CBAM Reporting Requirements in 2026: What Importers Actually Need to Do
Key Takeaways
- CBAM reporting requirements in 2026 include tracking imports, embedded emissions and applicable certificate obligations.
- Importers generally need authorised CBAM declarant status when imports exceed the 50-tonne annual threshold, subject to specific exceptions.
- Actual emissions data must be verified when used, while default values offer an alternative under applicable rules.
- The first annual CBAM declaration for 2026 imports is due by 30 September 2027.
- Accurate supplier data, emissions tracking and internal coordination help businesses manage CBAM costs and prepare for compliance.
If your understanding of CBAM comes mainly from the transitional reporting period, 2026 is a good time to update it.
The Carbon Border Adjustment Mechanism entered its definitive regime on 1 January 2026. The transitional period was largely about reporting and learning how to calculate embedded emissions. The definitive regime adds the part that gives CBAM its economic teeth: eligible importers must eventually surrender CBAM certificates corresponding to the emissions embedded in the goods they import.
There have also been important simplifications. Most importers are now subject to a single mass-based threshold of 50 tonnes per year, rather than CBAM obligations applying to every small shipment. At the same time, companies that remain within scope need to prepare for annual declarations, verified actual emissions where those are used, and the financial consequences of CBAM certificates.
So what does a company actually need to do in 2026?
Who has to comply with CBAM in 2026?
CBAM currently applies to selected goods in six sectors:
- Iron and steel
- Aluminium
- Cement
- Fertilisers
- Electricity
- Hydrogen
Whether a particular import falls under CBAM depends on its CN code, so companies should not determine applicability simply by asking whether they operate in one of these industries. A manufacturer may import only a handful of products that fall within CBAM while purchasing many others that do not.
Under the definitive regime, EU importers or their indirect customs representatives importing more than the applicable single mass-based threshold of 50 tonnes of CBAM goods per year generally need authorised CBAM declarant status. The threshold substantially reduces the number of smaller importers subject to the administrative requirements while retaining the overwhelming majority of emissions within the mechanism.
Electricity and hydrogen are treated differently from the general mass-based threshold, so companies dealing with these sectors should review the applicable rules separately.
For most companies, the first practical exercise is therefore surprisingly mundane: identify which imported CN codes are covered, determine annual quantities and establish whether the threshold is exceeded.
Everything else follows from that.
What changed when the definitive CBAM regime began?
During the transitional period from October 2023 through December 2025, importers reported information about CBAM goods and their embedded emissions but did not purchase or surrender CBAM certificates.
That changed from 1 January 2026.
Under the definitive regime, authorised CBAM declarants must declare the embedded emissions associated with their imports and surrender the corresponding number of CBAM certificates, after the applicable adjustments.
The certificate price is linked to the price of allowances under the EU Emissions Trading System. In 2026, the CBAM certificate price is calculated using a quarterly average of EU ETS auction prices. From 2027, the calculation moves to a weekly average.
This changes the nature of the data problem. An embedded-emissions number is no longer merely something that appears in a regulatory report. It contributes to determining a financial obligation.
That makes data quality considerably more commercially relevant.
What information needs to be maintained for CBAM?
At a high level, companies need to connect three kinds of information.
The first is import information: what was imported, how much, under which CN code, from where and through which importer or declarant.
The second is production information. CBAM emissions originate at the installation where the goods were produced, so companies need to connect imported products with the relevant non-EU production installations.
The third is emissions information: the data required to determine the embedded emissions of those goods according to the applicable CBAM methodology.
In practice, this can involve information on production quantities, direct emissions, indirect emissions where relevant, energy consumption, emission factors, production processes and precursor materials.
The exact calculation differs by sector and production route. A steel product, fertiliser and aluminium product do not necessarily create the same data requirements simply because all three sit inside CBAM.
The Commission published dedicated sector guidance for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity in August 2026, alongside general guidance on calculating embedded emissions.
Actual emissions or default values?
One of the most important decisions in the definitive regime is whether the declarant uses default values provided by the European Commission or actual emissions values from the producer.
Both routes exist under the definitive regime.
Default values reduce the need to obtain detailed primary emissions information from every producer. That can make them operationally attractive, particularly where supplier data is difficult to obtain.
Actual values can provide a more accurate representation of the emissions associated with a particular installation. If actual values are used, however, the producer outside the EU must provide emissions information that has been verified by an accredited CBAM verifier.
This creates a commercial question as well as a compliance question.
If a relatively low-carbon producer has actual emissions materially below the applicable default value, demonstrating those emissions may reduce the CBAM exposure associated with its products. Conversely, simply collecting primary data because it feels more sophisticated does not automatically create value.
Companies should therefore understand the difference between their actual supplier emissions and the applicable defaults before deciding where the effort of collecting and verifying primary information is worthwhile.
What does CBAM verification involve?
Verification applies at the level of the non-EU installation producing the CBAM goods when actual emissions values are used.
The installation operator monitors and calculates embedded emissions according to the CBAM methodology. An accredited CBAM verifier then reviews the monitoring approach, emissions calculations and supporting evidence and issues a verification report.
CBAM verifiers themselves must be accredited by national accreditation bodies in EU Member States. The first accredited verifiers are expected to become available around September 2026, with the first verification reports being issued from January 2027.
This timing is important. Companies do not need to have a finished 2026 verification report in September 2026. But installations intending to use actual emissions for the 2026 reporting year should already be maintaining the information and evidence that will eventually need to be verified.
Trying to reconstruct a year’s production and emissions evidence after the year has ended is possible in some situations. It is rarely the efficient way to do it.
What role does the CBAM Registry play?
The CBAM Registry is the European Commission’s official electronic platform for carrying out CBAM obligations.
It supports authorisations, reporting obligations, emissions-data submissions and other CBAM functions. Importers and authorised declarants use the Registry, but it is increasingly relevant to non-EU producers and verifiers as well.
Non-EU installation operators can use the Operators of Third Country Installations, or O3CI, portal to register their installations and provide emissions information. Accredited verifiers can access the same infrastructure to review emissions data and supporting documentation and issue verification reports.
This is particularly important for suppliers serving multiple European customers.
Instead of repeatedly providing the same installation and verified emissions information separately to each importer, an operator can maintain information through the Registry and make it available to relevant declarants.
For companies choosing CBAM software, this also creates an important distinction: the private software does not replace the official CBAM Registry. Its job is to manage the operational work required to get clean, complete and defensible information into the regulatory process.
When is the first CBAM declaration due?
The first annual CBAM declaration covers imports made during 2026 and must be submitted by 30 September 2027.
The declaration includes the total quantity of each type of CBAM good imported during the preceding calendar year and the associated embedded emissions. Where actual emissions are used, those emissions must be verified according to the applicable CBAM verification requirements.
The corresponding CBAM certificates must also be surrendered.
This creates a slightly unusual situation in 2026. Companies are already operating under the definitive regime, but the first annual declaration is not due until the following year.
That does not mean September 2027 is the sensible date to start preparing.
The data being declared in 2027 is being generated now.
What are CBAM certificates?
CBAM certificates are the mechanism through which CBAM creates a carbon cost on imports.
The certificate price follows EU ETS allowance auction prices. The objective is to progressively expose imported products to a carbon constraint comparable to that faced by EU producers under the ETS, while accounting for the gradual phase-out of free allocation within the EU.
The number of certificates ultimately surrendered is therefore not determined by import volume alone. Embedded emissions matter.
There are also adjustments. If a carbon price has already effectively been paid in the country of production, the corresponding amount can be deducted subject to the applicable rules. The CBAM system also accounts for the free allocation adjustment as free ETS allowances for EU producers are progressively phased out.
For finance and procurement teams, this means CBAM should increasingly be understood as part of landed product cost rather than solely as an environmental reporting requirement.
What should importers be doing during 2026?
The most useful starting point is not to build a giant CBAM project plan. It is to establish whether the underlying data flow works.
An importer should be able to take a CBAM-relevant transaction and trace it from the customs or procurement record to the product, supplier, production installation and embedded-emissions information associated with it.
If actual values will be used, the company should understand who is responsible for monitoring the emissions at the installation, what evidence is being retained and how verification will eventually occur.
Where default values are being used, teams should understand where they are being used and whether obtaining verified actual emissions could materially change future CBAM exposure.
The company should also know who owns each part of the process. Customs may understand CN codes and imports. Procurement owns supplier relationships. Sustainability teams may understand emissions methodology. Finance increasingly cares about certificate exposure. IT owns the systems through which much of the underlying data already moves.
CBAM tends to become painful when one team is asked to manually reconstruct information owned by all the others.
What should non-EU suppliers be doing?
CBAM is formally an obligation on EU importers and authorised declarants, but non-EU manufacturers have a significant role in making actual emissions data available.
A manufacturer supplying CBAM goods into Europe should first understand which products and installations are relevant. It should establish the monitoring approach required under the definitive CBAM methodology and begin maintaining the necessary production and emissions information.
If customers intend to use actual emissions values, the manufacturer should also prepare for verification.
There is a commercial reason to do this well.
Two suppliers may sell physically similar products into Europe but have very different embedded emissions. Once those emissions contribute to the importer’s CBAM certificate requirement, the carbon intensity of the product can begin affecting its effective cost to the European customer.
For lower-carbon producers, credible actual emissions data can therefore become more than a compliance response. It can become part of the product’s commercial proposition.
Do companies need CBAM software?
Not necessarily.
A company with a very small number of CBAM products, suppliers and transactions may be able to manage the process using internal systems, the Commission’s tools and carefully controlled spreadsheets.
The case for dedicated software becomes stronger as complexity increases: more transactions, more suppliers, more installations, more entities, more precursor calculations, repeated supplier engagement, changing emissions information and greater need for internal controls.
The important distinction is between reporting software and data infrastructure.
Generating a declaration is one part of CBAM. Maintaining the transaction, supplier, installation, calculation, evidence and verification relationships that support that declaration is the larger operational problem for many companies.
Software is useful when it reduces that work. It is not useful merely because a regulation exists.
A simple way to think about CBAM compliance
Strip away the terminology and the definitive CBAM process is trying to establish a fairly understandable chain:
What did you import? → Where was it produced? → How much carbon was embedded in producing it? → Can you substantiate that number? → What carbon price should therefore apply?
The complexity sits in proving each link reliably across thousands of commercial transactions and production processes.
That is why 2026 is an important year for companies within scope. The first annual declaration may not be due until September 2027, but the information that will support it is already being created across factories, suppliers, procurement systems and customs records today.
Getting those connections right now is considerably easier than reconstructing them later.
