Carbon compliance calendar

Installations making CBAM goods receive 95% of their benchmark free allocation, down from 97.5% in 2026. The CBAM obligation on imports rises as free allocation falls.

Certificates covering 2026 imports go on sale to authorised declarants through a central platform. This is the point at which CBAM starts costing real money.

From 2027, at the end of each quarter an importer must hold certificates covering at least 50 per cent of the embedded emissions in everything imported since 1 January.

The annual CBAM declaration covering 2026 imports is submitted and the certificates are surrendered. Moved here from the original 31 May 2027.

Where embedded emissions are declared with default values rather than verified actual values, the mark-up rises from 20% to 30% for iron and steel, aluminium, cement and hydrogen. Fertilisers stay at 1%.

Under current law the CBAM factor steps down to 90%.

A Commission proposal of 17 July 2026 would reintroduce 15% of the phased-out free allocation for CBAM sectors from 2028 and extend the phase-out to 2038. It is still being negotiated and is not law.

Under current law the CBAM factor steps down to 77.5%, the first large step in the phase-out.

Under current law about half of benchmark free allocation remains for CBAM goods.

Under current law the CBAM factor steps down to 39%.

Under current law the CBAM factor steps down to 26.5%.

Under current law the last year in which any CBAM factor applies.

No CBAM factor applies from 2034, so CBAM certificates cover the full embedded carbon cost. The 17 July 2026 proposal would extend the phase-out to 2038 if adopted.