Yes. For goods imported from 2026, an authorised CBAM declarant that has not surrendered enough CBAM certificates by 30 September of the following year pays a penalty for each missing certificate. Article 26 of Regulation (EU) 2023/956 sets it at the EU ETS excess emissions penalty for the year of import. That penalty is EUR 100 per tonne, raised in line with European consumer prices.
The penalty of EUR 10 to EUR 50 per tonne of unreported emissions belongs to the transitional period, which ended on 31 December 2025. Implementing Regulation (EU) 2023/1773 set it for the quarterly reports of specific embedded emissions (SEE) in CBAM goods. It covered cases where:
- the reporting declarant did not comply with the obligation to report the specific embedded emissions (SEE); or
- the reporting declarant had not corrected an incorrect or incomplete CBAM report even after the competent authority had begun the correction procedure.
Staying compliant under the definitive regime is the focus of the CBAM compliance service.