CBAM Calendar 2026-2027 —
Deadlines, Certificates and Reporting
From 1 January 2026 the CBAM definitive phase begins, but carbon certificates cannot yet be purchased — the platform only opens on 1 February 2027. This guide explains, step by step, every deadline: when you must keep records of emissions, when you can buy CBAM certificates, and when the annual declaration is due.
Full CBAM timeline: from transition to the definitive system
The base Regulation (EU) 2023/956 and the implementing Regulation (EU) 2023/1773 were substantially amended by the Omnibus package (EU) 2025/2083, which entered into force on 20 October 2025. The table below integrates all updated deadlines.
| Period | What happens | Action required |
|---|---|---|
| Oct. 2023 – Dec. 2025 | Transition period: quarterly reporting of embedded emissions, no payment obligation. | Collect data from non-EU suppliers. |
| 1 Jan. 2026 | Definitive phase starts. De minimis threshold rises to 50 tonnes/year. | Obtain authorised CBAM declarant status before exceeding the threshold. |
| All of 2026 | No CBAM certificate is available for purchase. The sales platform is not yet open. | Keep continuous emissions records — the obligation is deferred, not waived. |
| 1 Feb. 2027 | The centralised CBAM platform opens. Declarants purchase certificates retroactively for 2026 emissions. | Budget for the retroactive purchase plus ongoing 2027 emissions. |
| 31 Mar / 30 Jun / 30 Sep / 31 Dec (from 2027) | Quarterly check: the declarant must hold at least 50% of the certificates corresponding to cumulative reported emissions (reduced from 80% by the Omnibus package). | Monitor certificate holdings vs. reported emissions. |
| 30 Sep. 2027 | Final deadline for the annual CBAM declaration for 2026 + 100% certificate coverage. (Moved from 31 May 2027 by the Omnibus package.) | Submit the declaration and ensure full coverage. |
Why there are no certificates to buy in 2026
One of the most common misunderstandings is assuming that since the CBAM definitive phase starts on 1 January 2026, certificates must be purchased right away. That is not the case. The centralised platform through which the European Commission sells CBAM certificates only opens on 1 February 2027 — a deadline postponed from the original plan, also via the Omnibus package. For the 2026 compliance year, this is a deferral, not a waiver, of obligations: embedded emissions from imports made in 2026 must still be monitored and reported as usual, while the financial reconciliation (purchasing the corresponding certificates) happens retroactively starting February 2027, with full settlement at the 30 September 2027 annual declaration.
Companies that assume "nothing happens in 2026" because certificates cannot be bought risk reaching 2027 with incorrectly reported emissions and no budget prepared for the retroactive purchase. Records must be kept continuously, from day one of 2026.
The quarterly 50% holding mechanism — how it works from 2027
Once the platform is operational, every authorised CBAM declarant must check, at the end of each calendar quarter, whether their account holds at least 50% of the number of certificates corresponding to cumulative reported embedded emissions since the start of that year. This rule was reduced from 80% to 50% by the Omnibus package, specifically to ease the liquidity pressure on importers.
| Checkpoint | Requirement |
|---|---|
| 31 March | Minimum 50% of certificates required for Jan–Mar reported emissions. |
| 30 June | Minimum 50% of certificates required for cumulative Jan–Jun emissions. |
| 30 September | Minimum 50% of certificates required for cumulative Jan–Sep emissions. |
| 31 December | Minimum 50% of certificates required for full-year cumulative emissions. |
| At the annual declaration (30 Sep. the following year) | 100% coverage — all certificates must be held and surrendered. |
For the 2026 compliance year specifically, since the platform does not physically exist in 2026, these quarterly checks do not apply during the year itself — the entire reconciliation (both interim checks and the final 100% coverage) is concentrated retroactively in the February–September 2027 window.
What you need to do, by role
EU importer
Obtain authorised CBAM declarant status before exceeding 50 tonnes/year. Collect embedded emissions from suppliers (or use default values). Budget for the retroactive certificate purchase from 2027.
Non-EU exporter / producer
Prepare verified data on direct and indirect product emissions. Communicate it to EU clients via a structured declaration. The data can be reused for your own Scope 3.
Companies with both roles
If you import CBAM raw materials and produce for export, you need dual record-keeping: as a declarant for what you import, and as a data provider for what you export.
De minimis threshold: 50 tonnes/year of imported CBAM products (raised by the Omnibus package). Below this threshold, CBAM obligations do not apply. Penalties: fines for a missing declaration or insufficient certificates are €100 per unsurrendered CBAM certificate (amount indexed to inflation), uncapped.
Frequently asked questions about the CBAM calendar
When do I need to become an authorised CBAM declarant?
Before exceeding the de minimis threshold of 50 tonnes/year of imported CBAM products. To operate legally from 1 January 2026, we recommend submitting the authorisation application during 2025.
Can I buy CBAM certificates in 2026?
No. The centralised sales platform opens on 1 February 2027. For 2026 emissions, certificate purchases happen retroactively starting from that date.
What is the quarterly 50% holding rule?
From 2027, at the end of each quarter, the declarant must hold at least 50% of the certificates corresponding to cumulative reported emissions since the start of the year. The annual declaration requires 100% coverage.
Are CBAM certificates the same as Romania's green certificates?
No. Green certificates are a national support mechanism for renewable energy (Law 220/2008), entirely separate from CBAM. CBAM is an EU instrument taxing emissions embedded in imports.
What is the deadline for the 2026 annual CBAM declaration?
30 September 2027 — a deadline updated by the October 2025 Omnibus package (originally 31 May 2027).
What penalties apply for a missing declaration or certificate shortfall?
The penalty is €100 per unsurrendered CBAM certificate or per tonne of undeclared CO₂, indexed annually to European inflation, uncapped — per Art. 26 of Reg. (EU) 2023/956.
Need help meeting the
CBAM calendar?
CarbonDRI calculates embedded emissions, helps you obtain authorised declarant status, and prepares a personalised CBAM compliance calendar.
See also: CBAM reporting service