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CBAM compliance timeline, 2026-2027

The CBAM definitive phase started 1 January 2026. Since then, EU importers of covered goods have been operating under rules that sharpen quarter by quarter. Here's the practical calendar — what happens when and what you need to do.

Past (2023-2025)

• 1 October 2023. Transitional phase begins. Importers report but pay nothing.
• 31 January 2026. Final quarterly transitional report due (for Q4 2025 imports).

If you filed those reports, you have some practice with the data format. If you didn't — you're behind, but catchable.

Now (Q2 2026)

• You should already be an authorised CBAM declarant — or applying. Without authorisation, you cannot import covered goods into the EU from 2026 onwards. Applications go through the EU CBAM Registry; process takes weeks.
• Collecting supplier data. Each imported shipment needs embedded emissions data from the producer. Non-EU suppliers often have no prior experience with this — patience and follow-ups are normal.
• No certificate purchases yet. First certificate purchase window opens around February 2027.

30 June 2026 — the first pressure point

By this date you must hold CBAM certificates equivalent to at least 50% of the projected emissions for imports since 1 January 2026. This is the first quarter-end 50% obligation under Article 22 of the Regulation.

In practice, for many importers this deadline will pass with the obligation calculated but certificates not yet available to buy. The Commission has signalled certificate availability may lag the quarter-end. Check the CBAM Registry for your member state's practical guidance.

30 September 2026 — second quarter-end

Same 50%-holding rule. Track your Q3 cumulative obligation.

31 December 2026 — end of the calendar reporting year

Final cut-off for imports that land in the 2026 annual declaration. Imports clearing customs after 31 December fall into calendar 2027.

Q1 2027 — preparation month

Three things happen here:

• Certificate prices move from quarterly to weekly ETS average (Article 21 shift). More volatility.
• You finalise supplier data — last chance to chase missing declarations.
• Your accredited verifier reviews the annual data and signs off on the methodology.

31 March 2027 — first annual CBAM declaration

Your biggest deadline. Via the EU CBAM Registry, submit the annual declaration covering calendar 2026 imports. Data per CN code per supplier, with verifier sign-off. The XML schema is published by the EC — AutoCBAM Starter generates the file matched to that schema.

31 May 2027 — certificate surrender

By this date you must surrender CBAM certificates equal to your verified 2026 emissions. If you've been buying at quarterly 50% obligations throughout 2026, you top up the balance here. Under-holding triggers Article 18 penalties.

What happens next (2027 onwards)

• Free allowances phase out. The free EU ETS allowances given to EU domestic industry decline from 2026 through 2034. Every year they drop, CBAM certificate obligations on imports effectively rise.
• Scope expansion. The Commission has signalled CBAM may extend to downstream products (e.g. auto parts, some chemicals) in later years.
• Annual rhythm. Declaration → verification → surrender, each year, forever. The annual cycle runs: collect data continuously → 50% quarterly holds → annual declaration by 31 March → surrender by 31 May.

How AutoCBAM fits the timeline

Penalties — Article 18

Under-surrender of certificates triggers a penalty equal to three times the ETS price per missing certificate. At €85/tonne ETS, every unsurrendered certificate costs you €255 plus interest. The penalty does not replace the certificate — you still owe the original obligation.

Failing to register as an authorised declarant is a separate and more consequential issue: you lose the right to import covered goods until rectified.

Not legal advice. Specific deadlines and their application to your imports may vary by member state and CN code. Confirm with your authorised competent authority and an accredited verifier.