CBAM deadlines 2026 and 2027
CBAM is an obligation with fixed dates. Here are all deadlines of the definitive period in chronological order – with legal basis and what you have to do at each point.
At a glance
- Authorised CBAM declarant status before exceeding 50 t; the competent authority has 120 days, longer if it requests more information.
- CBAM certificates are sold from 1 February 2027. Nothing is bought in 2026 yet.
- From 2027: at the end of each quarter at least 50% of the embedded emissions so far covered by certificates.
- First annual declaration and surrender of certificates for 2026 by 30 September 2027.
All dates at a glance
The deadlines follow from Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 and the implementing acts.
| Date | What applies | |
|---|---|---|
| since 1 January 2026 | Definitive period: above the 50 t threshold, CBAM goods may only be imported by authorised CBAM declarants.Art. 2a, 4 CBAM Regulation | Art. 2a, 4 CBAM Regulation |
| 31 March 2026 | Anyone who had applied for authorisation by this date could provisionally continue importing until the decision.Art. 17(7a) CBAM Regulation | Art. 17(7a) CBAM Regulation |
| before exceeding 50 t | Apply for authorisation. The competent authority has 120 days, longer if it requests more information.Art. 5(1b) CBAM Regulation; Art. 4, 5 Implementing Regulation (EU) 2025/486 | Art. 5(1b) CBAM Regulation; Art. 4, 5 Implementing Regulation (EU) 2025/486 |
| from 1 September 2026 | Accredited verifiers can register in the CBAM registry – a prerequisite for verified actual emissions.Art. 10a(1) CBAM Regulation | Art. 10a(1) CBAM Regulation |
| 4 January 2027 | Announced: the Commission publishes the certificate price for imports in Q4 2026.Implementing Regulation (EU) 2025/2548 | Implementing Regulation (EU) 2025/2548 |
| 1 February 2027 | Sale of CBAM certificates on the common central platform begins.Art. 20(1), Art. 36(2) CBAM Regulation | Art. 20(1), Art. 36(2) CBAM Regulation |
| every quarter end from 2027 | At least 50% of the embedded emissions of all goods imported since the start of the year held as certificates in the registry account.Art. 22(2) CBAM Regulation | Art. 22(2) CBAM Regulation |
| 30 September 2027 | First CBAM annual declaration for 2026 imports in the CBAM registry and surrender of certificates.Art. 6(1), Art. 22(1) CBAM Regulation | Art. 6(1), Art. 22(1) CBAM Regulation |
| 31 October 2027 | Last day to request repurchase of excess certificates (limited).Art. 23 CBAM Regulation | Art. 23 CBAM Regulation |
| 1 November 2027 | Certificates bought for 2026 that were neither surrendered nor repurchased are cancelled without compensation.Art. 24 CBAM Regulation | Art. 24 CBAM Regulation |
The annual cycle from 2027
From 2027 the cycle repeats every year: buy certificates on an ongoing basis and meet the holding obligation at each quarter end, declare and surrender for the previous year by 30 September, request repurchase by 31 October, and on 1 November remaining certificates from the previous year are cancelled.
From 2027 the certificate price is set weekly; for imports in 2026, by contrast, the average price of the quarter of import applies.
Holding obligation after exceeding the threshold
Anyone who exceeds the threshold only during the year must meet the holding obligation by the end of the quarter following the one in which it was exceeded (Art. 22(2a)).
It is calculated either with default values without mark-up or – for the same CN code and country of origin – with the certificates surrendered in the previous year. The free allocation adjustment is deducted.
The deadline that is most easily missed
There is time until 30 September 2027 for the annual declaration. The authorisation is a different matter: it must be in place before the threshold is exceeded, and the competent authority (in Germany: DEHSt) has 120 days to decide (Art. 4 Implementing Regulation (EU) 2025/486); if it requests more information, the period is extended. Anyone who acts only when the goods are already on their way risks them getting stuck at the border.
That is why it pays to count and project the imported quantity on an ongoing basis – exactly what CBAMfix Threshold Watch does.
Frequently asked questions
When is the first CBAM annual declaration due?
For the import year 2026 by 30 September 2027. After that every year by 30 September for the previous year.
Do I have to buy CBAM certificates in 2026?
No. Sales start on 1 February 2027. For imports in 2026, however, the price follows the quarter in which the goods were imported.
Is there a quarterly obligation in 2026?
No. The holding obligation at quarter end only applies from 2027. Quarterly reports as in the transitional period no longer exist in the definitive period.
When do I have to apply for authorisation?
As soon as it is foreseeable that you will exceed the 50 t threshold – the authorisation must be in place before you exceed it. The competent authority has 120 days, longer if it requests more information. For electricity and hydrogen the obligation applies from the first import.
Stay on top of the 50-tonne threshold
CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.
Try free for 14 daysMore topics
- Am I subject to CBAM?
- The CBAM annual declaration for 2026
- 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.