CBAM Accounting for the 2026 Year-End Close

Goods imported in 2026 create a CBAM obligation that is paid in 2027. At 31 December 2026 the imports have happened and no certificate can be bought yet, so the year-end accounts carry an estimate: the certificates owed for each quarter's imports, times that quarter's official price. Which standard you book it under, and where the debit goes, is your judgment. No IFRS standard covers CBAM.

This guide is for controllers and finance teams at EU importers closing the 2026 books. It sets out what the CBAM rules settle, what they leave to you, and a worked accrual you can redo for your own import list in the bulk calculator. It is informational, not accounting advice: take the judgments to your auditor.

Settled by the rules, and left to you

The calculator on this site only does the left-hand column. It turns your import list into certificates and euros. The right-hand column is the part no tool should decide for you.

The facts that drive the number

• What is owed. An authorised CBAM declarant surrenders certificates matching the embedded emissions declared for the goods it imported in the previous calendar year (Article 22 of Regulation (EU) 2023/956). For 2026 imports, the declaration and the surrender are due by 30 September 2027.
• When you can pay. Certificates are sold on the common central platform (Article 20), and sales for 2026 imports start on 1 February 2027. Nothing can be bought in 2026.
• At what price. In 2026 the Commission publishes one price per quarter, and each applies to the goods imported in that quarter. From 2027 the price is weekly.
• How many certificates. Embedded emissions per tonne, from the default values (which carry a mark-up) or from verified actual data, less the free allocation EU producers still receive. In 2026 that deduction is 97.5% of the product benchmark. A carbon price actually paid in the country of origin can be deducted too (Article 9).
• Who is in. Since Regulation (EU) 2025/2083, an importer bringing in 50 tonnes or less of CBAM goods in a calendar year is exempt, hydrogen and electricity aside. Above it, every tonne counts.

The 2026 prices so far

The full series, and when the next one lands, is on the certificate price page.

When the obligation arises

The import. The CBAM Regulation attaches the surrender obligation to goods brought in during the year, so once the goods are released for free circulation, an importer over the threshold owes certificates for them whatever it does next. Under IAS 37 that is a present obligation from a past event (paragraphs 10 and 14). Some will read CBAM as a levy instead; IFRIC 21 then asks for the activity that triggers payment under the legislation (paragraph 8), which is the same import, recognised progressively as goods come in (paragraph 11). Both routes land on the same timing: by 31 December 2026, the whole 2026 obligation is on the balance sheet.

Two wrinkles. IFRIC 21 lets an entity leave emissions trading schemes out of its scope (paragraph 6), and CBAM is designed to mirror the EU ETS without being one, so which framing you adopt is itself a judgment to document. And the 50-tonne exemption is annual: an importer near it cannot be sure at the half year that any obligation will arise. At 31 December that question has an answer.

Measuring it

The measure is the certificates owed for each quarter's imports times that quarter's price. IAS 37 asks for the best estimate of what it will take to settle (paragraph 36), and ESMA's October 2024 statement on carbon allowances reads that, for allowance obligations, as usually the current market price of what has to be delivered. For 2026 CBAM the price is not a market guess: it is fixed per quarter by the Commission.

• Q1 to Q3 are known. The Q4 price is published on 4 Jan 2027. It is the average of auctions held before year end, which is the kind of after-the-date evidence IAS 10 treats as adjusting (paragraphs 3 and 9). If your accounts close before it lands, estimate at the latest price and say so.
• Use the emissions you will declare. Default values, mark-up included, unless you expect to file verified actual emissions and the verification will really be there.
• Re-measure for the July correction. Implementing Regulation (EU) 2026/1740 replaced the default values from 1 January 2026. A half-year figure booked on the old values needs updating, which reads as a change in estimate under IAS 8 rather than an error.
• Discounting rarely matters. Settlement falls within nine months of year end, so the effect of the time value of money (IAS 37 paragraph 45) is usually immaterial.

Whether you call the result an accrued liability or a provision is a presentation question. IAS 37 separates them by how uncertain the amount and timing are (paragraph 11). A quarter priced at the official figure on default values is close to certain. A quarter resting on an unpublished price, or on actual emissions still to be verified, is less so.

Where the debit goes

IFRIC 21 does not answer this; it leaves it to the other standards (paragraph 3). The live question is IAS 2. Its cost of purchase includes import duties and other taxes the entity cannot recover (paragraph 11), and a charge that exists only because goods were imported can be read as close enough to capitalise. The CBAM cost then sits in inventory until the goods are sold, and stock still on hand at 31 December carries its share.

The other reading is that CBAM is a carbon charge on the importer, not a cost of the goods, and is expensed as incurred. Either is defensible while no standard speaks to CBAM. What IAS 8 asks for is a policy that gives relevant, reliable information, applied consistently (paragraphs 10 to 13). If you capitalise and cannot pass the cost on to customers, test the stock for net realisable value. CBAM is not an income tax: it is charged on emissions, not profits, so IAS 12 does not apply.

A worked accrual

An importer brings in 1,000 tonnes of hot-rolled flat steel from China (CN 7208) in each quarter of 2026. The 2026 default value is 3.5057 tCO2e per tonne (the 3.187 country figure with the 2026 mark-up), the benchmark is 1.370, and after deducting 97.5% of the benchmark for free allocation each tonne needs 2.170 certificates.

Quarters marked estimate use the latest published price, €82.32, until their own is out.

The entries, in outline. Both are illustrative, not a recommendation:

• Capitalised into stock: as goods are imported, debit inventory and credit the CBAM liability. As the goods are sold, the cost moves to cost of sales with them.
• Expensed: as goods are imported, debit a CBAM expense in cost of sales and credit the CBAM liability.
• In 2027, either way: buying certificates swaps cash for certificates held; surrendering them by 30 September settles the liability. Any gap between the accrual and the final declared figure goes through the same line it was booked to.

Your own number comes from your own list. Paste it into the bulk calculator with an import date or quarter column, and it returns this table for your lines, each quarter at its own price, with a CSV of every line for the audit file.

Certificates you buy in 2027

No IFRS standard covers them either. ESMA's statement found two approaches in practice for compliance allowances held to settle an emissions obligation: inventory under IAS 2 and intangible assets under IAS 38, typically at cost, derecognised when surrendered against the liability. The same choice will come up for CBAM certificates bought from February 2027.

It comes up fast. From 2027 a declarant must hold, at each quarter end, certificates covering at least 50% of the embedded emissions of its imports so far that year. So the 2027 cash plan carries the whole 2026 bill, paid between February and September, plus half of the running 2027 one, from the end of March.

Outside IFRS

Local frameworks ask the same questions in their own words. Under the German Commercial Code, an obligation that is certain in principle but not yet in amount is a provision for uncertain liabilities (section 249 HGB). EY Germany's indirect tax team put it plainly in April 2026: certificates for 2026 imports are bought from February 2027, but provisions are needed now.

What to disclose

• The accounting policy: which standard you applied, and whether CBAM is capitalised or expensed (IAS 1 paragraph 117).
• The judgments behind it, since no standard settles them (IAS 1 paragraph 122).
• The estimation uncertainty: the Q4 price if it was not out, actual emissions still to be verified, and how far default values sit above your suppliers' real figures (IAS 1 paragraph 125).
• If you present a provision, its movement in the year (IAS 37 paragraphs 84 and 85).

Sources: Regulation (EU) 2023/956 Articles 9 and 20 to 22, as amended by Regulation (EU) 2025/2083; Commission Implementing Regulation (EU) 2026/1740; the Commission's CBAM certificate price page; IAS 1, 2, 8, 10, 12 and 37 and IFRIC 21; ESMA public statement ESMA32-483087481-68, 8 October 2024; EY Tax & Law Magazine, 28 April 2026. Checked 16 October 2026. Informational, not accounting, tax or legal advice.