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Deadlines 5 min

CBAM deadlines 2026–2027: the dates that bite

The CBAM timeline through the definitive period — when certificates start, when the annual declaration is due, and the de minimis threshold that exempts the smallest importers.

Last updated 29 June 2026

CBAM moved from reporting to paying at the start of the definitive period. If you import iron & steel, aluminium, cement, fertilisers, hydrogen or electricity into the EU, these are the dates and thresholds that now shape your obligation.

The shape of the timeline

  • Transitional period (through end-2025) — quarterly reports of embedded emissions, in XML, with no charge. The job was to build the data.
  • Definitive period (from 2026) — the financial obligation begins. Importers need authorised CBAM declarant status, and the embedded emissions of what they import turn into CBAM certificates to buy and surrender.

The dates that matter

  • Authorised declarant status — required to bring CBAM goods into free circulation in the definitive period. Apply early; you cannot clear covered goods without it.
  • The annual CBAM declaration — submitted once a year, covering the previous calendar year’s imports, and due by 30 September of the following year. The first declaration, covering 2026 imports, is due 30 September 2027 — a full year of imports declared the following autumn.
  • Certificate purchase and surrender — sales of CBAM certificates open in February 2027; you buy across the year and surrender them against your declared embedded emissions, at a price tracking the EU ETS. The cost accrues on your 2026 imports even though the cash outlay starts in 2027.

These dates were reset by the EU’s 2025 “Omnibus” simplification (Regulation (EU) 2025/2083, in force October 2025), and the mechanics — surrender ratios, reporting cadence — may be tuned again. Treat them as the current shape, and confirm specifics against official European Commission guidance.

The de minimis threshold

Not every importer is in scope. The 2025 Omnibus simplification introduced a single de minimis threshold: importers bringing in 50 tonnes or less of CBAM goods (cumulative net mass) per year are exempt from the obligation. It lifts the administrative burden off the long tail of very small importers while keeping the vast majority of embedded emissions covered — the Commission estimates it exempts around 90% of importers yet still captures roughly 99% of the emissions, because a small number of large importers account for most of the tonnes. (Hydrogen and electricity sit outside the exemption.)

If you’re near the threshold, the safe move is to measure: know your annual mass of covered goods before you assume you’re in or out.

What “ready” looks like

Being ready for the definitive period is less about a single deadline and more about a standing capability:

  1. Authorised declarant status secured.
  2. A clean read of every customs declaration — the right commodity codes, net mass and origin per line.
  3. Embedded-emissions data for each line — actual where you can prove it, default where you can’t.
  4. The exact filing format the registry accepts, validated before you lodge.

Miss one and the others don’t help. The work is continuous, not annual.

Next: start from what CBAM is, or estimate a shipment with the free CBAM calculator.