CBAM 2026: Start Date, Deadline & First Payment

Updated 3 May 2026. This guide reflects Regulation (EU) 2025/2083, the CBAM Simplification Regulation that entered into force on 20 October 2025. Three changes are easy to get wrong if you are reading older guidance: the annual surrender deadline is now 30 September (not 31 May), the quarterly minimum holding requirement is 50 per cent and applies only from 2027 onwards, and CBAM certificate sales begin on 1 February 2027.

It is 2 January 2026. A compliance officer at a mid-sized Dutch steel importer is reading a customs bulletin over her first coffee of the year. A shipment from Mumbai is stuck at Rotterdam. The cargo cleared EU inspection. The paperwork is fine. But the Registry is returning a single red flag.

Not authorised.

She checks the clock. She has three pages of instructions in front of her, none of which existed in this form four months ago. The clock keeps moving. The shipment does not.

This is what the definitive phase of CBAM feels like on day one.

Let me walk you through how we got here, what has actually changed, and what any importer of steel, aluminium, cement, fertilisers, hydrogen, or electricity now has to do every year, forever. I will share the technical detail from the regulation. But I will also share what it actually means when a shipment lands. Because those two things have only recently become the same thing.

CBAM 2026-2027 timeline at a glance

Every high-frequency question about CBAM reduces to one of these dates. Bookmark this table.

The rest of this guide unpacks each row: what the regime actually does, who is caught, how certificates work, how to register, and what happens if you miss the 30 September surrender deadline.

What is CBAM, really?

CBAM stands for Carbon Border Adjustment Mechanism. Most explainers stop there. I think that definition hides more than it reveals.

Here is the cleaner way to see it. The EU has been putting a carbon price on its own industries for twenty years through the EU Emissions Trading System. That means a steel mill in Germany pays for every tonne of CO2 it emits. A steel mill in Turkey does not. For a long time, the EU covered this gap by giving its own producers free allowances, so they would not lose business to cheaper imports.

But free allowances defeated the point. If the domestic producer does not really pay for carbon, there is no reason for them to decarbonise. And the atmosphere does not care which side of the border the emissions came from.

CBAM is the EU's attempt to close this hole. Instead of continuing to subsidise its own producers, it puts a carbon price on the imports. A Turkish steel mill selling into the EU now pays the same carbon price as a German one. In theory.

Why does that matter? Because once imports and domestic production pay the same carbon price, free allowances can be phased out without collapsing EU industry. CBAM and the end of free allowances are two ends of the same rope.

The transitional phase: October 2023 to December 2025

Before the definitive regime could begin, the EU ran a two-year rehearsal.

From 1 October 2023 to 31 December 2025, every importer of CBAM goods had to file quarterly reports. They had to disclose the quantity of goods, the country of origin, and the embedded emissions per tonne. They were not asked to pay anything. No certificates were purchased. No carbon liability was settled.

Why a rehearsal? Because nobody had ever done this at scale. Not importers, not customs authorities, not the national bodies that would eventually issue CBAM certificates. Asking a Dutch trading company to obtain verified emissions data from an Indonesian nickel smelter was genuinely new. The transitional phase gave everyone time to build the supply chain conversations, the reporting templates, and the internal processes that would be needed once money was on the line.

The first quarterly report was due 31 January 2024, covering October through December 2023. Reports were filed through the CBAM Transitional Registry, a simpler version of what would later become the full CBAM Registry.

During this rehearsal, importers could choose between three calculation pathways. They could use the EU Method, which relied on actual installation-level data from the foreign producer. They could use an equivalent method recognised by the Commission. Or, until 31 July 2024, they could use default reference values published by the Commission. These defaults were deliberately conservative, meaning higher than most real-world emissions, so importers had a reason to push their suppliers for real data instead of hiding behind the defaults.

The penalties during the transitional phase were small by definitive-phase standards. Between €10 and €50 per tonne of unreported or incorrectly reported CO2 equivalent. Not nothing. But not the kind of number that would reshape a business.

What was the EU really doing during this window? It was collecting a dataset. Every quarterly report added to a picture of the actual carbon intensity of goods flowing into EU markets from each country and sector. That dataset is what the Commission is now using to refine the default values for the definitive regime and to decide which countries' carbon prices are recognised as deductible.

January 2026: when reporting became authorisation

On 1 January 2026, CBAM crossed the line from a reporting rehearsal into the live regime. The financial leg of the regime is real, but it does not arrive on day one. Certificate sales begin on 1 February 2027, and the first surrender falls on 30 September 2027. What started on 1 January 2026 is the gating layer: only authorised declarants can import CBAM goods.

From that date, only authorised CBAM declarants may import CBAM goods above the threshold into the EU. The Registry is no longer a static reporting system. It is now wired in real time into national customs systems, TARIC, and the EU Customs Single Window. That is why the shipment from Mumbai in the opening scene was flagged at Rotterdam. The customs declaration triggered an automated check. The Registry answered. The answer was no.

This integration is the operational heart of the definitive regime. A shipment of CBAM goods arriving at any EU border now goes through a live query against the Registry. If the declarant is authorised, it clears. If not, it does not enter free circulation. There is no grace period for a missing authorisation, and no way to catch up on one after the shipment has arrived.

The first quarterly CBAM reference price for 2026 was published on 7 April 2026, covering the first quarter's imports. It came in at €75.36 per tonne of CO2 equivalent. Importantly, this is a published reference price, not a price at which certificates can yet be bought. Certificates corresponding to 2026 imports are sold from 1 February 2027 onwards, at the price published for the quarter in which the imports occurred. The Q2, Q3, and Q4 2026 reference prices are scheduled for publication on 6 July 2026, 5 October 2026, and 4 January 2027 respectively.

Who has to comply? The 50-tonne de minimis threshold, explained

Not every importer is caught by the definitive regime. The EU built in one important simplification in 2025.

A single mass-based de minimis threshold of 50 tonnes per year applies across all CBAM sectors. If your total annual imports of CBAM goods stay below 50 tonnes, you are not required to become an authorised declarant and you do not have to surrender certificates.

This replaced the earlier proposal of sector-by-sector thresholds, which would have meant tracking multiple different rules. The 50-tonne number is simple and predictable. It still catches the vast majority of industrial imports by volume, because CBAM sectors are dominated by heavy commodity flows.

Everyone else needs authorisation. And the authorisation has to be obtained in advance from the national competent authority, or NCA, of the Member State where the importer is established. You cannot apply at the border. You cannot apply retroactively.

The application needs company registration details, a VAT number, a declaration of no serious criminal or tax offences in the preceding five years, evidence of financial capacity to meet CBAM obligations, and acceptance of the Registry's terms of use. The NCA can grant or refuse the authorisation, and can revoke it later if the declarant stops meeting the conditions or commits fraud.

The Commission publishes a live list of authorised declarants. It is public. Anyone can verify whether a counterparty holds valid authorisation.

The annual compliance cycle

Once you are authorised, the definitive regime becomes an annual rhythm. Four beats. The cycle for 2026 imports runs differently from the cycle for 2027 onwards because the Simplification Regulation deferred certificate sales and quarterly holding to 2027.

One. Purchase certificates. Certificate sales open on 1 February 2027. From that date, declarants can buy CBAM certificates from the common central platform at the prevailing reference price. For 2026 imports, the price applied is the quarterly average of the EU ETS auction price for the quarter in which the import occurred, as published by the Commission. From 2027 imports onwards, the reference becomes a weekly average.

From 2027 onwards, a quarterly minimum holding rule applies. By the end of each calendar quarter, the declarant must hold at least 50 per cent of the certificates corresponding to the embedded emissions in goods imported since the start of the calendar year. The original draft of CBAM had set this floor at 80 per cent; the Simplification Regulation reduced it to 50 per cent. This rule does not apply to 2026 imports because there is no period during 2026 in which certificates are being sold; it begins to bite from Q1 2027 onwards.

Two. Submit the annual CBAM declaration. By 30 September of the year following import, the declarant files a declaration through the Registry. This is the formal statement of the total embedded emissions for the previous calendar year, broken down by commodity. For imports during 2026, the declaration is due 30 September 2027. The deadline was 31 May in the original CBAM Regulation, and was extended to 30 September by Regulation (EU) 2025/2083 to give declarants more time to verify supplier emissions data and acquire certificates.

Three. Surrender certificates to match the declared emissions. On or before the same 30 September deadline, the declarant surrenders certificates equal to the declared embedded emissions, adjusted for any carbon price already paid in the country of origin. Surrendered certificates are cancelled. They cannot be recovered or reused.

Four. Buy back surplus certificates if needed. If a declarant ends the year holding more certificates than they needed, Article 25 of the CBAM Regulation lets them sell back up to one-third of the certificates purchased during the prior year. The buyback happens at the current EU ETS price, not the price originally paid. So a declarant who overbought and then sees the EU ETS price fall will recover less than they paid. That price risk is the cost of flexibility.

This four-step cycle then repeats. Every year. Forever.

The first CBAM surrender deadline: 30 September 2027

If you only remember one date, remember this one.

The first CBAM surrender deadline is 30 September 2027. That is the single annual deadline by which the 2026 CBAM declaration must be filed and certificates for 2026 imports surrendered. It is also the date of the first CBAM payment: the first time real money leaves a declarant's account in settlement of a carbon border liability. The deadline was originally 31 May 2027 in the 2023 CBAM Regulation. Regulation (EU) 2025/2083, the CBAM Simplification Regulation that came into force on 20 October 2025, pushed it back by four months to 30 September 2027 to ease the verification and certificate-acquisition burden in the first year of the regime. The same 30 September deadline then repeats every year. For 2027 imports the surrender date is 30 September 2028, for 2028 imports it is 30 September 2029, and so on.

Miss it, and Article 26 of the CBAM Regulation kicks in. The excess emissions penalty is €100 per tonne of CO2 equivalent, adjusted for inflation from the 2013 base year under EU ETS rules. This is not a small fee. It mirrors the penalty that EU ETS installations face when they fail to surrender allowances. And here is the bite: paying the penalty does not discharge the obligation. You still have to go back, buy the missing certificates, and surrender them. The penalty is in addition to the carbon liability, not instead of it.

Why such a harsh design? Because if the penalty were cheaper than buying certificates, non-compliance would simply become a business decision. Making the penalty a multiple of the underlying carbon cost, plus a requirement to still deliver the certificates, removes that escape route.

CBAM certificates, explained

A CBAM certificate is not a share, not a carbon credit in the voluntary sense, and not an EU ETS allowance.

It is a compliance instrument. One certificate represents one tonne of CO2 equivalent of embedded emissions in imported goods. You buy it from the NCA. You hold it in your CBAM account in the Registry. You surrender it against your annual declaration. You cannot trade it with another declarant. There is no secondary market. There is no futures contract on CBAM certificates. There are no options.

The cleanest way to think about it is this. An EU ETS allowance behaves like a share. It trades on exchanges, has a futures market, and can be held as a financial investment. A CBAM certificate behaves like a postage stamp. You buy it from the post office at the posted rate, you use it to "post" your carbon liability, and you cannot sell it to anyone else.

Why is it designed this way? To prevent speculation. The Commission wanted CBAM certificates to track the EU ETS carbon price cleanly, not develop their own market dynamics. Restricting supply to NCA purchase and preventing secondary trading keeps that link intact.

The price of a certificate is set by reference to the EU ETS auction price on the European Energy Exchange. In 2026, the reference is the quarterly average. From 2027 onwards, it becomes a weekly average, making the certificate price much more responsive to the live ETS market.

Here is what that looks like in practice. A German manufacturer imports 10,000 tonnes of electrolytic aluminium from a Bahraini smelter during Q1 2026. The verified embedded direct emissions are 3.2 tonnes of CO2 per tonne of aluminium. The Q1 2026 CBAM certificate price, as published by the Commission on 7 April 2026, is €75.36 per tonne. Bahrain has no carbon pricing scheme, so no deduction applies.

Total embedded emissions: 10,000 × 3.2 = 32,000 tonnes CO2 equivalent. CBAM certificate cost: 32,000 × €75.36 = €2,411,520.

That is the bill that has to be settled by surrendering certificates on or before 30 September 2027, the first annual surrender deadline. Certificates themselves can only be purchased from 1 February 2027 onwards.

CBAM certificate price 2026: quarterly averages

The CBAM certificate price is set by reference to the EU ETS auction average on the European Energy Exchange. Throughout 2026 the reference is published quarterly. From 2027 onwards it moves to a weekly average, tracking the live ETS market much more closely.

The Q1 2026 price of €75.36 per tCO2e is the first-ever CBAM reference price under the definitive regime. It is also the number declarants are using to build cash-flow models for the 30 September 2027 surrender, even though no certificates can be purchased until 1 February 2027.

CBAM Transitional Registry vs. the Definitive Registry

The CBAM Registry is the digital spine of the regime. Without it, none of the rest of this works. But searchers often run into a terminology tangle, because two different versions of the Registry have existed during the life of CBAM so far.

The CBAM Transitional Registry went live on 1 October 2023 and operated until the end of the transitional phase on 31 December 2025. It was a lighter system. Its sole function was to accept quarterly CBAM reports from declarants. No certificates were purchased, no surrender happened, and no real-time integration with customs existed. If you still see references to the Transitional Registry in 2026, they refer to this now-retired system and to the historical reports filed in it.

The CBAM Registry (definitive) is the full-functionality platform that went live on 1 January 2026. It still accepts the functions of the Transitional Registry for historical records, but it also operates the Authorisation Management Module, the Certificate Management module, the Declaration and Surrender module, and the Data Reconciliation for Monitoring and Control module. It is wired in real time to TARIC, national customs, and the EU Customs Single Window.

What the CBAM Registry actually does

It is a centralised EU-level database operated by the Commission. It is separate from the EU ETS Registry and separate from national customs systems, but fully integrated with both.

The Registry is organised into functional modules. The Authorisation Management Module, or AMM, handles declarant applications, NCA reviews, status updates, and revocations. The Certificate Management module is where certificates are purchased, held, tracked, and bought back. The Declaration and Surrender module is where the annual CBAM declaration is submitted and where the corresponding certificates are cancelled. The Data Reconciliation for Monitoring and Control module, DRMC, is the auditor in the background. It cross-references customs import data against CBAM declarations to catch discrepancies, circumvention, and data-quality issues.

Think of a declarant's Registry account as a passport and a bank account combined. The passport part, AMM, establishes your identity and authorisation to operate. The bank account part, Certificate Management, holds your carbon compliance balance. When you file the annual declaration, you are telling the bank how much to debit.

How do you actually log in? You register through the NCA of your Member State as part of the authorisation application. Once authorisation is granted, you are issued credentials to access the Registry. There is no separate standalone CBAM login account in the way there might be for a commercial web service. Your access is tied to your authorised declarant status. If that status is revoked, so is your Registry access.

The Commission was developing a Common Central Platform in early 2026 to consolidate user experience across all Member States. A Call for Tenders was issued and its submission deadline was extended into April 2026. When it is in place, the CCP will give declarants a single interface for everything rather than slightly different flows depending on which NCA they belong to.

What about the carbon price already paid in the country of origin?

If the foreign producer has already paid a carbon price at home, should the EU charge them again?

The regulation says no, within limits. Article 9 of the CBAM Regulation allows a deduction from the CBAM liability for any explicit carbon price effectively paid in the country of origin, provided that the price is not already subject to any rebate or compensation upon export. The declarant has to provide evidence verified by an independent verifier accredited under the CBAM regime.

The challenge is that many carbon pricing systems around the world are partial, cover different sectors, or offer rebates at the border. The Commission has been working through the transitional-period data to decide which systems qualify. Declarants importing from countries with recognised carbon prices, for instance certain installations in the UK, Switzerland, or parts of China and India, may be able to claim a deduction. The mechanics are strict, and the burden of proof sits firmly with the declarant.

CBAM accredited verifier: who qualifies and how to find one

Every claim for a carbon-price deduction, and every declaration that relies on actual installation-level emissions data rather than default values, has to be verified by a CBAM accredited verifier. This is a narrowly defined role. A CBAM accredited verifier is an independent third-party body that has been accredited under Regulation (EC) No 765/2008 and formally recognised under the CBAM Implementing Regulation to audit embedded emissions. Being accredited for EU ETS verification does not automatically qualify a body for CBAM. A separate scope extension is required.

What does an accredited verifier actually do? They review installation-level data from the foreign producer, check the emission calculation methodology, physically inspect installations where scope 1 of the verification requires it, and issue a verification report that the declarant attaches to the annual CBAM declaration. Without a valid report from an accredited verifier, the declarant must fall back on default reference values, which are deliberately set higher than most real-world emissions.

How do you find one? Each national accreditation body in the EU publishes a register of bodies it has accredited, and the Commission maintains a consolidated list of CBAM-scope verifiers. Declarants should check that the verifier they appoint has the correct sectoral scope, steel verification is not the same accreditation as cement or aluminium, and that the accreditation is current on the date the verification report is signed.

FAQ

When did the CBAM definitive regime start?

The CBAM definitive regime started on 1 January 2026. That is the date on which only authorised declarants could import CBAM goods above the 50-tonne threshold, when certificate purchase and surrender became mandatory, and when the Registry was fully integrated with customs systems in real time.

When are CBAM certificates surrendered?

CBAM certificates are surrendered annually, by 30 September of the year following the calendar year in which the imports occurred. For embedded emissions in goods imported during 2026, the surrender deadline is 30 September 2027. For 2027 imports, it is 30 September 2028. The 30 September date was set by Regulation (EU) 2025/2083, the CBAM Simplification Regulation; before that, the deadline was 31 May. The declaration of embedded emissions is submitted at the same time, through the CBAM Registry.

What is the EU CBAM annual declaration deadline in the definitive regime?

30 September of the year following each import year. The annual CBAM declaration is submitted through the Registry and states the total verified embedded emissions for each commodity imported in the prior calendar year. The deadline was extended from 31 May to 30 September by Regulation (EU) 2025/2083.

What were the EU CBAM transitional phase dates?

1 October 2023 to 31 December 2025. During this window, importers had to file quarterly CBAM reports but were not required to purchase or surrender certificates. The first report covered Q4 2023 and was due 31 January 2024.

How does the EU CBAM registry integrate with customs systems?

The Registry is integrated in real time with national customs import systems, TARIC, and the EU Customs Single Window. When a shipment of CBAM goods arrives at any EU external border, the customs declaration automatically queries the Registry to verify that the declarant holds a valid authorisation. If the declarant is not authorised, the goods cannot be released into free circulation.

How do I register as a CBAM declarant?

You apply to the national competent authority (NCA) in the Member State where your company is established. The application requires company registration details, VAT number, a declaration of no serious criminal or tax offences in the preceding five years, evidence of financial capacity to meet CBAM obligations, and acceptance of the Registry's terms of use. Once the NCA approves the application, you are issued access credentials to the Registry.

How do I log in to the CBAM Registry?

You log in through the credentials issued by your NCA as part of your authorisation. There is no standalone public-facing CBAM login. Your Registry access is tied to your authorised declarant status.

Do I have to surrender CBAM certificates every year?

Yes, if you are an authorised declarant importing CBAM goods above the 50-tonne annual threshold. The surrender is an annual obligation settled by 30 September each year, covering the embedded emissions of goods imported during the previous calendar year.

What happens if I do not surrender enough certificates?

Article 26 of the CBAM Regulation sets the excess emissions penalty at €100 per tonne of CO2 equivalent, adjusted for inflation from 2013 under EU ETS rules. The penalty does not discharge the obligation. You still have to purchase and surrender the missing certificates on top of paying the penalty.

What is the first CBAM payment deadline?

The first CBAM payment falls on 30 September 2027. That is the date of the first annual surrender of CBAM certificates, covering embedded emissions in goods imported during the 2026 calendar year. The deadline was originally 31 May 2027 under the 2023 CBAM Regulation, and was extended to 30 September 2027 by Regulation (EU) 2025/2083. CBAM certificate sales themselves only open on 1 February 2027, so declarants have an eight-month window between certificate sales opening and the surrender deadline to acquire and surrender the certificates.

What is the first CBAM certificate surrender deadline for 2026 imports?

30 September 2027. This is the same date as the first annual declaration. For imports during the 2026 calendar year, declarants must both submit the CBAM declaration through the Registry and surrender certificates equal to the verified embedded emissions on or before 30 September 2027.

Is the CBAM Transitional Registry still in use in 2026?

The CBAM Transitional Registry operated between 1 October 2023 and 31 December 2025 as the system for submitting quarterly CBAM reports. From 1 January 2026, the full CBAM Registry replaced it and now handles authorisations, certificate purchase, annual declarations, and surrender. Historical transitional reports remain accessible through the new Registry, but all live operational activity happens in the definitive Registry.

What is the CBAM certificate price in 2026?

The CBAM certificate price in 2026 is published quarterly by the Commission as a reference to the EU ETS auction average on the European Energy Exchange. The Q1 2026 price was published on 7 April 2026 at €75.36 per tonne of CO2 equivalent. Q2, Q3, and Q4 2026 reference prices are scheduled for publication on 6 July 2026, 5 October 2026, and 4 January 2027. From 2027 onwards, the reference moves to a weekly average.

Who is a CBAM accredited verifier?

A CBAM accredited verifier is an independent third-party body accredited under Regulation (EC) No 765/2008 and recognised under the CBAM Implementing Regulation to audit embedded emissions at the installation level. Their verification report is required before a declarant can use actual emissions data or claim a deduction for a carbon price paid in the country of origin. EU ETS verification accreditation does not automatically extend to CBAM; a separate scope extension is needed.

What to do this week if you are caught by CBAM

If your company imports steel, aluminium, cement, fertilisers, hydrogen, or electricity, and you have not yet mapped your 2026 exposure, the honest answer is that you are already late. But late is not the same as lost.

Start with three things.

Quantify your annual import volume by commodity. If it is over 50 tonnes in any CBAM sector, you need authorisation. Apply now, not next quarter.

Open a supplier conversation. The EU Method requires verified installation-level emissions data. That conversation is slow. Starting it in April gives you time. Starting it in October does not.

Model the cash flow. A German importer bringing in 32,000 tonnes of embedded emissions at €75.36 per tonne is staring at a €2.4 million certificate bill due by 30 September 2027. That is a treasury problem, not just a compliance problem. Certificate sales open on 1 February 2027, so the buying window is concentrated into eight months, and from 2027 imports onwards a 50 per cent quarterly minimum holding rule means cash starts flowing well before each annual surrender date.

CBAM is not a future thing any more. It is the operating environment. The question is not whether to comply. The question is how quickly you can make compliance routine.

The shipment at Rotterdam eventually cleared. The authorisation had been applied for in December but not granted until 4 January. Three days of demurrage charges. A phone call to legal. A very long morning.

That was the easy version.