How to Become an Authorised CBAM Declarant (the Practical Guide)

You can’t import CBAM-covered goods without authorised declarant status from 2026. Applications take weeks. If you’re reading this and you haven’t started, you’re probably already late for Q3 imports — but you can still make Q4 if you move now.

This is a practical, not-legal-advice walkthrough of the Article 5 CBAM Regulation process: what to prepare, where to file, what each major member state’s competent authority actually looks at, how long it takes, and why applications get rejected.

Written against Regulation (EU) 2023/956 and the Authorisation Implementing Regulation adopted in late 2025 (the “ACD Implementing Regulation”) that fills in the procedural detail.

Why authorisation matters

Article 5(1) CBAM Regulation is blunt: only an authorised CBAM declarant may import goods covered by Annex I into the customs territory of the Union. No authorisation, no import — the customs authority will block release under Article 25(1). From 1 January 2026 this is live. The transitional reporting period (Q4 2023 to end-2025) is over; we’re in the definitive phase.

If you were reporting under the transitional regime as a “reporting declarant,” that status does not automatically convert. You have to apply for authorised status separately under Article 5 and the ACD Implementing Regulation.

Who needs it

• Importers of record of Annex I goods. This is the commonest case. If your EORI number is on the customs declaration, you need ACD status.
• Indirect customs representatives can apply instead of the importer, under Article 32, where agreed contractually. Freight forwarders who file in their own name for multiple importers typically take this route for their smaller clients.
• EU-established entities only. Article 5(3) is clear: an ACD must be established in a member state. Non-EU entities have to use an indirect representative.

Before you apply — the documents

The ACD application pulls from several record systems. Have these ready before you open the EU CBAM Registry:

• EORI number (Economic Operator Registration and Identification). If you’ve imported anything into the EU in the last few years, you have one. If not, apply to your national customs authority first — this alone can take a week or two.
• VAT registration in the member state of establishment.
• Beneficial ownership disclosure. Article 5(5)(d) requires the authority to confirm you’re not connected to sanctions breaches, serious customs/tax infringements, or listed entities.
• Three years of financial statements (or since incorporation, if younger). Article 5(5)(c) requires “sufficient financial and operational capacity” — some authorities ask for audited accounts, others accept management accounts.
• A CBAM-compliance description: internal procedures for emissions data collection, supplier Communication handling, quarterly declaration workflow. This is the bit most applications skimp on.
• Designation of a responsible person — the human being who signs the declaration and is accountable for accuracy.
• Bank details for the financial guarantee where required.
• Estimated annual imports by sector and country of origin, in tonnes and expected emissions.

The financial guarantee is a 2026 feature most first-time applicants don’t expect. Under Article 5(5)(f) and the ACD Implementing Regulation, applicants that have been established for fewer than two years, or that cannot demonstrate sufficient financial standing, must provide a guarantee covering the expected annual certificate value. Guarantees are usually bank-issued and usually cost 1–2% of face value annually.

Where to file

Single EU system, national gateway. The application is submitted through the EU CBAM Registry at cbam.ec.europa.eu, but routed to the competent authority of your member state of establishment. Major member states’ authorities:

• Germany — Deutsche Emissionshandelsstelle (DEHSt) at the Umweltbundesamt. Not BNetzA (which handles electricity market regulation). DEHSt already runs EU ETS compliance for German installations, so they were the natural fit. Expect strong technical review.
• France — Direction générale de l’énergie et du climat (DGEC) within the Ministry of Ecological Transition. DGEC runs CBAM in coordination with the Customs Directorate (DGDDI) for the customs-interface side.
• Netherlands — Nederlandse Emissieautoriteit (NEa). NEa is efficient; many financial-services and trading-company applicants with EU HQs in Amsterdam route through here for speed.
• Poland — Krajowy Ośrodek Bilansowania i Zarządzania Emisjami (KOBiZE), under the Institute of Environmental Protection. KOBiZE handles Polish ETS and CBAM in parallel.
• Sweden — Naturvårdsverket (Swedish Environmental Protection Agency). Competent authority for CBAM alongside the Tax Agency (Skatteverket) for certain customs aspects.
• Spain — Ministerio para la Transición Ecológica y el Reto Demográfico (MITECO), specifically the Oficina Española de Cambio Climático.
• Italy — Ministero dell’Ambiente e della Sicurezza Energetica (MASE), in coordination with Agenzia delle Dogane e dei Monopoli.
• Belgium — Federal Public Service Health, Food Chain Safety and Environment, with regional coordination.
• Ireland — Environmental Protection Agency (EPA).
• Denmark — Energistyrelsen (Danish Energy Agency).

If you’re not sure which authority, check the Commission’s consolidated list at the taxation-customs EU site — it was last updated in Q4 2025 and covers all 27 member states.

Timing: what “four to eight weeks” actually looks like

Article 17 of the ACD Implementing Regulation sets a 120-day statutory deadline, extendable by 60 days for complex cases. Real-world timing from the first wave of applications (January–March 2026):

• NEa (Netherlands). Roughly 25–35 calendar days for clean applications. Fastest national authority we’ve observed.
• DEHSt (Germany). 45–70 days. Thorough; expect written follow-up questions on your emissions data collection procedure.
• DGEC (France). 50–80 days. Heavy on financial-capacity documentation.
• KOBiZE (Poland). 40–60 days for clean applications; longer if any customs-history flags.
• Naturvårdsverket (Sweden). 30–50 days, efficient.
• Italy (MASE). 60–120 days. Slowest in the first wave; queue was long.
• Spain (MITECO). 50–90 days.

So the “4–8 weeks” figure in the Commission’s FAQs is optimistic for most large member states and broadly accurate for NL and SE. Plan for 8–12 weeks if you’re in DE, FR, IT or ES. Start now.

Common rejection reasons

From talking to CBAM consultants and from published decisions on appeal:

• Incomplete financial statements. The authority needs three years of signed accounts or a good explanation if you’re younger. Draft accounts are not enough.
• Mismatched entity data between EORI, VAT and company register. Classic problem after a recent restructuring, M&A, or name change. Fix the upstream records first. The authority will not accept “we know it’s the same company.”
• Missing EORI number. If you’ve never imported into the EU before, you haven’t got one. Apply via your national customs portal before starting the ACD application.
• Insufficient CBAM-compliance description. “We will comply with the regulation” is not a procedure. You need to describe: (a) how you will request Communications from suppliers, (b) how you will store them, (c) how you will calculate quarterly emissions, (d) who reviews before submission, and (e) what happens when a supplier fails to provide a Communication.
• No named responsible person. A role title alone is not enough; a named individual has to be designated with a specific training record.
• Sanctions-list connections. Article 5(5)(d) compliance is checked against EU, national and UN sanctions lists. A director or beneficial owner on any list is immediate rejection.
• Customs infringement history. Article 5(5)(b) — if the applicant or its directors have serious or repeated infringements of customs or tax law in the past three years, expect either rejection or a guarantee requirement.

What happens if you import without authorisation

Article 25(1) — the customs authority does not release the goods. Full stop. You may also face Article 16 penalties, which under the ACD Implementing Regulation start at 3× the certificate value that would otherwise have been due and scale up for repeat infringements.

There is no “oh we didn’t know” exception. The transitional period ended on 31 December 2025. The Commission sent multiple notifications through 2024 and 2025.

Practical sequencing

If you are starting from nothing today (April 2026) and want to be importing legally in Q3:

• Week 1. Gather internal documents. Confirm your EORI. Pull financial statements. Identify the responsible person.
• Week 2. Write the CBAM-compliance description. Two to four pages is normal. Cover the five procedural points above.
• Week 3. Submit via the EU CBAM Registry. Select your member state.
• Weeks 4–12. Respond promptly to any questions from the competent authority. Keep the email thread clean.
• Week 12–14. Authorisation issued. You get a CBAM declarant number which goes onto every subsequent customs declaration.

AutoCBAM’s role in this

To be explicit: we do not file your application. The application is a human process with your member state’s authority. What we help with:

• The CBAM-compliance description you attach to your application. We have template procedures for the five steps and for each Annex I sector, so the description is credible and consistent with how you’ll actually declare later.
• The estimated-annual-imports figures. Our CN-code lookup and supplier-emissions estimator produces the sector-by-country tonnage and expected embedded emissions projection the application asks for.
• The ongoing declaration workflow once you’re authorised. Quarterly declarations under Article 22, certificate purchasing under Article 22a, and reconciliation to suppliers’ Communications.

Short version: the application is on you, but don’t show up with nothing. Come with a real procedure and real numbers.

Start today. Q3 2026 is closer than it looks.