Transitional CBAM Registry
What It Was, What Replaced It in 2026
The transitional CBAM registry ended on 31 December 2025. If you reported quarterly during 2023-2025, your obligations haven't ended — they've changed. We explain exactly what the transitional registry was, what replaces it from 2026, and how CBAM reporting and declaration work today.
In short: the transitional CBAM registry (2023-2025) was a quarterly reporting portal with no financial obligations. It was replaced by the definitive CBAM Registry, active since 1 January 2026, where authorised declarants hold an account, purchase certificates and submit an annual declaration. The two are not the same platform, and authorisation from the transitional period does not carry over automatically.
What was the transitional CBAM registry (2023-2025)
Between 1 October 2023 and 31 December 2025, importers of CBAM products (steel, aluminium, cement, fertilisers, electricity, hydrogen) had a single obligation: quarterly reporting of embedded emissions in imported goods, through the CBAM portal made available by the European Commission (accessed via the EU Trader system). There was no payment or certificate-holding obligation — the transitional period was exclusively about data collection, to prepare both authorities and companies for the definitive phase. The last quarterly report of this period, for Q4 2025, had a filing deadline of 31 January 2026.
Why quarterly reporting no longer exists from 2026
Since 1 January 2026, CBAM has entered its definitive phase. Quarterly reporting with no financial obligations has been replaced by an annual cycle: authorised declarants track emissions throughout the year, purchase CBAM certificates (starting February 2027, for 2026 emissions) and submit a single annual declaration. In practice, reporting granularity has decreased (from quarterly to annual), but the stakes have increased — the annual declaration now also involves a real financial obligation, through the surrender of certificates.
The definitive CBAM Registry — what it is and who registers
The definitive CBAM Registry is the platform managed by the European Commission, interconnected with national customs systems (TARIC, EU Customs Single Window), through which authorised declarant status, certificate purchases and annual declaration filing are managed. Any company importing CBAM-scope products above the de minimis threshold of 50 tonnes/year (no threshold for electricity and hydrogen) registers here — regardless of whether it reported during the transitional period.
| Aspect | Transitional registry (2023-2025) | Definitive CBAM Registry (from 2026) |
|---|---|---|
| Reporting cadence | Quarterly | Annual |
| Financial obligation | No | Yes — CBAM certificates |
| Authorisation required | No, registration only | Yes — authorised CBAM declarant status |
| Status today | Closed since 1 January 2026 | Active, the only valid platform |
How to register as an authorised CBAM declarant
The authorisation request is submitted to the competent customs authority in Romania. The process can take up to 120 days, which is why we recommend applying early, before you approach the de minimis threshold. Once approved, you get access to the definitive CBAM Registry, where you manage your account, track reported emissions and, from February 2027, purchase the necessary certificates.
- 01
Check if you're in scope
Do you import CBAM Annex I products above the de minimis threshold of 50 tonnes/year (or any quantity, for electricity/hydrogen)?
- 02
Submit the authorisation request
To the competent national customs authority, with company documents and a description of your import activity.
- 03
Wait for approval
The legal deadline is up to 120 days — plan ahead, not at the last moment.
- 04
Activate your CBAM Registry account
Once authorised, you get access to the definitive platform for tracking, certificates and declaration.
CBAM 2026 Checklist
The 10 critical obligations, the official deadline calendar through 2027 and an actionable four-phase plan — for importers and exporters in Romania.
What a CBAM declaration is and what it contains
The annual CBAM declaration is the document through which the authorised declarant officially communicates, for a calendar year, the quantity of imported products, their origin, tariff classification (CN code) and embedded carbon emissions — direct and, where applicable, indirect. In practice, it's an import-level carbon footprint declaration: it doesn't describe your company's footprint, but that of the goods you brought into the EU. The declaration is filed through the definitive CBAM Registry, and the deadline for the 2026 compliance year is 30 September 2027 — moved from 31 May 2027 under the Omnibus package (EU) 2025/2083. By the same date, the declarant must also surrender the number of CBAM certificates corresponding to the declared emissions.
Continuity, not a reset: if you reported quarterly during the transitional period, that data history remains useful — it helps you estimate emission volumes for the annual declaration — but it does not replace authorisation. Without active authorised CBAM declarant status in the definitive registry, you risk having your imports blocked at customs from 2026.
Frequently asked questions about the CBAM registry
Does the transitional CBAM registry still exist in 2026?
No. The transitional CBAM registry operated between October 2023 and December 2025, with the last quarterly report due by 31 January 2026 (for Q4 2025). Since 1 January 2026, it has been fully replaced by the definitive CBAM Registry.
What is the difference between quarterly reporting and the annual CBAM declaration?
Quarterly reporting (2023-2025) carried no financial obligations — it was purely data collection. The annual declaration (from 2027, for the 2026 compliance year) also involves surrendering a number of CBAM certificates equal to the declared embedded emissions.
How do I register in the definitive CBAM Registry?
You submit an authorisation request as a CBAM declarant to the competent customs authority in Romania. The process can take up to 120 days, which is why we recommend applying well before you approach the de minimis threshold.
What happens if I reported in the transitional registry but didn't get authorised for 2026?
Authorisation from the transitional period does not carry over automatically. Without active authorised CBAM declarant status in the definitive registry, imports of CBAM products can be blocked or subjected to additional customs checks.
Where do I actually submit the CBAM declaration?
Through the CBAM Registry portal, managed by the European Commission and interconnected with national customs systems (TARIC, EU Customs Single Window). Access requires an authorised CBAM declarant account.
Need help with
CBAM registration or declaration?
CarbonDRI helps you with authorised declarant status, embedded emissions calculation and preparing the annual declaration.
Also see: CBAM Calendar 2026-2027 · CBAM Importers Guide · CBAM Exporters Guide