CBAM Annual Declaration 2026 — Everything You Need to Know Before May 31

1. What is CBAM?

The Carbon Border Adjustment Mechanism (CBAM) is established by Regulation (EU) 2023/956 of the European Parliament and of the Council. Its primary purpose is to prevent carbon leakage — the risk that EU climate ambitions are undermined when companies move production to countries with less stringent carbon pricing, or when EU-produced goods are displaced by cheaper, carbon-intensive imports.

CBAM works by requiring importers of certain carbon-intensive goods to purchase CBAM certificates corresponding to the embedded greenhouse gas emissions of those goods. This creates a carbon cost equivalent to what EU producers pay under the EU Emissions Trading System (EU ETS), levelling the competitive playing field.

CBAM is administered by the CBAM Registry — an EU-level system operated by the European Commission. Member State customs authorities handle authorisation of declarants and enforcement.

2. Annual Declaration Deadline — 31 May 2026

Under Article 6 of Regulation (EU) 2023/956, each authorised declarant must submit an annual CBAM declaration by 31 May of the year following the calendar year of import. For the first full financial year (2025), the deadline is 31 May 2026.

The Annual Declaration covers the entire preceding calendar year — in this case, 1 January 2025 to 31 December 2025. It is submitted via the CBAM Registry portal. Late filing or non-filing triggers penalty proceedings by the competent authority.

3. Goods Covered (Annex I)

CBAM currently applies to goods listed in Annex I of Regulation (EU) 2023/956. These six sectors were selected because they are carbon-intensive and at significant risk of carbon leakage under the EU ETS.

The European Commission has proposed extending CBAM's scope to additional sectors beyond 2026, including organic chemicals, polymers and other products. Importers in adjacent sectors should monitor legislative developments closely.

4. What the Annual Declaration Must Contain

Under Article 6(2) of Regulation (EU) 2023/956 and the relevant implementing regulations, the CBAM Annual Declaration must include the following elements for each category of goods imported during the preceding calendar year:

• Total quantity of each type of goods In megawatt-hours for electricity, in tonnes for all other goods. Broken down by country of origin.
• Country of origin The country where the goods were produced (not shipped from). Goods from countries with equivalent carbon pricing may be eligible for reduced CBAM obligation.
• Total embedded emissions Expressed in tonnes of CO2 equivalent (tCO2e) per tonne of goods (or per MWh for electricity). Distinguish between direct and indirect emissions where required.
• Carbon price paid in the country of origin If a carbon price was paid in the country of origin for the goods' embedded emissions, this can be deducted from the CBAM obligation. Must be evidenced by documentation.
• CBAM certificates to be surrendered The number of CBAM certificates corresponding to the total declared embedded emissions, net of any carbon price already paid in origin country.
• Verification statement For importers where total declared emissions exceed 10,000 tCO2e per year, a statement from an accredited verifier is required confirming the accuracy of the emission data.

5. Calculating Embedded Emissions

Correctly calculating embedded emissions is the most technically demanding part of CBAM compliance. Embedded emissions are the greenhouse gas emissions generated during the production of the imported goods at the installation level.

Direct vs Indirect Emissions

Direct emissions are those released during the production process itself (combustion, chemical reactions). Indirect emissions arise from the electricity consumed in the production process. The scope depends on the goods category:

• Iron and steel, cement, fertilisers, hydrogen: direct emissions only (with some upstream exceptions)
• Aluminium and electricity: direct and indirect emissions (because electricity production's carbon intensity is highly relevant)

Actual Values vs Default Values

Importers may use either actual emission values obtained from the production installation (via installation-level monitoring reports) or default values published by the European Commission in implementing regulations. Default values are typically higher than actual values for well-managed installations, so there is a financial incentive to collect actual data.

Verification Requirement

If your total declared embedded emissions exceed 10,000 tCO2e per year, you must obtain a verification statement from an accredited verifier — a third party accredited under ISO 14065 or equivalent. The verifier reviews your calculation methodology and the underlying data. Budget sufficient time for this process, as accredited verifiers have limited capacity.

6. CBAM Certificates

CBAM certificates are the financial instrument through which the carbon cost is applied. Each certificate corresponds to one tonne of CO2 equivalent of embedded emissions.

Price

The price of CBAM certificates is set weekly by the European Commission and equals the average price of EU ETS allowances (EUAs) in the preceding week, expressed in €/tCO2e. As of early 2026, EUA prices have fluctuated between approximately €50 and €70 per tonne, so CBAM certificate prices are in the same range.

Purchasing Certificates

Certificates are purchased through the CBAM Registry — the EU-level platform managed by the European Commission. Authorised declarants create an account, purchase certificates at the weekly price, and hold them until the Annual Declaration is filed.

Surrender

Certificates are surrendered when the Annual Declaration is filed — by 31 May. The number surrendered must equal the total embedded emissions declared in the Annual Declaration, minus any carbon price already paid in the country of origin. Excess certificates (unused) can be re-purchased by the Commission (repurchased at the price they were bought, up to one-third of the total purchased).

7. Penalties for Non-Compliance

CBAM penalties are significant and enforcement responsibility lies with Member State customs authorities. Article 26 of Regulation (EU) 2023/956 establishes the minimum penalty framework.

Member States may impose higher penalties than the EU minimum under their national customs legislation. Some Member States have indicated they will treat CBAM violations similarly to customs fraud, which can attract criminal penalties.

8. Action Plan — 5 Steps Before 31 May 2026

9. CBAM Declaration Tool — cbam.saaslab.pl

cbam.saaslab.pl is a dedicated CBAM compliance tool that helps authorised declarants manage the full declaration workflow:

• Emission calculator: enter quantities and CN codes, select actual or default emission factors, and calculate embedded emissions automatically — including upstream emission scope by product category
• Declaration builder: guided form that populates all required Annual Declaration fields, validates data completeness, and exports in the format required for CBAM Registry submission
• Certificate tracker: monitor your certificate balance against your current import volume and the quarterly 80% minimum hold requirement, with alerts when top-up purchases are needed
• Supplier data management: collect, store and version-control emission data received from suppliers, with audit trail documentation