CBAM Quarterly Reports vs Annual Declarations
During the transitional phase (2023–2025), importers submit quarterly reports with no financial penalty. From 2026, importers must submit an annual CBAM declaration and surrender paid certificates.
The Transitional Phase (Quarterly Reporting)
From 1 October 2023 to 31 December 2025, CBAM is in its transitional phase. During this period, the only obligation is reporting. EU importers must submit a CBAM report every quarter detailing the volume of imported goods and their embedded emissions. No financial payments or certificate surrenders are required.
The deadline for each quarterly report is one month after the end of the quarter. For example, the report for Q1 (January–March) is due by 30 April.
The Definitive Phase (Annual Declaration)
Starting 1 January 2026, the definitive phase begins. Quarterly reporting ceases, replaced by a single Annual CBAM Declaration. This declaration must be submitted by 31 May of the following year (the first declaration for 2026 imports is due 31 May 2027).
Crucially, the annual declaration carries financial obligations. Importers must surrender CBAM certificates corresponding to the total verified embedded emissions declared for the previous calendar year.
| Feature | Quarterly Report (Transitional) | Annual Declaration (Definitive) |
|---|---|---|
| Active Period | Oct 2023 – Dec 2025 | Jan 2026 onwards |
| Frequency | 4 times per year | Once per year (by 31 May) |
| Financial Cost | Zero (reporting only) | Full financial liability (certificate surrender) |
| Verification Required? | No (self-declared data accepted) | Yes (must be verified by ISO 14065 body) |
| Use of Default Values | Allowed (with restrictions post-July 2024) | Allowed, but financially punitive |