Carbon compliance countdown — CBAM certificate purchasing prep
Importers have less than three months to transition from quarterly CBAM reporting to certificate purchases when the Carbon Border Adjustment Mechanism’s permanent phase begins on 1 January 2026.
Executive briefing: The EU Carbon Border Adjustment Mechanism (CBAM) shifts from the transitional reporting regime to the permanent phase on 1 January 2026. From that date, importers of aluminium, cement, electricity, fertilisers, hydrogen, and iron and steel must surrender CBAM certificates corresponding to embedded emissions. By October 2025, firms should finalise emissions calculation methodologies, authorised declarant registrations, and financial hedging strategies so that the Q4 2025 report filed in January becomes the baseline for purchasing certificates in 2026.
Compliance checkpoints
- Authorised declarants. Regulation (EU) 2023/956 requires non-EU importers to obtain authorised declarant status from national competent authorities before the permanent phase.
- Embedded emissions. Commission Implementing Regulation (EU) 2023/1773 sets the calculation methods that will underpin certificate obligations—supplier data, default values, and verification need to be validated.
- Financial planning. Certificate prices will track EU ETS allowances; treasury teams must budget, hedge, and integrate CBAM costs into pricing models.
Operational build
- Integrate supplier emissions data into procurement and customs workflows, ensuring evidence is retained for verification.
- Enhance MRV (monitoring, reporting, verification) tooling to support annual CBAM declarations due by 31 May each year starting 2027.
- Simulate cash-flow impacts and adjust contracts to pass through CBAM costs where permissible.
Enablement moves
- Engage customs brokers and logistics partners to align data capture with declarant obligations.
- Update governance frameworks so CFOs and sustainability leaders approve CBAM hedging strategies and risk disclosures.
- Coordinate with EU ETS teams to leverage existing carbon accounting processes and verification partners.
Sources
Zeph Tech prepares importers for CBAM’s permanent phase—aligning MRV, finance, and procurement to manage certificate obligations.