The CBAM annual declaration for 2026
In the definitive period one declaration a year replaces the quarterly reports of the transitional period. The first covers all CBAM imports of 2026 and must be submitted in the CBAM registry by 30 September 2027 – together with the certificates.
At a glance
- Authorised CBAM declarants must submit; anyone who imported no more than 50 t in 2026 is exempt (except for electricity and hydrogen).
- Deadline for declaration and surrender of certificates: 30 September 2027, then every year by 30 September.
- Content: quantities per type of goods, embedded emissions, number of certificates and, where applicable, verification reports.
- The Commission has not yet published a technical format for the declaration (as of 11 October 2026).
Who has to submit the declaration?
Every authorised CBAM declarant who imported more than 50 t of CBAM goods in 2026, as well as anyone who imported electricity or hydrogen. According to the amending regulation, the exemption below the threshold expressly also applies to importers who are already authorised.
Submission of the declaration can be delegated to another person acting on behalf and in the name of the declarant (Art. 5(7a)). That person needs an EORI number and must be established in an EU Member State. The declarant remains responsible.
What goes into it?
Art. 6(2) of the CBAM Regulation requires four items for the previous year:
- the total quantity of each type of goods – in tonnes, for electricity in megawatt hours
- the total embedded emissions of these goods, per tonne or per MWh
- the total number of certificates to be surrendered – after deducting any carbon price paid in the country of origin and the free allocation adjustment
- where applicable, copies of verification reports if actual emissions are used
Which imports count?
All CBAM imports of the calendar year – including the first tonnes imported before the threshold was exceeded. In addition, detailed information per installation, country of origin and type of goods is foreseen to support the totals. Anyone who records their imports properly throughout the year – CN code, net mass, country of origin, producer – already has the basis of the declaration.
Where does the emission data come from?
Without verified data from the producer, the official default values per country of origin and CN code apply with a mark-up – for imports in 2026 10% for steel, aluminium, cement and hydrogen, 1% for fertilisers. Indirect emissions only count for cement and fertilisers.
Actual emissions may only be used if an accredited verifier has confirmed them. Verifiers can register in the CBAM registry from 1 September 2026 at the earliest; the Commission expects the first verification reports for 2026 from January 2027. Producers outside the EU can store their installation and emission data in the operator portal of the CBAM registry, where declarants retrieve it.
How a carbon price paid in the country of origin is deducted is governed by an implementing act that is still pending. Anyone using default values can only claim the deduction via standard default carbon prices.
How many certificates are due?
Embedded emissions minus the free allocation adjustment – in 2026, 97.5% of the allocation remains – give the number of certificates. For imports in 2026 the average price of the quarter of import is paid: Q1: €75.36 · Q2: €75.28 · Q3: €82.32 · Q4: not yet published.
Format and submission: what is known
The declaration is submitted in the CBAM registry, with access via EU Login. As of 11 October 2026 the Commission has not published a technical format – such as an XML schema – or an interface for the annual declaration; the implementing act on the standard format (Art. 6(6)) is still pending. According to the Commission's user manual, the first declaration will be submitted during 2027.
As soon as the format and input screen are known, we will update this page.
How CBAMfix helps
CBAMfix records your imports from documents throughout the year, calculates embedded emissions and certificates with the official default values and benchmarks, shows which data is still missing and exports everything as a CSV template for entry in the registry. If you don't want a subscription, use the one-off access “Annual declaration, one-off” for €149.00 incl. VAT and 60 days.
Frequently asked questions
When is the CBAM annual declaration for 2026 due?
By 30 September 2027. The certificates must also be surrendered by then. After that, 30 September applies every year for the previous year.
Are there still quarterly reports in the definitive period?
No. Instead of the quarterly reports of the transitional period there is one declaration a year. Separately, from 2027 a holding obligation for certificates applies at the end of each quarter.
Do I have to submit a declaration if I stay below 50 tonnes?
No, not even as an already authorised declarant. Exception: electricity and hydrogen, for which there is no threshold.
Can someone else submit the declaration for me?
Yes. Submission can be delegated to a person with an EORI number established in an EU Member State who acts in your name. You remain responsible.
Is there already an XML format for the declaration?
No, as of 11 October 2026 the Commission has not published a format or interface for the annual declaration. The declaration is submitted in the CBAM registry.
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Try free for 14 daysMore topics
- Am I subject to CBAM?
- CBAM deadlines 2026 and 2027
- Which documents do I need for CBAM?
- CBAM for DDP deliveries and importers outside the EU
- The CBAM 50-tonne mass threshold
- Becoming an authorised CBAM declarant
- CBAM for customs agencies and forwarders
- CBAM certificates: price, purchase and surrender
- CBAM for electricity and hydrogen
- CBAM for iron and steel
- CBAM for aluminium
- CBAM for cement and clinker
- CBAM for fertilisers
Legal status as of 11 October 2026. Based on Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 and the related implementing acts. CBAMfix does not replace legal, tax or customs advice; the Regulation and the guidance of the competent authority are authoritative.