CBAM declaration and certificates: buying, holding and surrendering
Every authorised CBAM declarant submits one CBAM declaration per year and surrenders the matching number of CBAM certificates. The first cycle covers goods imported in 2026: certificates go on sale on 1 February 2027 and the declaration is due on 30 September 2027.
The annual CBAM declaration
By 30 September each year, for the goods imported in the previous calendar year, the declarant submits in the CBAM Registry:
- the total quantity of each type of CBAM good imported, in tonnes (MWh for electricity);
- the total embedded emissions, using verified actual values or default values;
- the number of certificates to surrender, after the free allocation adjustment and any reduction for carbon price paid in the country of origin;
- copies of verification reports for actual emissions data.
The deadline was moved from 31 May to 30 September by the 2025 simplification. Competent authorities can review declarations and correct the number of certificates for up to four years after the declaration year.
Buying certificates
- Certificates are sold by Member States on a common central platform run by the Commission, opening on 1 February 2027.
- They cannot be traded between declarants. Only authorised declarants can buy them.
- 2026 imports: certificates are bought in 2027 at the price for the quarter of import ( Q1 €75.36, Q2 €75.28, Q3 €82.32; Q4 to be published on 4 January 2027).
- From 2027, the price is the weekly average of EU ETS auction clearing prices.
The detailed sale and repurchase rules are set in a delegated regulation that the Commission consulted on in July 2026. See certificate price for the latest figures.
Quarterly holding requirement
From 2027, at the end of each quarter the declarant must hold certificates on its registry account covering at least 50 % of the embedded emissions of CBAM goods imported since the start of the year, taking the free allocation adjustment into account. The figure can be based on default values (without mark-up) or on the previous year’s data. There is no holding requirement for 2026 imports. If the account falls short, the authority notifies the declarant, who has one month to top up.
Surrender, repurchase and cancellation
- Certificates are surrendered together with the declaration, by 30 September.
- Excess certificates can be sold back to the Member State at the price paid, on request, within limits set in the Regulation. Certificates bought in 2027 for 2026 imports can only be repurchased in 2027.
- Certificates not surrendered or repurchased are cancelled. Certificates bought for 2026 emissions are cancelled on 1 November 2027 if still on the account.
What to prepare now
- Total your 2026 CBAM imports by CN code and country of origin from customs data.
- Ask suppliers for verified emissions data, or plan for default values (default values by country).
- Estimate the number of certificates and the budget with the cost calculator.
- Plan cash flow for February–September 2027 and the first quarterly holding at the end of Q1 2027.