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The CBAM compliance checklist for importers

CBAM compliance comes down to eight steps: confirm your scope, get authorised, access the Registry, gather supplier emissions data, calculate emissions, verify if you use actual values, budget for certificates, and hit the deadlines. This page walks each one and links to the tool or guide you need. DG TAXUD

Last updated · 8 June 2026

TL;DR

  • The sequence: scope → authorisation → Registry → supplier data → emissions → verification → certificates → deadlines.
  • Key dates: 30 September annual declaration and surrender; quarterly 50% certificate holding from 2027.
  • 2026 exposure is small: the CBAM factor is only 2.5% this year, rising toward 100% by 2034.
  • Penalties: €100/t for unsurrendered certificates (you still owe them); 3–5x for importing above the threshold unauthorised.
  • Get the checklist: download the free CBAM Readiness Checklist to work through it offline.
Get the free Readiness ChecklistStart with the scope checker

The eight steps

Your route to CBAM compliance

1

Confirm your scope

Work out whether CBAM applies to you at all: which of the six sectors you import, whether you cross the 50-tonne threshold, and that electricity and hydrogen have no exemption.

Run the scope checker
2

Get authorised declarant status

Above the threshold, only an authorised CBAM declarant may import. Apply, or arrange an indirect customs representative who is the declarant for you.

Who is the declarant?
3

Get CBAM Registry access

Secure your EORI number and access to the CBAM Registry via the EU Customs Trader Portal, where authorisation, declarations and certificates all live.

How the Registry works
4

Collect supplier emissions data

Ask your non-EU producers for installation-level embedded-emissions data in the right format. This is the longest-lead-time task, so start early.

Supplier data templates
5

Calculate embedded emissions

Calculate direct and, where relevant, indirect embedded emissions — choosing between actual values (verified) and conservative, marked-up default values.

Actual vs default values
6

Arrange verification if using actual values

If you use actual values, engage an independent accredited verifier. If you rely solely on default values, verification does not apply.

When you need a verifier
7

Budget for certificates and the factor ramp

Understand the certificate price and the CBAM factor that ramps from 2.5% in 2026 toward 100% by 2034, so 2026 exposure is small but rising.

Certificates and cost
8

Calendar the deadlines

Diary the 30 September annual declaration and surrender, and the quarterly 50% minimum-holding rule that applies from 2027.

See the deadline tracker

What is at stake

The penalties, briefly

€100 / tonne

For each unsurrendered certificate (the EU ETS excess-emissions penalty, indexed) — and you still owe the certificates.

3x – 5x

For importing above the 50-tonne threshold without authorisation, reduced where you exceeded it by no more than 10%.

Regulation (EU) 2023/956. The €100 figure is indexed to inflation and rises annually.

Get the free CBAM Readiness Checklist

A printable, step-by-step version of this page to work through with your team — every task above, in order, with the deadlines built in.

Download the checklist

Why act now even though 2026 cost is small

The definitive regime is live, but the CBAM factor is only 2.5% in 2026, so the money you owe is modest this year. The work, though, is front- loaded: gathering verified supplier emissions data, becoming an authorised declarant (the NCA assessment runs up to 120 days), and setting up Registry access all take time. Doing the groundwork now, while exposure is small, is far easier than scrambling as the factor climbs toward 100% by 2034. DG TAXUD: 2025 simplifications

Diary the dates that matter

Certificate sales open 1 February 2027. The first annual declaration and surrender (for 2026 imports) are due 30 September 2027. From 2027 you must hold certificates for at least 50% of accrued emissions at the end of each quarter. See the full deadline tracker.

FAQ

People also ask

What are the steps to comply with CBAM as an importer?
In order: confirm your scope, get authorised CBAM declarant status, get CBAM Registry access, collect supplier emissions data, calculate embedded emissions (actual or default), arrange verification if you use actual values, budget for certificates and the CBAM factor ramp, and calendar the deadlines — the 30 September annual declaration and surrender and the quarterly 50% holding rule from 2027.
What are the penalties for CBAM non-compliance?
Failing to surrender the required certificates by 30 September incurs a penalty of €100 per tonne of CO2e (the EU ETS excess-emissions penalty, indexed to inflation) for each unsurrendered certificate — and you still owe the certificates. Importing above the 50-tonne threshold without authorisation triggers an enhanced penalty of 3 to 5 times that rate, reduced where the threshold was exceeded by no more than 10%.
When is the first CBAM declaration and surrender due?
The first annual CBAM declaration, covering 2026 imports, and the first certificate surrender are both due by 30 September 2027. Under the 2025 Omnibus this date moved from 31 May, and the annual deadline is now permanently 30 September of the year after import.
Do I have to pay anything in 2026?
Not directly in 2026. For 2026 imports you buy certificates from 1 February 2027 and surrender them by 30 September 2027. The effective cost for 2026 is also small because the CBAM factor is only 2.5% that year, even though the definitive regime is fully live.
How small does my CBAM cost stay in 2026?
In 2026 the CBAM factor is 2.5%, meaning you pay on only about 2.5% of embedded emissions, because EU producers still receive around 97.5% free ETS allowances. The factor then ramps — 5% in 2027, 10% in 2028, and on toward 100% by 2034 — so the obligation is small now but grows substantially over the decade.

This is guidance, not legal advice

This is an independent checklist to help you understand and organise CBAM compliance, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. We cannot guarantee compliance, and you should be wary of anyone who says they can.

Sources

  1. [1]European Commission (DG TAXUD): CBAM hubretrieved 8 Jun 2026
  2. [2]DG TAXUD: CBAM successfully entered into force on 1 January 2026retrieved 8 Jun 2026
  3. [3]DG TAXUD: Officially published — simplifications for CBAM (20 Oct 2025)retrieved 8 Jun 2026
  4. [4]European Commission (DG TAXUD): CBAM Registry and reportingretrieved 8 Jun 2026
  5. [5]EUR-Lex: CBAM summary, Regulation (EU) 2023/956retrieved 8 Jun 2026
  6. [6]German DEHSt: CBAM definitive regimeretrieved 8 Jun 2026

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