The CBAM definitive period, live from 1 January 2026, replaces the reporting-only transitional phase with financial liability. Covered goods may enter only through an authorised CBAM declarant, unless the importer stays at or below 50 tonnes net mass a year (not for electricity or hydrogen). Embedded emissions move to a single annual CBAM declaration, with any actual emissions in it verified by an accredited verifier. CBAM certificates cover the embedded emissions minus a free allocation adjustment that shrinks each year.
From reporting to financial liability
The transitional period ran from October 2023 to December 2025 as a data exercise only. Any importer could bring in CBAM goods and file quarterly CBAM reports with no payment attached. The CBAM definitive period, applying since 1 January 2026, converts that reporting into a financial obligation and restricts imports of covered goods to an authorised CBAM declarant, unless the importer stays at or below 50 tonnes net mass a year (not for electricity or hydrogen). Organisations assessing the shift can map the change through CBAM compliance support, which covers preparing for declarant status, embedded-emissions calculation and certificate exposure.
Transitional versus definitive at a glance
| Aspect | Transitional (Oct 2023 to Dec 2025) | Definitive (from 1 January 2026) |
|---|---|---|
| Nature | Reporting only, no payment | Financial liability |
| Who may import | Any importer | Authorised CBAM declarant, unless the importer stays at or below 50 tonnes net mass a year (not for electricity or hydrogen) |
| Filing | Quarterly CBAM reports | Single annual CBAM declaration |
| Verification | Not required | Declared actual emissions verified by an accredited verifier |
| Cost | None | Certificates for the embedded emissions minus the free allocation adjustment, priced off EU ETS auctions |
What the definitive period requires
Under the definitive regime, reporting becomes a single annual CBAM declaration, and certificates are surrendered for the declared emissions minus the free allocation adjustment. Declared actual emissions must be verified by an independent accredited verifier; default values need no verification. Although the definitive period starts on 1 January 2026, certificate purchase begins only on 1 February 2027, so 2026 liability is calculated first and settled later. Certificates for 2026 imports are surrendered with the annual declaration by 30 September 2027. The core obligations are:
- Authorised CBAM declarant status. Applications for the status can be made at any time. 31 March 2026 was the cut-off for the rule that let an applicant keep importing while its application was pending.
- A single annual CBAM declaration, first due 30 September 2027 for 2026 imports.
- CBAM certificates, one per tonne of CO2e, purchasable from 1 February 2027.
- A free allocation adjustment that shrinks as EU ETS free allocation is withdrawn. The CBAM factor is 97.5 per cent in 2026, 95 per cent in 2027, 90 per cent in 2028 and 77.5 per cent in 2029. It falls to 51.5 per cent in 2030, 39 per cent in 2031, 26.5 per cent in 2032 and 14 per cent in 2033. From 2034 nothing is deducted for free allocation. In 2026, 2.5 per cent of the benchmark is no longer deducted. That figure is not 2.5 per cent of the embedded emissions.
- A certificate price tracking the EU ETS, published as a quarterly average by quarter of import. In 2026 it was EUR 75.36 for Q1, EUR 75.28 for Q2 and EUR 82.32 for Q3, published on 5 October 2026.
Penalties also apply. An authorised declarant that under-surrenders pays the EU ETS excess emissions penalty for each missing certificate, at the rate for the year of import, and must still surrender the missing certificates. That rate is EUR 100 per tonne of CO2e, raised in line with European consumer prices, and parties importing without declarant status face three to five times that amount. The definitive period is not a simple continuation of transitional reporting, because it changes both liability and process. A structured CBAM guide helps separate the two phases before the first declaration falls due.
Sources: Regulation (EU) 2023/956 · Regulation (EU) 2025/2083 · European Commission CBAM