Last verified: 2026-05-19
Where you are today. What comes next.
Every milestone in the EU Carbon Border Adjustment Mechanism — verified against EU primary regulation (EUR-Lex + DG TAXUD) and triangulated with tier-1 secondary sources. Present-first hierarchy: today and what is next take precedence; past is collapsed reference.
You are here
The definitive regime is in force. The 31 March 2026 Authorised CBAM Declarant application deadline has passed. The next major customer-facing milestone is the 1 February 2027 certificate sales platform launch, followed by the 30 September 2027 first annual declaration.
Where the EU is right now
Definitive regime in force
Since 1 January 2026 · ~5 months ago
CBAM's definitive regime is the legal status quo across the EU. 2026 is a tracking-only year — no certificate sale, no payment yet — but every imported tonne must be documented for the first annual declaration on 30 September 2027.
Authorised CBAM Declarant deadline — passed
Was 31 March 2026 · ~8 weeks ago
Importers without authorised status face customs refusal for release into free circulation. Pre-deadline applicants may continue importing provisionally during the 120-day NCA decision window (Reg. (EU) 2025/2549).
Next 3 regulatory milestones
Methodology consultation closes
10 June 2026 · in 14 days
Q2 2026 certificate price published
7 July 2026 · in ~6 weeks
Q3 2026 certificate price published
7 October 2026 · in ~4 months
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Immediate horizon — regulatory consultations, quarterly certificate prices, supplier engagement windows.
No regulatory milestone scheduled in the next 90 days. The next event is in the 12-month band below.
The 2027 annual cycle ramps up: weekly pricing, certificate sales open 1 February, quarterly holding checks, first annual declaration 30 September.
First quarterly holding check. Authorised declarants must hold CBAM certificates covering at least 50% of embedded emissions of their 2027 year-to-date imports. Q1 2027 covers only 2027 YTD imports; 2026 imports are surrendered annually on 30 September 2027.
Beyond the first annual cycle: second annual declaration + holding checks + downstream extension target.
Second quarterly holding check. Authorised declarants must hold CBAM certificates covering at least 50% of embedded emissions of their 2027 year-to-date imports through 30 June 2027.
First annual CBAM declaration deadline. Three concurrent obligations: (1) submit annual declaration for all 2026 imports + (2) surrender certificates equal to verified embedded emissions + (3) Q3 2027 holding check. Penalty for missing: €100/tonne excess emissions + name publication. Deadline postponed from original 31 May 2027 by Omnibus Reg. (EU) 2025/2083.
Authorised declarants may request EU repurchase of surplus certificates held after the annual surrender. Repurchase is optional and limited to one-third of total certificates purchased during the compliance year, at the original purchase price.
Final quarterly holding check for the 2027 compliance year. Authorised declarants must hold CBAM certificates covering at least 50% of embedded emissions of 2027 full-year imports through 31 December 2027.
Downstream extension proposal (target 1 January 2028) and the second annual declaration cycle. Proposals are clearly marked — the legislative procedure may shift dates.
Second annual CBAM declaration deadline. Authorised declarants submit annual declaration for all 2027 imports and surrender certificates equal to verified embedded emissions.
How we got here
The road behind us. Click an era to expand the regulatory events that shaped today's compliance landscape.
2026-03-31 · Regulation (EU) 2023/956 Article 17 + Reg. (EU) 2025/2549
Authorised CBAM Declarant deadline PASSED
31 March 2026 deadline. Importers without authorised status face customs refusal for release into free circulation, plus penalty exposure three to five times €100/tCO2 base — severity-scaled per Regulation (EU) 2023/956 Article 26(2), with reduction provision under Omnibus Regulation (EU) 2025/2083 where exceedance is below 10%. Importers who applied BY 31 March may continue importing provisionally during 120-day NCA decision window (~late July 2026 for last-day applicants, per Reg. 2025/2549).
Sustainability + transparency
Every event is verified against minimum 2 EU primary sources or 1 EU primary + 2 tier-1 secondary sources. Each event card shows its category and verification date; conditional events surface a disclaimer footnote.
Last full verification. 2026-05-19. Total events: 55.
Next scheduled review. 2026-08-19. Quarterly cadence (1 February / 1 May / 1 August / 1 November) plus event-driven triggers when the European Commission publishes new CBAM regulations or guidance.
Found an error? cbam@sustys.com — we triage every report within one week, publish a corrected version, and append an audit-log entry.
Disclaimer. This calendar is informational, not legal advice. Verify with EU primary sources before compliance decisions. Subject to regulatory change. Sustys does not represent or warrant completeness or accuracy.
Verified
EU primary + secondary convergence
EUR-Lex and DG TAXUD primary references cross-checked against tier-1 secondary sources (law firm, consultancy, or sector authority).
Conditional
Single strong source + footnoted gap
Disclaimer surfaced on the card. Re-verification scheduled at the next quarterly cycle.
Sources
Direct links to the regulations and Commission guidance underpinning this calendar.