EU CBAM Registry 2026–2027
Declarant Access, Certificate Transactions and the 50% Compliance Rule
A CBAM Journal Intelligence Report Sekason Research Limited · London September 2026
This report is published for information purposes only. It does not constitute legal, regulatory or financial advice. Readers should seek professional advice before making compliance decisions on the basis of this publication. © 2026 Sekason Research Limited. All rights reserved.
Disclaimer
Published by CBAM Journal, operated by Sekason Research Limited (Company No. 14339910), London, UK.
This report is for information purposes only. It does not constitute legal, regulatory, financial or tax advice. Readers must obtain independent professional advice before making compliance decisions. Whilst every effort has been made to ensure accuracy, Sekason Research Limited makes no warranty as to the completeness or fitness for purpose of the information contained herein. Regulatory requirements are subject to change — readers are responsible for monitoring updates to applicable legislation and guidance.
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1. Executive Summary
The first EU CBAM certificate surrender deadline, covering all in-scope goods imported during 2026, falls on 30 September 2027. From the first quarter of 2027, authorised CBAM declarants must hold certificates in their Registry account equivalent to at least 50% of cumulative embedded emissions imported since the beginning of the year, tested at four separate quarter-end dates. Certificate purchasing through the Common Central Platform opens on 1 February 2027 — but Registry access governance, import data reconciliation, emissions verification and certificate account structures must be in place before that date.
Five compliance obligations govern this cycle: obtaining and maintaining authorised CBAM declarant status through the relevant National Competent Authority; submitting an import-level annual CBAM declaration by 30 September each year; making an explicit actual-versus-default decision on embedded emissions for each supplier and product category; purchasing, holding and surrendering certificates through the Registry and Common Central Platform; and managing the quarterly 50% certificate-holding requirement across four separate test dates in 2027. None of these obligations operates in isolation — a failure on the quarterly 50% test is a regulatory breach independently of the annual surrender position.
This report delivers three proprietary frameworks not available in Commission guidance or existing free content: a CBAM Registry Compliance Control Matrix mapping every control to a named owner, evidence standard and failure consequence; a 50% Certificate Holding and Financial Exposure Model that converts the quarterly requirement into an internal monitoring process; and a complete 2026–2027 compliance calendar. Free content explains what the Registry does. This report specifies what the Compliance Manager must do, who must do it, when, and what evidence must be retained.
2. Regulatory Context
2.1 From Transitional to Definitive: What Changed on 1 January 2026
FINDING: Regulation (EU) 2025/2083 (8 October 2025) introduced the 50-tonne single mass-based threshold under new Article 2a and restructured the authorised declarant framework, making financial CBAM obligations live from 1 January 2026 for importers of iron/steel, aluminium, fertilisers and cement above that threshold.
SO WHAT: Every tonne of in-scope goods imported above the threshold since 1 January 2026 accumulates embedded emissions that will require verified certificate coverage by the 30 September 2027 surrender deadline — there is no retroactive grace period within the definitive regime.
NOW WHAT: Quantify 2026 in-scope imports by CBAM goods category against the 50-tonne threshold immediately; companies importing more than 50 tonnes of any single CBAM goods category in any 12-month rolling period must have applied for authorised declarant status by now.
The transition from the transitional to the definitive regime is not a regulatory rebadging. Emissions data collected under the transitional period for reporting purposes now carries direct financial consequence: every iron/steel, aluminium, fertiliser and cement shipment above the threshold since 1 January 2026 contributes to the first certificate surrender obligation. An importer who treated 2025 transitional reporting as a communication exercise — rather than as a data-quality foundation for the first declaration — will now face the cost of reconstructing import-level records that should already exist. The four sectors covered by the 50-tonne threshold are iron and steel, aluminium, fertilisers and cement. Hydrogen is also within EU CBAM scope but has different threshold mechanics under the applicable definitional provisions of Regulation (EU) 2023/956 as amended.
2.2 The Legal Architecture of the CBAM Registry (Articles 14 .and 16)
FINDING: Article 14 of Regulation (EU) 2023/956 establishes the EU CBAM Registry as the legal platform for all authorisations, reporting submissions, emissions data and certificate management, operative from 1 January 2026; Article 16 assigns each authorised declarant a unique CBAM account identified by EORI number; Article 15 gives the Commission risk-based control powers over every certificate transaction recorded in the account.
SO WHAT: The EU CBAM Registry is not an information portal — it is an audited compliance system in which every authorisation decision, import record, emissions submission and certificate transaction is visible to the Commission under Article 15 controls.
NOW WHAT: Confirm that CBAM Registry account governance is documented with a defined access list, named approval hierarchy and document retention protocol before the first certificate purchasing cycle opens on 1 February 2027.
Every decision a declarant makes — authorisation application, emissions submission, certificate purchase, quarterly balance, surrender — is recorded in the Registry and subject to Article 15 Commission scrutiny. That scrutiny is not theoretical: the Article 15 risk-based control power gives the Commission authority to examine certificate transaction patterns and investigate anomalies. Internal governance must match that standard. Documented access controls, an approval trail for certificate transactions, and a retention policy for supporting evidence are not administrative overhead — they are the evidence base the Compliance Manager would need to produce if the Commission exercised its Article 15 powers over the account.
2.3 The Four Portal Architecture — Who Accesses What
FINDING: Commission Implementing Regulation (EU) 2024/3210 (as amended in 2025) establishes four distinct portals within the CBAM Registry: the Declarants Portal, the National Competent Authorities Portal, the European Commission Portal, and the Operators Portal; the Commission published a new Declarants Portal user manual on 21 August 2026.
SO WHAT: The Operators Portal enables third-country installation operators to submit emissions data directly into the Registry — meaning the Compliance Manager's data quality depends not only on internal processes but on what overseas suppliers enter through a separate portal.
NOW WHAT: Map your organisation's Registry interactions against all four portals and assign a named owner for each data channel, including the supplier-facing Operators Portal interface, before 30 September 2026.
Portal | Primary User | Purpose | Data Flow Direction |
Declarants Portal | Authorised CBAM declarant | Authorisation, reporting, certificate account management, declaration submission | Declarant → Registry |
NCA Portal | National Competent Authority | Authorisation approvals, oversight, controls | NCA → Registry |
Commission Portal | European Commission | Risk-based controls, oversight, cancellation actions | Commission → Registry |
Operators Portal | Third-country installation operators | Direct emissions data submission for imported goods | Operator → Registry |
Table 1 — CBAM Registry Portal Architecture
The Operators Portal is the least understood portal in existing free content and the most operationally consequential for supply chain data governance. When third-country suppliers submit emissions data directly through the Operators Portal, the Compliance Manager must verify that the data entering the Registry from that channel is accurate, timely and matched to the correct import records. A discrepancy between Operators Portal data and the declarant's own import register is a reconciliation risk that the declarant — not the supplier — must resolve and evidence.
2.4 The Common Central Platform — Separate From the Registry, Connected to It
FINDING: Article 20 of Regulation (EU) 2023/956 (as amended by Regulation (EU) 2025/2083) establishes that Member States sell CBAM certificates through a Common Central Platform (CCP), with certificate transaction information then transferred to the CBAM Registry; CCP sales open on 1 February 2027.
SO WHAT: Certificate purchasing happens on the CCP — not inside the Registry — meaning a Compliance Manager who conflates the two systems will encounter operational friction at precisely the point where the first financial compliance cycle begins.
A certificate purchased on the CCP generates a transaction record that is then reflected in the declarant's Registry account. The two systems are connected but are not the same system. Finance teams expecting to purchase certificates by logging into the Registry will find no purchasing function there. The CCP is the purchasing interface; the Registry is the record of what was purchased, held and surrendered.
3. Compliance Obligations
3.1 Authorised Declarant Status — The 50-Tonne Threshold and the NCA Application
FINDING: Regulation (EU) 2025/2083, Article 2a requires importers of iron/steel, aluminium, fertilisers and cement exceeding the 50-tonne single mass-based threshold to obtain authorised CBAM declarant status; access to the CBAM Registry is requested through the National Competent Authority in the Member State of establishment.
SO WHAT: An importer above the threshold that has not obtained declarant status is non-compliant from the point the threshold is crossed — not from the first declaration deadline — meaning the financial exposure from 2026 imports accrues regardless of whether status has been obtained.
NOW WHAT: If NCA application has not been submitted, treat it as the immediate priority and document the submission date; companies importing more than 50 tonnes of any single CBAM goods category must have applied before incurring further in-scope imports.
The NCA application process runs through the national authority in the Member State where the declarant is established. Without authorised declarant status, a company cannot access the Declarants Portal, monitor its certificate account or submit a declaration. The most operationally difficult situation falls on borderline importers: those importing close to 50 tonnes of a CBAM goods category must monitor rolling import volumes to identify when the threshold is crossed, because the obligation begins at the crossing point — not at a calendar date. An importer who crosses the threshold mid-2026 and delays the NCA application compounds their compliance exposure with each subsequent shipment.
3.2 Annual CBAM Declaration — Obligations, Scope and the 30 September Deadline
FINDING: Article 6 of Regulation (EU) 2023/956 (as amended by Regulation (EU) 2025/2083) requires the authorised CBAM declarant to submit an annual declaration by 30 September each year for the preceding calendar year; the first declaration covers 2026 imports and is due 30 September 2027.
SO WHAT: The declaration requires verified embedded emissions data for every in-scope import during the year — it cannot be reconstructed from aggregate figures at year-end, meaning an importer without an import-level emissions register is already behind.
NOW WHAT: Build a 2026 CBAM import register recording CN code, country of origin, quantity and supplier emissions data or applicable default value for each in-scope shipment, completed before 31 December 2026.
The annual declaration is not a summary document. It is a shipment-level submission requiring a discrete entry for every in-scope import during the preceding calendar year, each with a CN code, country of origin, quantity and either verified actual emissions or an applicable default value. An importer who made 400 steel shipments in 2026 must account for all 400. Data collection cannot begin in July 2027 when the 30 September deadline starts to feel imminent — it must run in parallel with import operations throughout the year. A register reconstructed from invoices and memory in Q3 2027 will contain gaps, and a declaration built on gaps will not survive Commission scrutiny.
3.3 Embedded Emissions — Methodology, Default Values and the Verification Decision
FINDING: Commission Implementing Regulation (EU) 2025/2621 (16 December 2025), corrected by Regulation (EU) 2026/1740 (20 July 2026), specifies sector-specific default values with mark-ups of 10% for steel, aluminium, cement and hydrogen in 2026, and 1% for fertilisers; where actual emissions are used, verification is required under Article 8 and Annex VI of Regulation (EU) 2023/956.
SO WHAT: The 10% default mark-up means a declarant using default values pays a legally structured premium above their actual emissions exposure — the mark-up is not advisory, it is built into the calculation, and it compounds as import volumes grow.
NOW WHAT: Make an explicit actual-versus-default decision for each supplier and product category before 31 December 2026, document the basis, and confirm verifier availability and accreditation status before the 2027 declaration window opens.
Default values offer administrative simplicity at a financial cost. The 10% mark-up on steel, aluminium, cement and hydrogen default values means the declarant pays for emissions they may not have generated — and the larger the import volume, the larger the gap between default-based liability and actual exposure. Actual-emissions reporting eliminates the mark-up but requires accredited verification under Article 8 and Annex VI, which carries its own cost and a supply chain dependency on verifier availability. That dependency is not uniform across countries — the specific constraint affecting major supplier nations is addressed in Section 7.3. The decision between actual and default must be made product by product and supplier by supplier. For the calculation methodology itself, declarants should refer directly to Commission Implementing Regulation (EU) 2025/2547 (10 December 2025)
3.4 Certificate Surrender, Repurchase and Cancellation — The Non-Transferability Rule
FINDING: Article 22(1) of Regulation (EU) 2023/956 (as amended) requires certificate surrender by 30 September each year; Article 24 provides that the Commission cancels specified unused certificates on 1 November — leaving a window of only 32 days between the surrender deadline and cancellation; certificates cannot be sold or transferred to another person.
SO WHAT: CBAM certificates have no secondary market — any certificates held after the 1 November cancellation date are extinguished with no recovery mechanism, meaning over-purchasing to build a buffer carries a direct financial cost that cannot be recouped.
NOW WHAT: Calibrate certificate purchasing to the verified surrender obligation, not to a rounded-up estimate, and complete the verified emissions calculation at least 30 days before 30 September 2027 to allow time to correct any shortfall before the deadline.
The 32-day window between the 30 September surrender deadline and 1 November Commission cancellation provides no meaningful operational flexibility. If the surrender calculation contains an error — from a data gap in the import register, a mismatch in emissions figures or a systems failure — there is no secondary market from which to source missing certificates and no mechanism to extend the window. Member State repurchase and Commission cancellation are regulatory exit mechanisms for surplus certificates, not revenue instruments for the declarant. A declarant holding excess certificates after the surrender loses the value of those certificates entirely.
4. Key Dates and Deadlines
4.1 The 2027 Certificate Compliance Year — Five Separate Deadlines
FINDING: The 2027 EU CBAM certificate compliance year contains five distinct hard deadlines: certificate purchasing opens 1 February 2027; quarterly 50% certificate-holding tests fall on 31 March, 30 June, 31 October and 31 December 2027; annual declaration and surrender is due 30 September 2027; and the Commission cancels 2026-related unused certificates on 1 November 2027.
SO WHAT: Missing the 31 March 2027 quarterly test is a regulatory breach independently of the September surrender position — 2027 is not a single deadline year, it is a year of five consecutive compliance obligations, each requiring its own preparation.
NOW WHAT: Build a 2027 CBAM compliance calendar assigning a named owner, required action and evidence standard to each of the five dates, completed before 1 December 2026.
Date | Milestone | Regulatory Basis | Owner |
1 Jan 2026 | Definitive regime live; financial obligations begin | Regulation (EU) 2023/956 / 2025/2083 | Compliance |
2026 (rolling) | Import-level emissions data collection | Article 6 | Compliance / Trade |
1 Feb 2027 | Certificate purchasing opens via Common Central Platform | Article 20 | Finance / Compliance |
31 Mar 2027 | First quarterly 50% certificate-holding test | Article 22(2) | Finance / Compliance |
30 Jun 2027 | Second quarterly 50% certificate-holding test | Article 22(2) | Finance / Compliance |
30 Sep 2027 | First annual declaration and certificate surrender (2026 imports) | Articles 6, 22(1) | Compliance / Finance |
31 Oct 2027 | Third quarterly 50% certificate-holding test | Article 22(2) | Finance / Compliance |
1 Nov 2027 | Commission cancellation of specified unused 2026-related certificates | Article 24 | — |
31 Dec 2027 | Fourth annual 50% certificate-holding test | Article 22(2) | Finance / Compliance |
Table 2 — EU CBAM Registry Compliance Timeline 2026–2027
The highest operational pressure point in 2027 is the period between 30 September and 31 October. The 2026 surrender deadline falls on 30 September; the third quarterly 50% test for 2027 cumulative emissions falls 31 days later on 31 October. A Compliance Manager managing the 2026 surrender whilst simultaneously monitoring and building a certificate position against 2027 year-to-date emissions has two distinct financial calculations running in parallel, each requiring separate data sets, separate approval processes and separate Registry actions. Planning for this overlap must begin in Q2 2027, not in September.
5. Financial Exposure and Risk
5.1 How the CBAM Certificate Price Is Calculated
FINDING: For 2026, the Commission calculates the CBAM certificate price quarterly, based on EU ETS auction clearing prices; from 2027, the calculation moves to a weekly frequency based on EU ETS allowance closing prices, with the EEX as the primary EU ETS auction market.
SO WHAT: The shift from quarterly to weekly pricing in 2027 materially increases certificate cost volatility — a purchasing decision delayed by four weeks in 2027 could face a meaningfully different price than one made at the quarter-end, unlike the more predictable quarterly reference price applicable to 2026 imports.
NOW WHAT: Establish a price-monitoring process linked to the Commission's weekly CBAM certificate price publication and EEX EU ETS data before 1 January 2027, and brief Finance and Treasury that CBAM certificate price risk is a recurring weekly financial exposure from February 2027.
Feature | 2026 | From 2027 |
Calculation frequency | Quarterly | Weekly |
Reference price | EU ETS auction clearing price | EU ETS allowance closing price |
Price publication | Commission quarterly | Commission weekly |
Primary market | EEX EU ETS auctions | EEX EU ETS auctions |
Table 3 — CBAM Certificate Price Calculation: 2026 vs 2027
CBAM certificate prices are derived from EU ETS allowance prices, which are subject to carbon market dynamics — policy developments, energy market conditions and macro-economic signals all influence EUA price movements. The Commission's official quarterly (for 2026) and weekly (from 2027) CBAM certificate price publications are the authoritative reference for purchasing decisions. Finance teams must use the Commission publication directly, not a broker estimate or third-party index.
5.2 The 50% Certificate-Holding Requirement — Operational Control Model
FINDING: Article 22(2) of Regulation (EU) 2023/956 (as amended by Regulation (EU) 2025/2083) requires authorised declarants to hold certificates equivalent to at least 50% of cumulative embedded emissions imported since the beginning of the year, tested at four quarter-end dates: 31 March, 30 June, 31 October and 31 December 2027; the Registry's DRMC component enables declarants to monitor and anticipate this requirement.
SO WHAT: The 50% test is a hard quarterly compliance requirement — a breach on 31 March 2027 is a regulatory failure independently of the annual surrender position, meaning an organisation that manages the 50% test only at year-end is operating four compliance failures behind.
NOW WHAT: Set an internal alert threshold of 60% — 10 percentage points above the regulatory minimum — assign DRMC monitoring to a named owner in Finance or Compliance with a monthly review cadence and a pre-quarter-end alert at T-30 days from each test date.
Quarter-End Test | Date | Cumulative Embedded Emissions | Minimum Certificates Required | Recommended Internal Threshold | Monitoring Tool |
Q1 2027 | 31 Mar 2027 | All 2027 imports to 31 Mar | ≥50% of Q1 cumulative | ≥60% | DRMC |
Q2 2027 | 30 Jun 2027 | All 2027 imports to 30 Jun | ≥50% of H1 cumulative | ≥60% | DRMC |
Q3 2027 | 31 Oct 2027 | All 2027 imports to 31 Oct | ≥50% of 9-month cumulative | ≥60% | DRMC |
Q4 2027 | 31 Dec 2027 | All 2027 imports to 31 Dec | ≥50% of full-year cumulative | ≥60% | DRMC |
Table 4 — 50% Certificate-Holding Requirement: Financial Control ModelNote: The Q3 test date is 31 October 2027, not 30 September. The 30 September date is the annual surrender deadline for 2026 imports — these are separate obligations occurring one month apart.
The DRMC — the Declarant Risk Management Component — tracks four data streams: goods imported, emissions accumulated, certificate balance held and penalties accrued. All four must be monitored together to assess the 50% position. An organisation tracking certificate balance without tracking cumulative emissions accumulation cannot calculate whether the test will be passed at the quarter-end. Cumulative emissions grow continuously as imports continue through the year; certificates must be purchased at pace. The 60% internal threshold recommended by CBAM Journal provides a 10-percentage-point buffer against purchasing delays, price movements and data corrections. An organisation that triggers its internal alert at exactly 50% is already at the regulatory minimum — any purchasing delay or data revision creates an immediate breach.
5.3 The Penalty Regime — What Article 26 Provides
FINDING: Article 26 of Regulation (EU) 2023/956 (as amended by Regulation (EU) 2025/2083) imposes a penalty for each certificate not surrendered by 30 September, linked to the EU ETS excess-emissions penalty under Article 16(3) and increased under Article 16(4) of Directive 2003/87/EC; payment of the penalty does not discharge the obligation to surrender the outstanding certificates — the surrender obligation remains open.
SO WHAT: The Article 26 penalty is additive: an organisation that pays the penalty still owes the missing certificate surrender, meaning the total cost of a certificate shortfall is the penalty amount plus the cost of acquiring and surrendering the outstanding certificates after the deadline.
NOW WHAT: Verify the declaration and surrender calculation against the import register and verified emissions data at least 30 days before 30 September 2027, and obtain documented senior approval before submission to prevent a shortfall that cannot be corrected after the deadline.
The Article 26 penalty architecture is materially different from a standard regulatory fine. In most penalty regimes, payment closes the breach. Under Article 26, it does not. The declarant pays the penalty per missing certificate — and must then still surrender those certificates. Total exposure on a shortfall is: penalty per certificate multiplied by the number of missing certificates, plus the cost of acquiring those certificates after the deadline, plus the administrative cost of a post-deadline surrender. CFOs and Chief Compliance Officers must understand this structure before any scenario planning is conducted — modelling only the penalty underestimates the total liability. For the specific euro amount of the penalty per certificate, declarants should consult the Commission's official guidance, which links the calculation to Directive 2003/87/EC Articles 16(3) and 16(4).
5.4 Final CBAM Liability Calculation — What the Certificate Cost Is Not
FINDING: Commission Implementing Regulation (EU) 2025/2621 (as corrected by Regulation (EU) 2026/1740 of 20 July 2026) establishes that final CBAM liability is calculated at the CN code, country and production-route level — no single sector-wide default intensity exists for steel, aluminium, cement, fertilisers or hydrogen; the final liability also incorporates a free-allocation adjustment and any qualifying carbon prices paid in third countries.
SO WHAT: An internal CBAM liability estimate built on a generic sector intensity multiplied by EU ETS price will overstate or understate true exposure — potentially by a material amount — because it omits both the product-specific default and the free-allocation deduction.
NOW WHAT: Use only the Commission's official CBAM liability calculation methodology for internal financial planning, and identify which third-country carbon pricing schemes qualify for Carbon Price Relief before modelling net CBAM exposure for 2026 imports.
The formula "embedded emissions × EUA price = CBAM liability" is not the CBAM calculation.
It omits the free-allocation adjustment, which reduces the certificate obligation as a function of how much EU production still receives free ETS allocations; it omits the Carbon Price Relief deduction for carbon prices paid in third countries; and it applies a single intensity figure where the regulation requires a CN-code, country and production-route-specific value. As free allocation phases out in the years ahead, the CBAM certificate obligation will grow as a proportion of total carbon exposure. That trajectory must be modelled using the correct legal methodology.
6. Sector-Specific Impact Analysis
Sector | EU CBAM | UK CBAM | Default Mark-Up 2026 | Key Regulation Reference | Emissions Data Complexity | Verification Priority |
Steel | Yes | Yes | 10% | Reg. (EU) 2025/2621 | High — production-route specific | High |
Aluminium | Yes | Yes | 10% | Reg. (EU) 2025/2621 | High — CN code and country specific | High |
Cement | Yes | Yes | 10% | Reg. (EU) 2025/2621 | Medium — clinker content dependent | Medium |
Fertilisers | Yes | Yes | 1% | Reg. (EU) 2025/2621 | Medium — nitrogen methodology | Medium |
Hydrogen | Yes | Yes | 10% (rising to 30% by 2028) | Reg. (EU) 2025/2621 | High — default intensity highest per tonne | Highest |
Electricity | Yes | No | N/A — tCO₂e/MWh basis | Reg. (EU) 2023/956 | Medium — default/actual methodology | EU-only |
Table 5 — Sector-Specific Registry and Default-Value Obligations
6.1 Steel — Production-Route Complexity and Data Granularity
FINDING: The Commission published dedicated definitive-period guidance for iron and steel on 14 August 2026; Commission Implementing Regulation (EU) 2025/2621 provides production-route-specific default values for pig iron, semi-finished steel and flat-rolled products — no single steel sector intensity exists; India exported 4.03 million tonnes of finished steel to the EU in FY2023–24 (Government of India, Ministry of Steel, 25 March 2025).
SO WHAT: A steel importer that applies one blended default value across its entire product portfolio is not using the legally applicable methodology — the error compounds across large import volumes and creates a material liability misstatement.
NOW WHAT: Classify every steel import line by CN code and production route before 31 December 2026, and do not allow a single blended default to be applied across heterogeneous steel products in the 2027 declaration.
India's 4.03 million tonnes of finished steel exports to the EU in FY2023–24 illustrates the scale of the classification problem: each of those tonnes carries a CBAM obligation determined by its specific production route as specified in Regulation (EU) 2025/2621 and its applicable CN code. The declarant importing pig iron faces a different default value than the one importing flat-rolled products. Applying a blended figure across these categories is not a simplification; it is a methodological error that will not survive Commission scrutiny.
6.2 Aluminium — Country and Product Specificity
FINDING: Commission Implementing Regulation (EU) 2025/2621 states a default intensity of 1.700 tCO₂e/t for unwrought aluminium (CN 7601) in the cited country-specific table — but this is not a universal aluminium default; values are differentiated by CN code, country of origin and product type.
SO WHAT: Applying the 1.700 tCO₂e/t figure as a universal aluminium sector default misapplies the regulation and produces a CBAM liability calculation that will not withstand Commission scrutiny.
NOW WHAT: For each aluminium import line, match to the specific CN code, country of origin and the corresponding Regulation (EU) 2025/2621 default-value row before 31 December 2026, and flag any import line where a matching row cannot be identified.
The 1.700 tCO₂e/t figure is a row entry in a country-specific table, not a sector average. It does not apply to wrought aluminium products, aluminium alloys or processed aluminium goods — each of which has its own applicable default. A declarant importing across multiple aluminium product categories must map each CN code to its specific row in the default-value table.
6.3 Fertilisers — Lower Default Mark-Up, Not Lower Obligation
FINDING: Commission Implementing Regulation (EU) 2025/2621 applies a 1% mark-up to fertiliser default values in 2026, compared with 10% for steel, aluminium, cement and hydrogen — but the fertiliser emissions methodology remains product-specific and nitrogen-type dependent.
SO WHAT: The lower mark-up does not make fertiliser CBAM exposure negligible — it means the financial penalty for using default values instead of actual emissions is substantially smaller than in other sectors, but the obligation to determine and report embedded emissions for every in-scope shipment remains unchanged.
NOW WHAT: Calculate fertiliser CBAM exposure using the applicable product-specific default before 31 December 2026 and decide whether the cost of actual-emissions verification is justified by the liability reduction it would achieve.
The 1% mark-up changes the financial calculus of the actual-versus-default decision. For fertilisers, the cost of accredited verification is more likely to exceed the mark-up saving than it is for steel or hydrogen. That does not make default the automatic answer — it makes the cost comparison explicit. Declarants with large fertiliser import volumes should run the numbers before assuming either route is obviously correct.
6.4 Hydrogen — Highest Default Intensity, Escalating Mark-Ups
FINDING: Commission Implementing Regulation (EU) 2025/2621 specifies a default emissions intensity of 10.820 tCO₂e/t H₂ with default mark-ups of 10% in 2026, 20% in 2027 and 30% from 2028 — the highest default intensity of any EU CBAM sector, with a mark-up that legally escalates each year.
SO WHAT: A hydrogen importer using default values faces the highest per-tonne CBAM exposure of any sector — and that exposure increases by a legally specified 10 percentage points each year under the published mark-up schedule, making early actual-emissions verification financially material.
NOW WHAT: Hydrogen importers should commission actual-emissions verification immediately; weigh the cost of accredited verification against the default mark-up differential and the 2028 escalation before 31 December 2026.
The 10.820 tCO₂e/t H₂ default intensity combined with the escalating mark-up schedule creates a compliance cost that grows automatically each year without any change in import volumes or carbon prices. A hydrogen importer who defers actual-emissions verification to 2028 will face a 30% mark-up on that intensity rather than the 10% applicable now. The case for early verification is stronger in hydrogen than in any other EU CBAM sector precisely because the default penalty escalates regardless of what carbon markets do.
6.5 Electricity — EU CBAM Only; UK Excluded
FINDING: Electricity is within EU CBAM scope under Regulation (EU) 2023/956, with embedded emissions expressed in tCO₂e/MWh; Finance Act 2026, Part 5 lists five UK CBAM sectors — electricity is explicitly excluded from UK CBAM.
SO WHAT: Organisations importing electricity into EU markets face certificate obligations that do not arise for equivalent electricity imports into the UK — a compliance model built on EU electricity CBAM obligations will generate unnecessary cost and incorrect obligations if applied to UK operations.
NOW WHAT: Ensure EU and UK electricity import compliance are tracked in entirely separate frameworks and that no EU CBAM certificate obligation is assigned to a UK electricity import by 1 January 2027.
EU electricity CBAM uses a tCO₂e/MWh measurement basis rather than the per-tonne basis applied to goods sectors. Applying EU electricity CBAM methodology to UK electricity imports is a category error — UK CBAM does not cover electricity at all. The separation must be enforced at the systems level.
7. Practical Action Framework
7.1 Step 1 — Authorisation and Registry Access Governance
FINDING: The Commission published a new Declarants Portal user manual on 21 August 2026; Registry access is requested through the National Competent Authority in the Member State of establishment under Article 14 of Regulation (EU) 2023/956; EU Login credentials with two-factor authentication are required.
SO WHAT: An organisation without confirmed Registry access credentials cannot purchase certificates on the CCP from 1 February 2027, submit a declaration by 30 September 2027, or monitor the 50% position in the DRMC — meaning loss of access mid-cycle is a direct compliance emergency.
NOW WHAT: Confirm NCA application submitted and approved, EU Login credentials established with 2FA active, access rights assigned by role, and a named backup administrator documented, all before 1 December 2026.
Access governance is an internal control, not a technical task. The questions it must answer are: who holds credentials, what actions can each credential holder take, who approves certificate transaction decisions, and what is the escalation path if the primary access holder is unavailable? A certificate purchasing decision made by an individual without documented authorisation is a governance failure, regardless of whether the regulatory deadline is met. The Declarants Portal user manual published on 21 August 2026 should be reviewed by the Compliance Manager with operational responsibility for Registry functions — not delegated exclusively to IT or systems administrators.
7.2 Step 2 — Import Data Collection and Customs Reconciliation
FINDING: Article 14 of Regulation (EU) 2023/956 and Article 16 establish that the declarant's EORI number is the linking identifier between the CBAM Registry account and customs records; the Registry is designed for interoperability with customs systems under Commission Implementing Regulation (EU) 2024/3210.
SO WHAT: Any discrepancy between customs import records and Registry goods data is a reconciliation failure visible to the Commission under Article 15 risk-based controls — the Registry is the compliance record of reference, not an internal spreadsheet.
NOW WHAT: Establish a monthly CBAM import reconciliation process using EORI as the control key, matching customs declaration data against Registry goods data, with documented resolution of every discrepancy before the following month's import cycle closes — beginning 1 October 2026.
A discrepancy between customs data and Registry data at the moment of a Commission Article 15 review is not an administrative inconsistency — it is an evidenced compliance weakness with a timestamp. The reconciliation protocol must name four roles: who identifies each discrepancy, who investigates the cause, who corrects the Registry record where it is wrong, and who provides documented sign-off confirming resolution. All four must be defined in the internal compliance procedure, not resolved informally.
7.3 Step 3 — Supplier Emissions Data, Verification and the Accreditation Gap
FINDING: As at 6 February 2026, no NABCB-accredited Indian agencies had been confirmed as recognised under EU Regulation 2018/2067 (Government of India, Ministry of Commerce, 6 February 2026); the Commission published updated verification and accreditation guidance on 24 August 2026; India exported 4.03 million tonnes of finished steel to the EU in FY2023–24.
SO WHAT: An importer sourcing CBAM goods from India without an available accredited verifier defaults to Commission default values with a 10% mark-up for steel and aluminium — a directly quantifiable additional cost that persists for as long as the accreditation gap continues.
NOW WHAT: Audit verifier availability by country and goods category for every CBAM supplier before 31 December 2026; where no accredited verifier is available, plan for default-value use and incorporate the applicable mark-up into financial projections.
The verification accreditation gap in India is a structural constraint, not a transitional inconvenience. With 4.03 million tonnes of Indian finished steel exported to the EU in FY2023–24, the scale of affected trade is commercially significant. Until NABCB-accredited agencies are confirmed under EU Regulation 2018/2067 — or an alternative accreditation pathway is confirmed as satisfying Article 8 and Annex VI of Regulation (EU) 2023/956 — importers sourcing steel and aluminium from India cannot use actual-emissions reporting. The Commission's 24 August 2026 verification and accreditation guidance should be reviewed for any changes to third-country accreditation pathways that may affect existing supply chain structures.
7.4 Step 4 — Certificate Account Management and the 50% Monitoring Process
FINDING: The Registry's DRMC component enables authorised declarants to monitor goods, emissions, certificates and penalties and to anticipate the 50% quarterly holding requirement; certificate purchasing through the Common Central Platform opens on 1 February 2027; quarterly 50% tests fall on 31 March, 30 June, 31 October and 31 December 2027.
SO WHAT: The DRMC is the primary monitoring instrument for the most financially consequential ongoing compliance obligation the declarant faces — an organisation that reviews the DRMC only near the quarter-end has no ability to build a purchasing plan with meaningful lead time.
NOW WHAT: Build an internal CBAM certificate account dashboard drawing monthly from DRMC data, with a 60% internal alert threshold and a named owner responsible for the monthly review and a pre-quarter-end alert at T-30 days from each test date — governance in place before 1 February 2027.
The DRMC tracks four data streams: goods imported, emissions accumulated, certificate balance held and penalties accrued. An organisation monitoring certificate balance without monitoring cumulative emissions accumulation cannot calculate whether the 50% test will be passed. Both data streams must be read together, monthly, against the 60% internal threshold. As imports continue through 2027, cumulative emissions grow; certificates must be purchased at pace to maintain the internal threshold. A monthly review cycle gives Finance and Compliance 30 days of lead time before each quarter-end test — sufficient to purchase additional certificates if the position is approaching the 60% alert.
7.5 Step 5 — Annual Declaration and Certificate Surrender
FINDING: Article 22(1) and Article 6 of Regulation (EU) 2023/956 (as amended) require annual declaration and certificate surrender by 30 September; Article 24 provides that the Commission cancels specified unused certificates on 1 November — a window of 32 days; certificates cannot be transferred or sold to another person.
SO WHAT: The 32-day window between the surrender deadline and the cancellation date provides no meaningful time to acquire additional certificates if the surrender calculation is wrong — an error discovered in late September 2027 cannot be corrected through any secondary market.
NOW WHAT: Verify the declaration and surrender calculation against the import register and verified emissions data at least 30 days before 30 September 2027, obtain documented senior approval, and complete submission before 25 September 2027 to allow for technical platform issues.
CBAM Journal recommends submission by 25 September 2027 — five days before the legal deadline. The Registry is a Commission-operated platform; technical issues on a regulatory deadline date cannot be assumed away. A submission attempted on 30 September that fails due to a platform issue leaves no time for a retry. The evidence standard required for surrender is: the CBAM import register, the verified emissions data or applicable default-value classification for each shipment, and the certificate account balance at the point of surrender. A named compliance or finance officer must sign off the surrender calculation — not as a formality, but as a documented confirmation that the figures have been reviewed against the primary records.
7.6 The CBAM Registry Compliance Control Matrix
Six distinct controls govern the CBAM Registry compliance cycle, each requiring a different function to own it and a different evidence trail to demonstrate it. The matrix below converts the regulatory architecture of Regulation (EU) 2023/956 into an assignable internal control document — ownership, frequency, evidence standard and failure consequence specified for each control and ready for direct adoption.
Control | Frequency | Internal Owner | Evidence Required | Failure Risk |
Registry access and credential management | Monthly review; immediate on staff change | Compliance | Access log, role list, backup administrator record | Loss of operational access; inability to purchase certificates or submit declaration |
Import data collection and customs reconciliation | Monthly | Trade / Customs | CBAM import register; EORI-matched customs declaration vs Registry goods data | Incorrect or incomplete declaration; Commission Article 15 scrutiny |
Supplier emissions data collection and verification status | Quarterly | Sustainability / Procurement | Supplier emissions evidence or default-value classification; verifier accreditation confirmation | Default-value fallback with mark-up; declaration inaccuracy |
Certificate account monitoring (50% test) | Monthly; pre-quarter-end review at T-30 | Finance / Compliance | DRMC balance report; cumulative emissions vs certificate holding calculation | Quarterly 50% breach; regulatory penalty |
Certificate purchasing | As required to maintain 60% threshold; before each quarter-end | Finance / Treasury | CCP purchase confirmation; Registry account credit record | 50% breach; surrender shortfall |
Annual declaration preparation and surrender | Annual; preparation begins no later than 60 days before the 30 September deadline (CBAM Journal recommendation) | Compliance / Finance | Import register; verified emissions data; certificate account balance; surrender confirmation | Article 26 penalty; residual surrender obligation post-deadline |
Table 6 — CBAM Registry Compliance Control Matrix (CBAM Journal Framework)
No single department can own this matrix. Compliance, Trade, Finance/Treasury, Procurement, Sustainability and external verifiers each carry a defined role. A named coordination lead must be responsible for ensuring all six controls are operating and evidenced — a role that requires sufficient seniority to hold each function accountable and sufficient Registry access to verify the compliance position directly.
8. Strategic Outlook
8.1 The EU ETS Reform Proposal — Not Actionable as Current Law
FINDING: The Commission proposed on 17 July 2026 a targeted EU ETS revision that would slow the free-allocation phase-out and extend it toward 2038 — this is a legislative proposal and has not been adopted; it should not be incorporated into 2026–27 CBAM compliance calculations.
SO WHAT: If adopted, the proposal would reduce the rate at which CBAM certificate obligations scale up as free allocation decreases — but acting on an unadopted proposal as though it were current law introduces an error into financial projections in the opposite direction from the current legislative position.
NOW WHAT: Monitor Commission legislative progress through EUR-Lex and Carbon Pulse; do not adjust 2026–27 CBAM liability calculations until the final adopted text is published in the Official Journal of the EU.
The 17 July 2026 EU ETS revision proposal is relevant to longer-range CBAM financial planning, but it changes nothing in the compliance obligations for 2026 and 2027. Until the proposal completes the EU legislative process and is published in the Official Journal, all CBAM liability calculations must be based on the current text of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.
8.2 The Verification Infrastructure Gap — A Confirmed 2027 Supply Chain Risk
FINDING: As at 6 February 2026, no NABCB-accredited Indian agencies had been confirmed as recognised under EU Regulation 2018/2067 (Government of India, Ministry of Commerce, 6 February 2026); the Commission published updated verification and accreditation guidance on 24 August 2026; India's 4.03 million tonnes of finished steel exports to the EU in FY2023–24 illustrates the scale of affected trade.
SO WHAT: The verification infrastructure gap in India — a major supplier of CBAM goods to the EU — is a structural supply chain compliance risk that pushes affected importers onto default values with a 10% mark-up for the duration of the gap, with no confirmed timeline for resolution.
NOW WHAT: Embed verification pathway status into supplier qualification processes immediately and review the Commission's updated 24 August 2026 verification guidance for any changes to third-country accreditation pathways that affect existing supply chain structures.
Until NABCB-accredited Indian agencies are confirmed under EU Regulation 2018/2067, actual-emissions verification for goods sourced from India requires a verifier accredited by an alternative accreditation body that satisfies the conditions of Article 8 and Annex VI of Regulation (EU) 2023/956. Declarants must not assume an alternative pathway is available without written confirmation from their verifier specifying the applicable accreditation basis. The Commission's 24 August 2026 guidance should be reviewed to identify which alternative pathways are currently operative and whether any verification bodies working in India already satisfy those conditions.
8.3 UK CBAM — A Different Architecture, A Different Timeline
FINDING: UK CBAM is established by Finance Act 2026, Part 5, Section 143 as a tax administered by HMRC — not a certificate system; the first annual accounting period runs 1 January to 31 December 2027, with the first return and payment due 31 May 2028; the registration threshold is £50,000, triggering under either a forward-looking test (expected imports in the next 30 days) or a backward-looking test (imports during the preceding 12 months); HMRC published a provisional list of qualifying carbon-pricing schemes on 27 August 2026, including the EU ETS and India's Carbon Credit Trading Scheme.
SO WHAT: An organisation subject to both EU and UK CBAM must operate two structurally incompatible compliance frameworks — importing EU Registry governance, certificate purchasing and quarterly 50% controls into a UK CBAM process would generate systematic errors in both directions.
NOW WHAT: Maintain EU CBAM and UK CBAM as entirely separate compliance work streams with separate named owners, separate procedures and separate records, with UK CBAM governance in place before 1 January 2027.
Feature | EU CBAM | UK CBAM |
Legal nature | Carbon border adjustment mechanism | Environmental tax |
Governing legislation | Regulation (EU) 2023/956 / 2025/2083 | Finance Act 2026, Part 5 |
Start date | 1 January 2026 | 1 January 2027 |
Administering authority | Member State NCA / Commission | HMRC |
Registry / certificate system | Yes — CBAM Registry | No — no certificate system |
50% quarterly holding test | Yes — from 2027 | No equivalent |
Threshold | 50 tonnes (mass-based, four sectors) | £50,000 (value-based; forward-looking 30-day test or backward-looking 12-month test) |
First financial deadline | 30 September 2027 (surrender) | 31 May 2028 (tax return) |
Sectors covered | 6 (including electricity) | 5 (electricity excluded) |
Certificate price mechanism | EU ETS-linked | UK ETS-linked sectoral rates |
Table 7 — EU CBAM vs UK CBAM: Architecture Comparison
The HMRC qualifying carbon-pricing schemes list published on 27 August 2026 includes the EU ETS and India's Carbon Credit Trading Scheme, among others. For organisations importing CBAM goods into the UK from countries with a qualifying scheme, the carbon price paid in the third country may reduce UK CBAM liability through Carbon Price Relief. This is a financial planning opportunity that requires accurate identification of applicable schemes and the carbon price actually paid — it is not a compliance obligation, but it warrants analysis before the first UK CBAM return is filed in May 2028.
9. FAQ Section
Q: What is the EU CBAM Registry and what does our compliance team actually use it for?
The EU CBAM Registry, established under Article 14 of Regulation (EU) 2023/956, is an audited compliance system — not an information portal — through which authorised CBAM declarants manage authorisations, submit emissions data, maintain their certificate account and file the annual declaration. Article 16 assigns each declarant a unique CBAM account identified by EORI number, and Article 15 gives the Commission risk-based control powers over every certificate transaction recorded in that account. Every compliance action — authorisation, import record, certificate purchase, surrender — is recorded in the Registry and visible to Commission scrutiny.
Q: When can we start purchasing CBAM certificates and where — through the Registry or somewhere else?
Certificate purchasing opens on 1 February 2027 through the Common Central Platform (CCP) — not through the CBAM Registry itself. The CCP is the purchasing interface through which Member States sell certificates under Article 20 of Regulation (EU) 2023/956; once purchased, transaction information is transferred to and recorded in the declarant's Registry account. Finance and Treasury teams must confirm CCP access credentials with their NCA before 1 February 2027 — the CCP and the Registry are separate systems requiring separate access.
Q: What is the 50% certificate rule and exactly when during the year must we pass it?
Under Article 22(2) of Regulation (EU) 2023/956 (as amended), authorised declarants must hold certificates equivalent to at least 50% of cumulative embedded emissions imported since the beginning of the year, tested at four quarter-end dates: 31 March, 30 June, 31 October and 31 December 2027. The 50% test applies to cumulative year-to-date emissions — not to emissions imported in each quarter individually — meaning the certificate position must keep pace with a growing annual total. The Registry's DRMC component enables declarants to monitor the cumulative position and anticipate each quarterly test.
Q: What is the first EU CBAM certificate surrender deadline for our 2026 imports?
The first annual surrender deadline is 30 September 2027, covering all in-scope goods imported during 2026, under Article 22(1) of Regulation (EU) 2023/956. Article 24 provides that the Commission cancels specified unused certificates on 1 November 2027 — a window of only 32 days after the surrender deadline, leaving no time to acquire additional certificates if the surrender calculation is wrong.
Q: What should we have in place before EU CBAM certificate purchasing begins in February 2027?
Before 1 February 2027, the following must be confirmed: authorised CBAM declarant status granted by the NCA; Registry credentials with role-based access assigned and a named backup administrator documented; a 2026 CBAM import register recording CN code, country of origin, quantity and emissions data or default-value classification for every in-scope shipment; an explicit actual-versus-default decision documented for each supplier and product category; a verifier status audit completed for each CBAM supplier country; DRMC monitoring governance with a named owner and monthly review cadence; and a certificate budget approved by Finance reflecting the 60% internal holding threshold through each of the four 2027 quarter-end test dates.
Q: If we fail a quarterly 50% certificate holding test, does paying the Article 26 penalty close the compliance breach?
No. Article 26 of Regulation (EU) 2023/956 imposes a penalty for each certificate not surrendered by 30 September — but payment of that penalty does not discharge the obligation to surrender the outstanding certificates. The surrender obligation remains open after the penalty is paid, meaning the total cost of a shortfall is the penalty per missing certificate plus the cost of acquiring and surrendering those certificates after the deadline passes.
Scope
This report covers EU CBAM Registry operations, certificate purchasing, the 50% quarterly holding requirement, annual declaration and surrender, and sector-specific default-value obligations under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. UK CBAM under Finance Act 2026, Part 5 is addressed comparatively only.
All information reflects the regulatory position as at September 2026. The EU ETS reform proposal of 17 July 2026 is noted as an unadopted proposal and is not incorporated into any compliance calculation in this report.
This report does not cover transitional period obligations, product-level liability calculations, individual Member State NCA procedures, or UK CBAM in full detail.
Reproduction without prior written permission is prohibited.
© 2026 Sekason Research Limited · cbamjournal.com · contact@sekasonresearch.com
Sources Used in This Report
European Union / EUR-Lex - Regulation (EU) 2023/956 establishing CBAM (10 May 2023): https://eur-lex.europa.eu/eli/reg/2023/956/
European Union / EUR-Lex - Regulation (EU) 2025/2083 amending CBAM (8 October 2025): https://eur-lex.europa.eu/eli/reg/2025/2083/oj/eng
European Commission / DG TAXUD - CBAM Registry (Accessed September 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-registry_en
European Commission / DG TAXUD - CBAM Definitive Regime (Current): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en
European Commission / DG TAXUD - CBAM Questions and Answers (27 May 2026): https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en
EU / EUR-Lex - Implementing Regulation (EU) 2025/2547 — Emissions Methodology (10 December 2025): https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32025R2547
EU / EUR-Lex - Implementing Regulation (EU) 2025/2621 — Default Values (16 December 2025): https://eur-lex.europa.eu/eli/reg_impl/2025/2621/oj/eng
EU / EUR-Lex - Implementing Regulation (EU) 2026/1740 — Default Value Correction (20 July 2026): https://eur-lex.europa.eu/eli/reg_impl/2026/1740/oj/eng
European Commission - CBAM Sector Guidance — Definitive Period (14 August 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-sectors_en
European Commission - CBAM Verification and Accreditation Guidance (24 August 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en
European Commission - EU ETS Policy Overview / July 2026 Revision Proposal (17 July 2026): https://climate.ec.europa.eu/areas-action/carbon-markets/about-eu-ets_en
UK Parliament / legislation.gov.uk - Finance Act 2026, Part 5 — CBAM (2026): https://www.legislation.gov.uk/ukpga/2026/11/pdfs/ukpga_20260011_en.pdf
HMRC / GOV.UK - CBAM Policy Summary (16 July 2026): https://www.gov.uk/government/publications/carbon-border-adjustment-mechanism-cbam-policy-summary
HMRC / GOV.UK - CBAM Record Keeping Guidance (16 July 2026): https://www.gov.uk/guidance/keeping-records-for-carbon-border-adjustment-mechanism-cbam
HMRC / GOV.UK - Goods in Scope of UK CBAM (16 July 2026): https://www.gov.uk/government/publications/check-which-goods-are-in-scope-of-carbon-border-adjustment-mechanism-cbam
HMRC / GOV.UK - UK CBAM Qualifying Carbon-Pricing Schemes (27 August 2026): https://www.gov.uk/government/publications/uk-cbam-current-qualifying-carbon-pricing-schemes
Government of India / Ministry of Steel - Finished Steel Exports to EU — Lok Sabha Question No. 3980 (25 March 2025): https://steel.gov.in/sites/default/files/lu%203980.pdf
Government of India / Ministry of Commerce - CBAM Verifier Accreditation — Rajya Sabha Question No. 857 (6 February 2026): https://www.commerce.gov.in/wp-content/uploads/2026/02/USQ-857.pdf
EEX - EU ETS Auction Market (Current): https://www.eex.com/en/markets/environmentals/eu-ets1-eu-ets2-auctions/eu-ets1-auctions
© 2026 Sekason Research Limited · cbamjournal.com · contact@sekasonresearch.com
Reproduction in whole or in part without written permission from Sekason Research Limited is prohibited.
