CBAM Defaults
updates/3 Sep 2026
verificationregulation

The chain that lets you use actual emissions for 2026 only opened this week

On 24 August 2026 the Commission published its guidance on CBAM verification and accreditation, together with the procedure for how verifiers get into the CBAM Registry. One sentence in it sets the clock for every importer who intends to rely on actual emissions:

“CBAM verifiers must register in the CBAM Registry within two months of receiving their CBAM accreditation, but not before 1 September 2026.” And the next line says when those registrations start producing anything an importer can use: “Starting from January 2027, they will issue verification reports in the CBAM Registry, thus allowing importers to use actual verified emissions to complete their CBAM declaration.”

The verification runs after the imports, not alongside them

The guidance is aimed at verifiers of goods “imported from 1 January 2026”. Those goods have been crossing the border for eight months. The people who verify them could not apply for Registry access until two days ago.

  • From 1 January 2026 — the imports the verification will cover. Already happening.
  • 14 August 2026 — the Commission publishes ten guidance documents for the non-EU operators who calculate the emissions.
  • 1 September 2026 — the earliest a verifier may apply for CBAM Registry access.
  • January 2027 — the earliest a verification report can be issued in the Registry.
  • 1 February 2027 — certificate sales open for 2026 imports.
  • 30 September 2027 — the 2026 declaration is due.

There is time in that sequence. What there is not is control. The Commission's own procedure sets out the order: accreditation by a National Accreditation Body comes first, then an application for Registry access, then a National Competent Authority grants it after checking the accreditation is real. Put your supplier at the front of that queue, since somebody has to produce the emissions report before anyone can verify it, and four organisations stand between your consignment and a verified number. You are none of them.

Ten documents, and six of them are addressed to your supplier's sector

On 14 August 2026 the Commission published ten guidance documents aimed, in its words, at “operators of installations outside the EU that produce CBAM goods, as well as authorised CBAM declarants and verifiers”. Four are general: an introduction to CBAM concepts, a quick guide for non-EU operators, the calculation of embedded emissions, and the calculation of the free allocation adjustment. The other six are sector guides with worked examples, one each for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity.

Those are the same six sectors CBAM covers, so whatever you import, there is one written for it. If you have been asking a supplier for emissions data and getting silence or a spreadsheet you cannot use, this is the thing to send them. It is the Commission's own manual for the number you are asking for, and it is free.

Until that lands, the default value is the number you can price

Nothing here removes actual emissions as an option, and the Commission clearly intends importers to get there. But an importer pricing a 2026 contract today cannot wait for a report that cannot exist before January. The default value can be looked up today and turned into a euro figure today, and if the verified number arrives later and comes in lower, you will have been conservative rather than wrong.

The current values are on every country and product page, the calculator turns one into a cost at the official certificate price, and the full export file gives you every value in one spreadsheet if you are pricing a list rather than a single code. If your goods are heading to Great Britain as well, the UK CBAM page tracks the separate timetable there, which has its own record-keeping duty running from 1 January 2027.

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