the year; retain records until the end of the fourth year after the declaration year; submit an annual CBAM declaration by 30 September each year (first: 30 September 2027 for 2026 imports); and surrender CBAM certificates equal to total embedded emissions declared. The Commission published updated verification rules on 30 June 2026 — compliance teams must confirm their appointed verifier meets these updated accreditation and evidence standards.
Key Takeaway: Registration is the legal gateway, not the compliance destination. The annual declaration and certificate surrender cycle is a recurring obligation — the first deadline is 30 September 2027 and it repeats every year thereafter.
Q6: Can one company register multiple EU legal entities under a single Authorised CBAM Declarant registration?
No. Authorised Declarant status is granted to individual legal entities established in an EU Member State, not to corporate groups or parent companies. Each EU legal entity that imports covered CBAM goods above the 50-tonne annual threshold must submit a separate AMM application and obtain separate authorisation from the relevant NCA. A parent company cannot hold Authorised Declarant status on behalf of subsidiary importing entities. Groups with multiple EU importing subsidiaries require separate applications, separate NCA relationships, and separate annual declarations for each authorised entity.
Key Takeaway: Group CBAM compliance requires a centralised governance approach to coordinate separately registered entities — certificate balances, annual declarations, and verifier appointments must be managed at entity level even where group-level oversight is applied.
10. References and Sources
All sources below were used in the preparation of this report. Every regulatory claim, date, and figure is traceable to authoritative primary sources. No fact, date, or figure has been introduced beyond those confirmed in the verified research base.
EU Regulations
European Parliament & Council – Regulation (EU) 2023/956 establishing a Carbon Border Adjustment Mechanism (10 May 2023). Available at: https://eur-lex.europa.eu/eli/reg/2023/956/oj/eng
European Parliament & Council – Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 (CBAM simplification — quarterly holding reduced to 50%; 50-tonne threshold) (17 October 2025; in force 20 October 2025). Available at: https://eur-lex.europa.eu/eli/reg/2025/2083/oj
Official Journal of the European Union – Commission Implementing Regulation (EU) 2025/486 — Conditions and Procedures for Authorised CBAM Declarant Status (17 March 2025). Available at: https://eur-lex.europa.eu/eli/reg_impl/2025/486/oj/eng
Official Journal of the European Union – Commission Implementing Regulation (EU) 2023/1773 (Transitional Phase) (17 August 2023). Available at: https://eur-lex.europa.eu/eli/reg_impl/2023/1773/oj
European Commission Guidance and Communications
European Commission (DG TAXUD) – CBAM Definitive Regime (Updated 2026). Available at: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en
European Commission (DG TAXUD) – CBAM Registry and Reporting — Authorisation Management Module (AMM) Guidance (Updated 2026). Available at: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-registry-and-reporting_en
European Commission (DG TAXUD) – CBAM Registry — List of National Competent Authorities (Updated 2026). Available at: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-registry_en
European Commission (DG TAXUD) – CBAM Legislation and Guidance (Updated 2026). Available at: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en
European Commission (DG TAXUD) – CBAM Communication and News (Q2 2026 certificate price published on 6 July 2026; new verification rules on 30 June 2026; actual vs. default values factsheet issued in June 2026) (Updated 2026). Available at: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-communication-and-news_en
European Commission (DG TAXUD) – Announcement: Commission Implementing Regulation on Authorised CBAM Declarant Conditions (28 March 2025). Available at: https://taxation-customs.ec.europa.eu/news/commission-implementing-regulation-regards-conditions-and-procedures-related-status-authorised-cbam-2025-03-28_en
European Commission (DG TAXUD) – CBAM Successfully Entered into Force on 1 January 2026 — 12,000+ Applications and 4,100+ Authorisations by 7 January 2026 (14 January 2026). Available at: https://taxation-customs.ec.europa.eu/news/cbam-successfully-entered-force-1-january-2026-2026-01-14_en
European Commission (DG TAXUD) – CBAM Transitional Registry Guidance (Updated 2026). Available at: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en
Council of the European Union
Council of the European Union – Council Agrees Position to Strengthen EU CBAM — Expansion to Downstream Goods and Anti-Circumvention (12 June 2026). Available at: https://www.consilium.europa.eu/en/press/press-releases/2026/06/12/council-moves-to-strengthen-the-eus-carbon-border-adjustment-mechanism/
UK Government Sources
HM Treasury – Introduction of a UK Carbon Border Adjustment Mechanism (2024). Available at: https://www.gov.uk/government/publications/introduction-of-a-uk-carbon-border-adjustment-mechanism
HM Treasury – UK CBAM Consultation Response (2024). Available at: https://www.gov.uk/government/consultations/addressing-carbon-leakage-risk-to-support-decarbonisation
GOV.UK – UK CBAM Policy Paper (Updated 2025). Available at: https://www.gov.uk/government/publications/introduction-of-a-uk-carbon-border-adjustment-mechanism
UK ETS Authority – UK Emissions Trading Scheme Guidance (Updated 2025). Available at: https://www.gov.uk/government/collections/uk-emissions-trading-scheme
Market Intelligence
Reuters – Industry Groups and Businesses Call for UK–EU ETS Linkage (30 April 2025). Available at: https://www.reuters.com/sustainability/climate-energy/industry-groups-business-call-britain-eu-link-carbon-markets-2025-04-30/
Reuters – EU Carbon Cost Rules Are Changing: How Companies Can Prepare for CBAM (5 September 2025). Available at: https://www.reuters.com/legal/transactional/eus-carbon-cost-rules-are-changing-how-companies-can-prepare-cbam--pracin-2025-09-05/
European Environment Agency – EU ETS Data and Background (Updated 2026). Available at: https://www.eea.europa.eu/
Carbon Pulse – EU ETS and CBAM Market Intelligence (Updated 2026). Available at: https://carbon-pulse.com
ICIS – EU ETS Carbon Market Coverage (Updated 2026). Available at: https://www.icis.com
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