When did EU CBAM enter full compliance?

EU CBAM entered full compliance on 1 January 2026. Importers must now hold Authorised Declarant status and manage CBAM certificates for embedded emissions in covered goods.

When is the first EU CBAM certificate surrender deadline?

The first EU CBAM 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 is targeted to go live on 1 January 2027. It will apply to imports of steel, aluminium, cement, ceramics, fertilisers, glass, and hydrogen into Great Britain.

CBAM Key Dates & Deadlines | CBAM-Assured

Compliance calendar

CBAM Key Dates & Deadlines

Q: How long must CBAM records be retained?

All CBAM declarations, emissions reports, certificate records, supplier verification data, and correspondence must be retained for a minimum of five years.

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

2027

UK CBAM target year

31 May

Annual EU surrender deadline

5 years

Record retention required

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

Final quarterly transitional report submitted. Certificate purchase obligation begins from the following day.

1 Jan 2026

You are here

Full compliance in force

Importers must hold and manage CBAM certificates. Authorised Declarant status required to import. Penalties apply under Article 26 for non-compliance.

31 May 2027

Key deadline

First certificate surrender

CBAM certificates covering all embedded emissions from 2026 imports must be surrendered via the CBAM Registry. Begin purchasing now.

31 May annually

Recurring surrender deadline

Annual surrender repeats on 31 May each year, covering the preceding calendar year's imports. Permanent obligation.

2034 (indicative)

Full phase-in

Planned coincidence with phase-out of free EU ETS allowances. Commission to review scope ahead of this date.

UK CBAM — Finance Act 2025

Applies to imports into Great Britain

In development

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

Finance Bill introduced

UK CBAM included in Finance Bill 2024–25. In-scope sectors confirmed: aluminium, cement, ceramics, fertilisers, glass, hydrogen, iron & steel.

Early 2025

Finance Act receives Royal Assent

UK CBAM framework established in primary legislation. Secondary legislation, HMRC guidance, and registration systems to follow.

2025–2026

Current phase

Secondary legislation & guidance

HMRC developing secondary legislation, UK carbon price rate methodology, and registration portal. Industry working groups active. Monitor HMRC and DESNZ publications for updates.

Late 2026

Watch

Registration window opens

HMRC expected to open UK CBAM registration portal ahead of go-live. Businesses importing in-scope goods must register in advance.

1 Jan 2027

Target date

UK CBAM charge goes live

UK CBAM charge applies to imports of in-scope goods into Great Britain. Charge calculated against UK Emissions Trading Scheme (UK ETS) carbon price.

TBC 2027–28

First UK accounting period

First UK CBAM accounting and payment period. Exact dates subject to secondary legislation confirmation.

2028+

Scope review

UK government indicated post-implementation scope review. Additional sectors — including chemicals and ceramics — may be added.

Critical deadlines at a glance

31 May

2027 — then annually

First EU certificate surrender

CBAM certificates covering all embedded emissions from 2026 imports must be surrendered via the CBAM Registry. Begin purchasing certificates now to manage price risk.

1 Jan

2027 (target)

UK CBAM charge applies

UK CBAM charge goes live on imports of in-scope goods into Great Britain. Registration with HMRC required in advance. Ceramics and glass included — broader scope than EU CBAM.

Now

2026

EU Authorised Declarant registration

Importing without Authorised Declarant status is a breach of Regulation 2023/956. Processing time is 4–8 weeks. Apply immediately if not yet registered.

Ongoing

Quarterly

Certificate purchasing strategy

CBAM certificate prices fluctuate daily with the EU ETS. Purchasing quarterly rather than in a single year-end block manages price risk and cash flow.

5 years

minimum retention

Both

Record keeping obligation

All declarations, emissions reports, certificate purchase records, supplier verification data, and correspondence must be retained for a minimum of five years.

Watch

2026

UK secondary legislation

HMRC secondary legislation confirming UK CBAM rates, registration process, and accounting periods expected during 2026. Monitor gov.uk and HMRC CBAM guidance pages.

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 deadline31 May annually — certificate surrender

UK CBAM

StatusLegislation passed — implementation 2027

Legal basisFinance Act 2025 (secondary legislation TBC)

Applies toImports into Great Britain

SectorsSteel, aluminium, cement, ceramics, fertilisers, glass, hydrogen

Carbon priceLinked to UK ETS carbon price

MechanismTax charge via HMRC — exact model subject to secondary legislation

Administered byHMRC

Key deadline1 Jan 2027 — charge goes live (target)

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

Certificate prices fluctuate with the EU ETS. Purchasing quarterly or monthly reduces year-end price risk and smooths cash flow.

Monitor UK CBAM secondary legislation

HMRC secondary legislation, rate-setting methodology, and registration portal updates expected throughout 2026. 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.

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