The EC is revising and extending the implementing acts for the working of CBAM in the definitive period. The definitive rules already apply for all imports of CBAM goods since January 1, 2026. 13 acts define how CBAM works covering 3 application areas: administration & customs, purchasing, and finance.
(Last updated 11/08/2026)
Evolving CBAM legislation
As a new instrument, the EU is constantly refining the rules of the EU’s Carbon Border Adjustment Mechanism (CBAM). Some of the relevant acts have been corrected, amended or added since the start of the definitive period.
Starting January 1, importing companies of CBAM goods will face new costs – tied to the purchase of CBAM certificates. These costs will reflect the carbon prices paid by EU producers under the EU’s Emissions Trading System (ETS).
The legal foundation for CBAM is Regulation (EU) 2023/956. It was originally published in May 2023. A wide range of amendments were published in Regulation 2025/2083 in October 2025 to simplify and strengthen the mechanism.
This core regulation empowers the European Commission (EC) to adopt implementing and delegated acts to define the detailed rules for CBAM from 2026.
On December 17, 2025 the EC published the provisional texts for the key pieces of the regulatory puzzle in the definitive phase. The official texts were published a few days later in the EU Journal. As needed, these rules have been revised since then and missing rules have been added.
In addition, the EC published its review of the CBAM application including impacts and recommendations for next steps and proposals for additional measures to strengthen CBAM.
Amending regulatory CBAM foundations
One key objective is to strengthen CBAM to reduce the risks of carbon leakage and to protect the competitiveness of European companies. End of 2025, the EC laid out proposals to expand the CBAM scope and to set-up a decarbonization fund.
The Decarbonisation Fund proposal (2025/0418(COD)) would support energy-intensive industries at high carbon leakage risk. The temporary fund links financial aid to concrete decarbonisation investments. As the proposals to reform the ETS from July 2026, it aims to align decarbonization and competitiveness.
Another proposal (2025/0419(COD)) would amend the CBAM core regulation 2023/956. It would expand the scope of CBAM to additional goods made of iron & steel and aluminum further down metallic value chain. It also includes anti-circumvention measures, and simplified rules for emissions attribution.
These proposals now have to go through the EU’s trilogue process – as did earlier amendments to the regulation 2023/956 to simplify CBAM and ease compliance. They were first proposed by the EC as part of its Omnibus package in February 2025.
After a deal was reached in June, the adopted texts were published on October 17, 2025. Consequently, key provisions in the implementing regulations may need to get amended too.
EU acts to detail CBAM rules
Overall, 13 acts set the implementation rules for CBAM in the definitive period since January 1, 2026. They consist of delegated regulations (DR) and implementing regulations (IR) across 3 application areas.
1. CBAM authorization and custom rules
From 2026, CBAM goods may only be imported into the EU by authorized CBAM declarants. Importers must have submitted an application for authorization by March 31, 2026 to continue importing CBAM goods.
IR 2025/486 was already published in March 2025 with applications opening March 31, 2025. Rules were amened in IR 2025/2549 to reflect the new timeline and rules for provisional imports.
Authorizations are run via the CBAM Registry, for which the rules have been published in IR 2024/3219 amended and corrected by IR 2025/2550. The Registry serves as central platform for declarants and authorities.
IR 2025/2619 sets out the rules for how customs authorities must communicate information under the CBAM framework to the Commission and competent authorities for compliance checks. This information covers EORI or alternative identifiers, importer details, and relevant customs documents.
IR 2025/2210 defines additional rules for CBAM goods entering the exclusive economic zone of Member States.
2. CBAM emissions and their verification
Already during the transition period, importers had to report actual emissions from the production of CBAM goods – governed by IR 2023/1773. So far, there was no formal mechanism to ensure that reported data meets CBAM methods.
From 2026, only verified emissions data will be accepted — confirmed by accredited CBAM verifiers, who will be responsible for:
- Reviewing emission monitoring and calculation methods
- Conducting on-site inspections of production facilities
- Issuing verification reports to the producers
DR 2025/2551 sets the conditions for accreditation of CBAM verifiers by EU recognized accreditation bodies across EU member states. It ensures harmonized verification standards and consistent application of accreditation rules.
IR 2025/2546 establishes the principles and requirements for verifying declared embedded emissions under CBAM. It details verifier obligations, verification methodologies, and conditions for ensuring accuracy and consistency in emissions reporting.
IR 2025/2547 sets out the methods for calculating embedded emissions in CBAM goods by installation operators as producers. It covers rules for determining actual emissions at installation level ensuring consistency and transparency in emissions reporting.
If no verified data is available, importers must use default values set for the country of origin — plus a cost-increasing mark-up. Both elements are defined in IR 2025/2621. On July 31, 2026, corrections were published in IR 2026/1740.
3. CBAM certificates and their calculation
Importers must purchase and surrender CBAM certificates for the embedded emissions in their goods imported from January 1, 2026 onwards. Annually, they will also need to declare the number of certificates to be surrendered. An upcoming IR will set the rules for this CBAM declaration.
The number of certificates will be adjusted for:
- The level of free allowances granted to EU producers
- Carbon prices already paid in the country of origin
IR 2025/2620 defines the method for calculating the adjustment applied to CBAM certificates to account for free allocation under the EU ETS. This adjustment makes importers to only surrender certificates for emissions above a benchmark, based on EU production standards and adjusted with a CBAM factor.
An upcoming IR (draft from May 2026) will define how to convert carbon prices paid abroad into a number of CBAM certificates — including how to assess actual payments vs. compensation. This act is also expected to define which carbon prices can be credited for in CBAM.
IR 2025/2548 establishes how the price to be paid for CBAM certificates is calculated and published. It is aligned with the average auction price of EU ETS allowances. It is set at quarterly base for imports in 2026 and weekly from 2027 onwards.
An upcoming DR (draft from July 2026) will set the rules for buying, selling, and returning certificates. Only authorized declarants can purchase CBAM certificates, which will be traded through a Central EU Platform. Start date is February 2027.
Far reaching compliance rules for companies
These implementing rules bring new compliance requirements for affected companies that reach into all corporate functions. All in all, importers have little time to get prepared for these rules and fully assess their full business implications.
Preparation is needed across three key areas:
- Clarify organizational CBAM responsibilities and processes: Designate CBAM leads, define roles across departments, and establish customs and compliance processes;
- Build-up CBAM data: Monitor purchasing and import data across all relevant CN codes and secure reliable emissions data from suppliers;
- Prepare for financial management: Factor-in CBAM costs in procurement and sales, align finance teams to manage CBAM certificate purchasing, budgeting, and hedging against carbon price volatility.
Until now, CBAM has mainly been an administrative reporting task. But from now on, it will become a strategic and financial issue. The implementation challenges ahead will require close collaboration between finance, procurement, and customs teams.
Sources and further information:
- European Commission: CBAM Legislation and Guidance
- EU: Regulation establishing CBAM (2023/956)
Photo by Julia Taubitz on Unsplash
