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

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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.

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CBAM timeline: from transitional to definitive phase

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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.

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

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• 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

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Key CBAM deadlines in 2026 and 2027

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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

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CBAM covered sectors

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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.

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CBAM penalties for non-compliance

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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.

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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.

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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:

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• 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.

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Using default vs. actual emissions values

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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.

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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.

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CBAM and the broader regulatory landscape

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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.

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Want to prepare verified CO₂e data for CBAM compliance?

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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.