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CBAM Deadlines & Penalties

CBAM's definitive phase began on 1 January 2026, requiring EU importers to purchase certificates for embedded emissions. Key deadlines, authorisation requirements, and €100/tonne non-compliance penalties explained.

CBAM Deadlines & Penalties: Key Dates, Certificate Obligations and What Non-Compliance Costs

The Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase on 1 January 2026, transitioning from a reporting exercise into a financially binding compliance regime. For EU importers of covered goods, this means real certificate purchase obligations, mandatory third-party verification, and significant financial penalties for non-compliance. Understanding the exact deadlines, the authorisation process, and the cost structure of non-compliance is now a business-critical requirement.

CBAM timeline: from transitional to definitive phase

Transitional phase: 1 October 2023 – 31 December 2025
Importers of covered goods were required to submit quarterly emissions reports via the CBAM Transitional Registry. No certificates were required. Penalties during this phase ranged from €10 to €50 per tonne of unreported CO₂ (varying by member state), but enforcement was primarily focused on facilitating learning and improving compliance.

Definitive phase: from 1 January 2026
The full compliance regime applies. Key changes:

  • Quarterly reporting replaced by annual CBAM declarations
  • Certificate purchase obligations apply to all in-scope imports from 1 January 2026
  • Third-party verification by accredited verifiers is required when using actual (non-default) emissions values
  • All importers above the 50-tonne de minimis threshold must hold Authorised CBAM Declarant status

Key CBAM deadlines in 2026 and 2027

  1. 31 March 2026: Application for Authorised CBAM Declarant status — importers who filed before this date may provisionally continue importing until the decision takes effect
  2. From 1 January 2026: All imports of CBAM goods above the 50-tonne threshold require a CBAM account number or application reference number
  3. Quarterly 2026: CBAM certificate prices set quarterly in 2026, then weekly from 2027 onward
  4. 30 September 2027: First annual CBAM declaration due, covering all in-scope imports for the full calendar year 2026
  5. 30 September 2027: First certificate surrender deadline — certificates must be surrendered to cover all embedded emissions in 2026 imports
  6. Annually from 2027Annual declaration and certificate surrender due by 30 September each year

CBAM covered sectors

As of 2026, CBAM applies to imports of: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. An expansion to additional downstream goods (including certain steel and aluminium-intensive products) is expected from 2028 onward.

CBAM penalties for non-compliance

The CBAM penalty framework is directly aligned with the EU Emissions Trading System (EU ETS):

Core financial penalty: €100 per tonne of CO₂ for each tonne of embedded emissions that is unreported or for which insufficient certificates are surrendered. This amount is indexed annually to the EU inflation rate.

Crucially, paying the fine does not remove the obligation to surrender the missing certificates — meaning non-compliance results in both the penalty and the full certificate cost. For large-volume importers, this can translate into multi-million euro liabilities.

Example: An importer underreports or fails to report 1,000 tonnes of CO₂ embedded in steel imports. Fine alone: €100,000 — on top of the cost of purchasing the outstanding certificates at the prevailing EU ETS price.

Additional consequences of non-compliance:

  • Suspension or revocation of Authorised CBAM Declarant status: repeated non-compliance can result in loss of the right to import CBAM-covered goods until compliance is restored, triggering supply chain disruption and contractual penalties
  • Border detention: non-compliant shipments may be detained at EU borders
  • Loss of EU customers: EU buyers are legally required to work with compliant suppliers and will drop non-compliant vendors to avoid their own exposure
  • Reputational damage: public flagging of non-compliant importers

For importers who exceed the threshold without holding the required Authorised Declarant status, penalties can reach up to five times the standard €100/tonne rate.

Using default vs. actual emissions values

CBAM allows importers to report either actual verified emissions or default values published by the Commission. However, default values are set conservatively — based on the average emission intensity of the ten highest-emitting exporters — which typically results in significantly higher certificate costs than using verified primary data.

This creates a direct financial incentive for non-EU manufacturers to provide product-specific CO₂e data to their EU importers. Verified emission factors and PCF calculations aligned with GHG Protocol and ISO 14067 provide the data foundation needed to avoid punitive default values — and to reduce actual certificate costs by demonstrating lower embedded emissions. For procurement teams evaluating non-EU suppliers, CBAM compliance data and carbon intensity are now direct components of supplier selection decisions alongside price and quality.

CBAM and the broader regulatory landscape

CBAM does not exist in isolation. Companies managing CBAM obligations are typically also navigating CSRD reporting, EU Battery Regulation PCF declarations, and sustainability regulations more broadly. The underlying data requirement — verified, product-level CO₂e data across the supply chain — is shared across all of these frameworks. Integrating carbon data infrastructure rather than managing each obligation separately is the most efficient path to multi-regulation compliance.

Want to prepare verified CO₂e data for CBAM compliance?

Explore our CO₂e database and PCF calculation tools, or contact our team to access the sustamizer® and generate verified embedded emissions data for CBAM declarations.

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