CBAM Updates & Regulatory Timeline
A definitive timeline of the EU Carbon Border Adjustment Mechanism, tracking the shift from the reporting-only transitional phase to full financial enforcement.
The Definitive Phase (2026 onwards)
The definitive phase marks the beginning of financial enforcement. During this period, EU importers must purchase and surrender CBAM certificates corresponding to the embedded carbon in their imported goods.
The deadline for Authorised CBAM Declarants to surrender certificates covering the embedded emissions of goods imported during the 2026 calendar year.
The deadline for submitting the first annual declaration covering 2026 imports. This declaration must include verified actual embedded emissions data audited by an ISO 14065 accredited verification body.
The start of the definitive phase. Importers must be registered as Authorised CBAM Declarants to import covered goods. The requirement to maintain a quarterly balance of CBAM certificates (covering at least 80% of YTD emissions) begins.
The Transitional Phase (2023–2025)
The transitional phase was designed as a learning period, requiring quarterly reporting of embedded emissions without any financial payments or certificate surrender obligations.
The deadline for the final quarterly report covering Q4 2025 (October–December). After this date, the quarterly reporting obligation ceases entirely.
The deadline for the Q2 2024 report. This was the last report where importers could use EU default values for 100% of embedded emissions without restriction. Subsequent reports required actual emissions data (with default values limited to 20% of complex goods emissions).
The deadline for the inaugural CBAM report covering Q4 2023 imports.
The official start of the CBAM transitional reporting period.
The formal signing of the CBAM Regulation by the European Parliament and the Council.