The dates that control the first cycle.
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1 January 2026Declarants and operators
The definitive CBAM regime applies
Authorised CBAM declarant status and certificate obligations begin, with a single mass threshold of 50 tonnes of CBAM goods per importer per year.
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14 August 2026Non-EU installation operators
Ten implementation guidance documents published
Four general guides plus six sector guides covering production processes, value chains and monitoring and reporting considerations.
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24 August 2026Verifiers and accreditation bodies
Verification and accreditation guidance published
Requirements for verification of emissions reports of operators of installations producing CBAM goods outside the EU, plus the Registry access procedure.
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From 1 September 2026Accredited verifiers
CBAM Registry registration opens
A verifier may obtain Registry access from this date, and must register within two months of receiving CBAM accreditation.
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From January 2027Accredited verifiers and declarants
Verification reports issued through the CBAM Registry
Accredited verifiers issue verification reports in the Registry.
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30 September 2027Authorised CBAM declarants
First annual declaration for 2026 imports
The first annual CBAM declaration and the associated certificate surrender fall due.
Working backwards from September 2027.
The declaration deadline is the visible date, but it is not the one that decides your outcome. If actual values are to be used for 2026 imports, the monitoring arrangements had to be in place during 2026 — data cannot be reconstructed afterwards from a calendar that did not exist. The practical question in late 2026 is not “when is the deadline”, it is “does the 2026 data we already hold support an actual value, and can it be traced”.
Describe the claim — not the service.
Tell us what must be relied on, who will rely on it and by what date. We will confirm the correct programme, evidence requirement and responsible entity — or tell you it is outside our scope.