CBAM Annual Declaration

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Updated October 4, 2026

• The grain of the declaration is installation by origin by type of goods Article 6(2) asks for annual totals of quantity, embedded emissions and certificates to surrender, but Article 6(6) has the standard format carry detail for each installation, country of origin and type of goods behind those totals, so the platform stores the detail and derives the totals rather than entering them.
• The de minimis threshold is one counter per importer per calendar year The single mass-based threshold applies to the total net mass of goods under all CN codes aggregated per importer and per calendar year with electricity and hydrogen excluded, and crossing it within the year brings every good imported in that year into every obligation, so the platform projects the crossing rather than reporting it afterwards.
• Verification attaches to the actual-emissions route only Where embedded emissions are determined on actual emissions the declarant must have them verified by a verifier accredited under Article 18 to reasonable assurance, with a report whose content Annex VI fixes. Default values carry a mark-up and need no report, so the method flag on each record decides whether a verification report is linked.
• The certificate ledger runs on purchase year, not on balance Sale, surrender, repurchase and cancellation are each a rule with a named party and a start event. The repurchase cap is the holding obligation of the purchase year and cancellation takes certificates bought during the year before the previous calendar year, so the ledger needs a vintage view alongside the quarter-end balance check.
• Retention and the review window are the same four-year clock Annex V records, the verifier's report, the calculation method and the carbon-price evidence are kept until the end of the fourth year after the year in which the declaration was or should have been submitted, and the Commission's power to review the declaration runs to the same point, so versioned methods and inputs are part of the record.

Copy takeaways

A CBAM annual declaration is the yearly filing an authorized CBAM declarant submits through the CBAM registry for the goods it imported in the preceding calendar year. Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, fixes what the filing contains, which records sit behind it, who verifies the emission figures and what the certificate account must hold before surrender. For the engineer building the declarant's platform, that text reads as a data model: which fields come from customs, which from the producer's installation, which from a verifier and which checks run before submission.

In short: the declaration totals quantity per type of goods, embedded emissions and the certificates to surrender, with per-installation, per-origin and per-goods detail behind each total. Emissions come from actual values on primary data, verified by an accredited verifier, or from Commission default values, which need no report. The certificate count is the emissions figure after the carbon-price reduction and the free-allocation adjustment. Every rule below binds a named party from a named event, and every date the mechanism fixes appears in the snapshot table only.

Where the mechanism stands, as published

Every date the mechanism fixes lives in this table, checked on the read date in the sources line against the consolidated text of Regulation (EU) 2023/956 on EUR-Lex and the Commission's CBAM pages.

Fact	What the text says	Source
Definitive-period articles apply	"Article 2(2) and Articles 2a, 4, 6 to 9, 10a, 15, 19 and 21, Article 22(1) and 22(3) and Articles 23 to 27 and 31 shall apply from 1 January 2026;" (consolidated text)	Article 36(2)(b), Regulation (EU) 2023/956 as amended
Authorization, third-country registration, registry and account articles apply	"It shall apply from 1 October 2023. However: (a) Articles 5, 10, 14, 16 and 17 shall apply from 31 December 2024;" (consolidated text)	Article 36(2), opening words and point (a)
First declaration, with the surrender under Article 22(1) due on the same day	"By 30 September of each year, and for the first time in 2027 for the year 2026, each authorised CBAM declarant shall use the CBAM registry referred to in Article 14 to submit a CBAM declaration for the preceding calendar year." (consolidated text)	Article 6(1), with Article 22(1)
Quarterly holding rule and platform sales	"(c) Article 22(2) shall apply from 1 January 2027; (d) Article 20(1), (3), (4) and (5) shall apply from 1 February 2027." (consolidated text)	Article 36(2)(c) and (d)
Repurchase request window, with the 2027 purchases for the 2026 emissions repurchasable only in 2027	"The authorised CBAM declarant shall submit the repurchase request by 31 October of each year during which CBAM certificates were surrendered." (consolidated text)	Article 23(1) and (2a)
Cancellation day, with 1 November 2027 named for the 2026 emissions	"On 1 November of each year, the Commission shall cancel any CBAM certificates that were purchased during the year before the previous calendar year and that remained in the account of an authorised CBAM declarant in the CBAM registry." (consolidated text)	Article 24(1) and (2)
De minimis threshold, per importer per calendar year over all CN codes, electricity and hydrogen excluded	"The single mass-based threshold referred to in Article 2a shall be set at 50 tonnes of net mass." (consolidated text)	Annex VII point 1, with Article 2a(1) and (4)
Threshold review	By 30 April each year the Commission assesses the threshold on the preceding 12 months of import data and may amend it by delegated act, with effect from 1 January of the following calendar year (consolidated text)	Article 2a(3)
Amending act of 8 October 2025, published on 17 October 2025, in force on 20 October 2025, the third day after publication and the date of the consolidated text	"REGULATION (EU) 2025/2083 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 October 2025 amending Regulation (EU) 2023/956 as regards simplifying and strengthening the carbon border adjustment mechanism" (amending act)	Regulation (EU) 2025/2083, title and final article
Registry documentation	Declarants Portal user manual version 6.00, Release 3.2, dated 16/06/2026 and posted 21 August 2026, and a verifiers and operators portal manual posted 27 August 2026 (CBAM Registry page)	European Commission, DG TAXUD
Definitive-period acts listed	Registry 2024/3210 and 2025/2550, declarant status 2025/486 and 2025/2549, verification principles 2025/2546, calculation methods 2025/2547, customs information 2025/2619, free-allocation adjustment 2025/2620, default values 2025/2621 corrected by 2026/1740, continental shelf 2025/2210, and Delegated Regulation (EU) 2025/2551 on accreditation and verification, and no adopted act on the carbon price paid in third countries is listed (legislation and guidance page)	European Commission, DG TAXUD

Who files and what the registry holds

The filer is the authorized CBAM declarant, a status granted by the competent authority of the Member State of establishment. An importer established in a Member State applies before importing, an indirect customs representative obtains the status itself before importing the goods it declares, and an exempt importer applies when it expects to exceed the de minimis threshold. Under Article 5 the application goes through the registry with the applicant's identity, EORI number and estimated import quantities, and later changes that may affect the authorization decision are notified through the registry without delay. Article 14 makes the registry a standardized electronic database of declarant accounts, shared automatically and in real time with customs and competent authorities.

Submission may be delegated. Article 5(7a) lets the declarant delegate the submission of declarations to a person acting on its behalf and in its name, and Article 14(6) leaves the credentials for that delegation to implementing acts, but "The authorised CBAM declarant shall remain responsible for compliance with the obligations applicable to it under this Regulation." For a platform run by a customs agent, that sentence puts approval steps and audit logs with the declarant, whoever presses submit.

Goods in scope and the de minimis rule

Scope is a CN-code test on the customs line. Under Article 2(1), "This Regulation applies to goods listed in Annex I originating in a third country, where those goods, or processed products from those goods resulting from the inward processing procedure referred to in Article 256 of Regulation (EU) No 952/2013, are imported into the customs territory of the Union." A line for processed products from the inward processing procedure is therefore tested on the Annex I goods that went in, not on its procedure code. Origin follows the non-preferential rules of Article 59 of the Union Customs Code, so the platform stores the origin on the customs declaration, never a supplier's claim. The customs records underneath are the ones our logistics software development guide describes.

The de minimis exemption in Article 2a is a running total per importer, not a per-shipment test. An importer is exempt while the net mass of its imported goods in a calendar year does not cumulatively exceed the single mass-based threshold, and "That threshold shall apply to the total net mass of goods under all CN codes aggregated per importer and per calendar year." Once the threshold is exceeded within the year, "the importer or the authorised CBAM declarant shall be subject to all obligations under this Regulation in respect of all emissions embedded in all goods imported in that calendar year." Electricity and hydrogen are outside the exemption. While below the threshold, the importer declares the exemption in the customs declaration itself. The threshold's figure is in the snapshot, because the Commission reviews it every year.

The platform therefore keeps one counter per importer per calendar year and projects the crossing, because an exempt importer must apply when it expects to cross and the quarterly certificate obligation starts at the end of the following quarter.

What the declaration contains, as a data model

Article 6(2) lists four items. The chapeau and the first read: "The CBAM declaration shall contain the following information: (a) the total quantity of each type of goods imported during the preceding calendar year, expressed in megawatt-hours for electricity and in tonnes for other goods, including the imported goods below the single mass-based threshold;" Point (b) is the total embedded emissions, calculated under Article 7 and, where actual emissions are used, verified under Article 8. Point (c) is the number of certificates to surrender, the emissions in point (b) after the reduction for the carbon price paid in a third country under Article 9 and the free-allocation adjustment under Article 31. Point (d) is copies of verification reports, where applicable.

The totals are not the data model. Article 6(6) has the Commission adopt "the standard format of the CBAM declaration, including detailed information for each installation and country of origin or other third country and type of goods to be reported, which supports the totals referred to in paragraph 2 of this Article", so the grain of a CBAM annual declaration platform is installation by origin by type of goods, with the annual totals derived rather than entered. The first two columns of the table are sourced, and the last two are editorial, because no provision prescribes where a platform takes each field from or which check it runs.

Declaration element	Article	Data source (editorial)	Validation (editorial)
Declarant identity: name, address, contact, EORI number, CBAM account number	Art 14(2)(a) to (c), Art 16(1), Art 17(4), Annex V	Registry account data as registered in the authorization decision	Matches the decision, with changes to the Art 5(5) data notified through the registry
Goods in scope, by CN code and type of goods	Art 2(1) and Annex I, Art 7(1) for Annex II goods	Customs declaration lines: CN code, net mass, procedure	CN code in Annex I, Annex II flag limiting the calculation to direct emissions
Total quantity per type of goods, in tonnes or in megawatt-hours for electricity	Art 6(2)(a)	Customs lines aggregated per calendar year	Goods below the threshold included, total equal to the sum of its lines
Country of origin per consignment	Art 2(5), Annex V	Origin under the non-preferential rules of the Union Customs Code	Present on every line and taken from the customs declaration
Installation and operator, actual-emissions route	Annex V, Art 14(3), Art 3 point 31	Operator data from the registry's third-country section or from the operator	Installation resolvable in the registry section, operator record including a controlling parent company where relevant
Embedded emissions per type of goods, direct and indirect	Art 3 definitions, Art 7(1) to (4), Annex IV	Actual emissions on primary data, or default values	Method flag on every record, electricity on default values unless the Annex IV point 5 criteria are shown
Verification report copies, where applicable	Art 6(2)(d), Art 8(1), Annex VI point 2	Report issued by a verifier accredited under Art 18	Installations, operator, reporting period, verifier and accreditation number, visit date or waiver reason, one report per actual-emissions record
Certificates to surrender: emissions after the carbon-price reduction and the free-allocation adjustment	Art 6(2)(c), Art 9, Art 31, Art 22(1)	Carbon-price evidence held by the declarant, and the Article 31 adjustment inputs with their published version recorded	The carbon-price reduction and the free-allocation adjustment applied before the count, which must be available on the account before surrender
Quarter-end holding	Art 22(2) and (2a)	Account balance against year-to-date embedded emissions	At least 50 % of year-to-date embedded emissions on the account at each quarter end
Certificate ledger: sale, surrender, repurchase, cancellation	Art 14(2)(d), Art 20(3) and (5), Art 23, Art 24	Platform sales and repurchases transferred to the registry at the end of each working day	Unique identification number with price and date of sale on every certificate, repurchase within the obligation of the purchase year
De minimis position of the importer	Art 2a(1), (2) and (4), Annex VII point 1	Cumulative net mass per importer per calendar year, all CN codes	Exemption flag while below, every good of the year in scope once crossed
Records and retention	Art 7(5) and (6), Annex V	Every field above plus the verifier's report and the calculation method	Retained to the end of the fourth year after the declaration year
Submission and delegation	Art 6(1), Art 5(7a), Art 14(6)	Declarant's registry account, or a delegate with the credentials the Article 14(6) implementing acts provide for	Filed through the registry for the preceding calendar year

Embedded emissions: actual values and defaults

Embedded emissions are the direct emissions released in producing the goods plus the indirect emissions from the electricity consumed in the process, calculated under Annex IV. For Annex II goods only direct emissions are calculated, under Article 7(1), so the Annex II flag on a goods record switches the indirect component off. Under Article 7(2), "Embedded emissions in goods other than electricity shall be determined: (a) based on the actual emissions in accordance with the methods set out in points 2 and 3 of Annex IV; or (b) by reference to default values in accordance with the methods set out in point 4.1 of Annex IV." Imported electricity is on default values unless the declarant demonstrates the Annex IV point 5 criteria.

Actual emissions are calculated on primary data from the production processes and the electricity consumed in them, an installation-level dataset the producer owns. Default values are drawn from secondary data, and Annex IV point 4.1 says how: "Default values shall be set at the average emission intensity of each exporting country and for each of the goods listed in Annex I other than electricity, increased by a proportionately designed mark-up." The mark-up is fixed in the implementing acts under Article 7(7).

The Commission's legislation and guidance page lists the implementing regulation on default values with a correcting act and states that its spreadsheet is for information while the legally binding values are those in the act, so a platform records the act version behind each value it loads. Whichever route a record takes, actual values depend on the producer's primary data and trigger verification, while default values need no report. The trade-off is the mark-up on the default route against the verifier, the installation visit and the additional Annex V records on the actual route.

Verification reports and the accredited verifier

Verification attaches to the actual-emissions route only. Under Article 8(1), where the embedded emissions are determined on the basis of actual emissions, "the authorised CBAM declarant shall ensure that the total embedded emissions declared in the CBAM declaration submitted pursuant to Article 6 are verified by a verifier accredited pursuant to Article 18, based on the verification principles set out in Annex VI." For goods from an installation registered under Article 10, verified information disclosed to the declarant under Article 10(7) may be used instead.

Annex VI fixes the standard and the report's content. On the standard, "the total embedded emissions to be declared in the CBAM declaration shall be considered as verified only if the verifier finds with reasonable assurance that the verification report is free of material misstatements and of material non-conformities", and installation visits are mandatory unless a waiver criterion is met. Since the amendment the report also identifies the installations where a precursor input material was produced and the actual emissions from producing it, so a record for goods made from precursors links to those installations too. Article 8(3) leaves the supporting documentation and the report format to implementing acts, and the Commission lists Commission Implementing Regulation (EU) 2025/2546 on the application of verification principles.

For the platform the report is a linked record with structured fields, and two failure modes belong to its design rather than to anything the text prescribes. An actual-route record with no verification report at the deadline is held out of the submission set and flagged, and a verifier's finding of a material misstatement reopens the record and every total derived from it.

Certificates, stated as rules

Certificate accounting is a ledger with four movements and one balance check, each a rule binding a named party from a named event. Sale: a Member State sells certificates on a common central platform to declarants established in it, the Commission assigns each certificate a unique identification number on creation and registers it with the price and date of sale in the buyer's account, and platform sales and repurchases reach the registry at the end of each working day. Surrender: by the annual deadline the declarant surrenders through the registry the number of certificates corresponding to the emissions declared under Article 6(2)(c) and verified under Article 8, and it must have that number on its account beforehand. A late surrender is penalized. Holding: at the end of each quarter the account holds certificates for at least 50 % of the embedded emissions in all goods imported since the beginning of the calendar year, computed on default values without the mark-up or on the number surrendered for the previous year, the second only for the same goods by CN code and origin. A newly exposed importer complies from the end of the quarter following the crossing. Repurchase: on request, the Member State of establishment repurchases the excess certificates left after surrender, executed by the Commission through the platform and capped at the holding obligation of the purchase year, with full repurchase for a declarant that expected to cross the threshold and did not. Cancellation: certificates bought during the year before the previous calendar year and still on the account are canceled by the Commission without compensation.

The ledger therefore needs a vintage view keyed on purchase year, because the repurchase cap and the cancellation both run on the purchase year rather than on the balance, next to the quarter-end balance check.

Registry modules and submission

The Commission's registry page describes an electronic platform on which importers perform their obligations and report on them. The same page has every user set up two-factor authentication on an EU Login account to access the registry. Applications for the declarant status go through the AMM. Monitoring runs in the DRMC: "The data reconciliation for monitoring and control (DRMC) component monitors the CBAM declarant’s account and gives declarants a view of all data on imported goods, emissions, certificates and penalties. It also enables declarants to monitor and anticipate requirements for the 50% rule." Its filters, sector, goods code, country of origin, quantity and estimated emissions, are the dimensions a platform's own reconciliation report should match.

Operator data arrives through the O3CI module, the registry page's module for non-EU installation operators, which "allows installation operators outside the EU to upload and share their installations and emissions data with reporting declarants in a streamlined manner, instead of submitting it to each declarant separately." Declarants retrieve it by searching the third-country installations registry, and "For this to work, CBAM declarants need to share their EORI number with the supplier outside the CBAM Registry." That handshake happens off the registry, so the platform's supplier onboarding flow owns it.

Submission is the declarant's account, or a delegate's. The Declarants Portal user manual documents screens and document attachment, and neither it nor the registry page, as read on the date in the sources line, describes an API, a machine-to-machine interface, a bulk upload, a sandbox, a conformance environment or a test environment, so the platform produces the declaration as structured data it can render into the portal's fields and attachments.

Records the platform must keep

Record keeping is specified twice, for the emission figures and for the carbon price. Under Article 7(5) the declarant keeps the information required to calculate the embedded emissions per Annex V. Retention is a rule with a start event: "The authorised CBAM declarant shall keep those records of information referred to in paragraph 5, including the report of the verifier, until the end of the fourth year after the year in which the CBAM declaration has been or should have been submitted." Carbon-price evidence under Article 9 runs on the same period, and the Commission's power to review a declaration under a risk-based strategy runs to the end of the same fourth year.

Annex V names the minimum: for every imported good, type and quantity, country of origin and actual emissions or default values, and where actual emissions are used, the installation, its operator's contact information, the verification reports, the specific embedded emissions of the goods and, since the amendment, "(e) information and the method used to calculate the embedded emissions." That last item turns the calculation into a record, so the platform versions its methods and inputs.

Testing the platform against the registry

Neither the registry page nor the Declarants Portal user manual names a conformance, sandbox or test environment, so what follows is the platform's own design, not a Commission facility. The harness is built from the Article 6(2) items, the Annex V record set and the Annex VI report fields, and replays a full calendar year of the declarant's customs lines.

Worth automating are the assertions the text makes checkable. Every Annex I CN code on a customs line lands in exactly one type of goods and the annual total equals the sum of its lines. Every actual-emissions record resolves to one verification report whose period covers it, and every default value carries its act version. The de minimis counter crosses on the right line and the quarterly projection turns on at the end of the following quarter.

How Pharos Production helps

A CBAM annual declaration is assembled from customs data the importer already files, producer data it does not control and certificate sales and repurchases the registry receives at the end of each working day, and the engineering is in the joins.

Pharos Production builds that data model, its reconciliation views and the test harness above within its supply chain software development service, and its logistics software development service covers the consignment and customs records the declaration runs on.

Sources: Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, consolidated text on EUR-Lex, Regulation (EU) 2025/2083 amending it, on EUR-Lex, and the European Commission's CBAM pages on legislation and guidance and on the CBAM Registry. Read on 16 September 2026. Engineering guidance, not legal advice.

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• What does a CBAM annual declaration contain?

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  Article 6(2) of Regulation (EU) 2023/956 lists four items: the total quantity of each type of goods imported in the preceding year, the total embedded emissions, the certificates to surrender once the carbon-price reduction and the free-allocation adjustment are applied and, where applicable, copies of verification reports. Behind those totals the standard format under Article 6(6) carries detail for each installation, country of origin and type of goods, which is the grain a platform stores.

• When is the CBAM annual declaration due?

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  The text fixes a calendar deadline in the year following the import year: the declarant submits the declaration through the CBAM registry for the preceding calendar year and surrenders the corresponding certificates by the same deadline, with a penalty for a late surrender. The first declaration year and the exact day are stated in the snapshot table on this page, which is the only place this guide carries the mechanism's dates, because the deadline was moved by the amending regulation and the snapshot is the part re-checked against the consolidated text.

• Which goods count towards the de minimis threshold?

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  The threshold in Article 2a applies to the total net mass of goods under all CN codes aggregated per importer and per calendar year, with electricity and hydrogen outside the exemption altogether, so it is one running counter rather than a per-shipment or per-product test. Once it is exceeded within the year, every obligation applies to all goods imported in that calendar year, including those imported before the crossing.

• Do default values need a verification report?

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  No. Article 8(1) requires verification by a verifier accredited under Article 18 only where the embedded emissions are determined on the basis of actual emissions, and Article 6(2)(d) asks for copies of verification reports where applicable. Default values for goods other than electricity are set as the average emission intensity of the exporting country per good plus a mark-up, and the legally binding values are those in the implementing act rather than in the informational spreadsheet.

  The trade-off is that the default route carries the mark-up while the actual route carries the verifier, the installation visit and the additional Annex V records for actual emissions.

• What must the certificate account hold at the end of each quarter?

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  Certificates for at least 50 % of the embedded emissions in all goods imported since the start of the calendar year, computed on one of the two bases the certificates section states, with a newly exposed importer complying from the end of the quarter after the crossing. The year from which the rule applies is in the snapshot table.

• How long must CBAM records be kept?

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  Until the end of the fourth year after the year in which the declaration was or should have been submitted, covering the Annex V records, the verifier's report, the calculation method and the carbon-price evidence under Article 9. The Commission's power to review a declaration under a risk-based strategy ends with the same fourth year, so retention and review are one clock started by one event.

• Does the CBAM registry offer an API or a test environment?

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  Neither the registry page nor the Declarants Portal user manual describes one: the page documents access through an EU Login account with two-factor authentication, the manual documents screens and document attachment, and neither names an API, a machine-to-machine interface, a bulk upload, a sandbox, a conformance environment or a test environment. A declarant's platform therefore produces the declaration as structured data it can render into the portal and tests itself against the published data structures with a replay of a full year of customs lines.

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