When did EU CBAM enter full compliance?

EU CBAM entered its definitive period on 1 January 2026. Importers of more than 50 tonnes of in-scope goods a year must hold authorised CBAM declarant status, and embedded emissions in 2026 imports must be covered by certificates surrendered in 2027.

When is the first EU CBAM certificate surrender deadline?

The first EU CBAM declaration and certificate surrender deadline is 30 September 2027, covering embedded emissions from all 2026 imports. Certificate sales begin 1 February 2027.

When does UK CBAM start?

UK CBAM starts on 1 January 2027 under the Finance Act 2026. It applies to imports of aluminium, cement, fertilisers, hydrogen, and iron and steel. Glass and ceramics were proposed but left out. Importers register with HMRC once their in-scope imports reach £50,000.

How long must CBAM records be retained?

EU CBAM records must be kept until the end of the fourth year after the year in which the declaration is made. UK CBAM records must be kept for six years.

Compliance calendar

CBAM Key Dates & Deadlines

Every critical milestone across both the EU and UK Carbon Border Adjustment Mechanisms — from the transitional period through to full EU compliance and UK implementation in 2027.

2026

EU full compliance year

1 Jan 2027

UK CBAM start date

30 Sep

Annual EU declaration and surrender deadline

£50,000

UK CBAM registration threshold

Filter by

Regime timelines — side by side

EU CBAM — Regulation 2023/956

Applies to imports into EU member states

In force

Oct 2023

Transitional period begins

Quarterly emissions reporting obligation starts for importers of in-scope goods. No certificate purchase required during this phase.

31 Jan 2024

First quarterly report due

First CBAM transitional period report covering Q4 2023 imports submitted to the CBAM Registry.

Throughout 2024–25

Quarterly reports continue

Reports due 31 Jan, 30 Apr, 31 Jul, 31 Oct each year throughout the transitional period.

31 Dec 2025

Transitional period ends

The last quarterly report, covering Q4 2025, was due by 31 January 2026.

1 Jan 2026

You are here

Definitive period begins

Importing more than 50 tonnes of in-scope goods a year requires authorised CBAM declarant status, and embedded emissions in 2026 imports must be covered by certificates surrendered in 2027. Penalties apply under Article 26 for non-compliance.

1 Feb 2027

Certificate sales open

Certificates for 2026 imports are priced at the average for the quarter of import; from 2027 the price is set weekly.

2027 onwards

Quarterly holding rule

At the end of each quarter, hold certificates covering at least 50% of the embedded emissions in goods imported since the start of the year.

30 Sep 2027

Key deadline

First declaration and certificate surrender

First annual CBAM declaration and certificate surrender, covering 2026 imports, through the CBAM Registry.

30 Sep annually

Recurring declaration and surrender

The declaration and surrender repeat on 30 September each year for the previous calendar year's imports.

2034

Full phase-in

Under current law the CBAM factor reaches zero and importers pay the full carbon cost. An EU ETS reform now under negotiation would extend free allocation to 2038.

UK CBAM — Finance Act 2026

Applies to imports into Great Britain

Law in place

Dec 2023

UK CBAM consultation published

HMRC and DESNZ publish consultation on UK CBAM design. Sectors, rate methodology, and administration model consulted on.

Oct 2024

Design confirmed

Government confirms the design. In scope: aluminium, cement, fertilisers, hydrogen, iron and steel. Glass and ceramics, proposed earlier, are left out.

18 Mar 2026

Finance Act 2026 receives Royal Assent

The UK CBAM is put into primary legislation.

Sep–Oct 2026

Rulebook complete

Regulations and guidance published

The emissions and verification regulations (SI 2026/995) and the rate and relief regulations (SI 2026/809) are made, and HMRC publishes illustrative rates, default values and verification guidance on 16 October.

From 1 Jan 2027

Watch

Registration

Register once your in-scope imports reach £50,000, either expected within the next 30 days or over the previous 12 months. Only imports from 1 January 2027 count.

1 Jan 2027

Start date

UK CBAM starts

The charge is weight × emissions intensity (verified actual or HMRC default) × the quarterly CBAM rate.

31 May 2028

First return and payment

The first return and payment cover the whole of 2027. Returns are quarterly after that.

From 2029

Country-specific default values

Country-specific default values are planned, and the 10% default value mark-up will be reviewed.

Critical deadlines at a glance

30 Sep

2027, then annually

EU declaration and surrender

Declaration and surrender for the previous year's imports. Certificates go on sale on 1 February 2027.

1 Jan

2027

UK CBAM starts

Register with HMRC once you reach £50,000 of in-scope imports. It covers aluminium, cement, fertilisers, hydrogen, iron and steel, and unlike the EU scheme it excludes electricity.

Now

2026

EU Authorised Declarant registration

Importing without Authorised Declarant status is a breach of Regulation 2023/956. Processing times vary by member state, so apply now if you import more than 50 tonnes a year.

From Feb

2027

Certificate purchasing strategy

Certificate prices are quarterly for 2026 imports and weekly from 2027. Buying through the year spreads price risk.

Records

EU and UK

Both

Record keeping obligation

EU: until the end of the fourth year after the declaration year. UK: six years.

Watch

Q4 2026

UK CBAM rates

The UK rulebook is complete. HMRC publishes the Q1 2027 CBAM rates before the end of 2026.

EU CBAM vs UK CBAM — key differences

EU CBAM

StatusIn force from Jan 2026

Legal basisRegulation (EU) 2023/956

Applies toImports into EU member states

SectorsSteel, aluminium, cement, fertilisers, hydrogen, electricity

Carbon priceLinked to EU ETS weekly auction price

MechanismCertificate purchase & surrender via CBAM Registry

Administered byEU competent authorities per member state

Key deadline30 September annually — declaration and surrender

UK CBAM

StatusLaw in place — starts 1 January 2027

Legal basisFinance Act 2026 and regulations made in 2026

Applies toImports into Great Britain

SectorsAluminium, cement, fertilisers, hydrogen, iron and steel

Carbon priceQuarterly CBAM rate set from UK ETS prices, reduced by a free allocation adjustment

MechanismTax paid to HMRC on a CBAM return

Administered byHMRC

Key deadline31 May 2028 — first return and payment

Ongoing obligations — no fixed date

These obligations apply continuously — not just at deadline dates

Unlike single-event deadlines, these require active management throughout the year.

Maintain EU declarant registration

Notify the CBAM Registry of any changes to your business structure, ownership, trade volumes, or contact details promptly.

Update supplier emissions data annually

Verified actual emissions data must be refreshed each year. Outdated data defaults back to conservative benchmark values, increasing your certificate cost.

Purchase EU CBAM certificates throughout the year

From February 2027, buying certificates through the year rather than in one block spreads price risk and smooths cash flow.

Track HMRC's quarterly CBAM rates

HMRC publishes the UK CBAM rate before the start of each quarter. Subscribe to HMRC CBAM updates at gov.uk.

Not sure where you stand against these deadlines?

Our compliance review covers your EU Authorised Declarant status, certificate purchasing position, supplier MRV data quality, and UK CBAM readiness — all in one structured assessment.

View all resources Book a compliance review