CBAM 2026: Key simplification updates

10. December 2025
Blog

As we approach the end of the year, the EU Carbon Border Adjustment (CBAM) is undergoing a significant amount of changes ahead of its definitive implementation with an overwhelming amount of updates. It can be hard to keep track of what’s officially been adopted and what’s a leaked rumour. This blog walks you through the officially adopted simplifications and details how they may affect your businesses.

What is CBAM?

CBAM is the EU’s policy tool to prevent “carbon leakage” by applying a tax on carbon-intensive imports and align them with locally produced goods. As complexities piled up, the EU publicised a simplification package in February (the Omnibus I package) to reduce the regulatory burden while keeping the framework’s core climate goals intact. EU simplifications were officially adopted in October, changing several key aspects of CBAM.

What are the official simplifications?

These are the simplifications officially adopted by the EU Commission on the 21^st October 2025.

1. De minimis threshold

A de minimis limit of 50 tonnes now applies to importers bringing in Annex I products (iron and steel, aluminium, fertilisers and cement).

This limit excludes imports of hydrogen or electricity, which remain fully subject to CBAM rules.

Implications:

Smaller consignments of Annex I goods may fall outside annual CBAM reporting, easing compliance for low-volume traders (mainly small and medium businesses)
Importers of electricity and hydrogen must prepare for full CBAM obligations regardless of shipment size.

2. Authorised Declarant status & delegation

Importers anticipating volumes above the de minimis threshold must obtain Authorised CBAM Declarant status.
Import activities may continue through 2026 provided the authorisation request is filed by 31 March 2026.
Responsibilities may be delegated to an external representative (e.g., consultants) that fulfil specific conditions such as holding an EORI number and being established in an EU Member State. The importer, however, retains legal accountability.

Implications:

Businesses approaching or exceeding the threshold must secure authorisation early to avoid customs disruptions.
Delegation can ease administrative pressure, but governance controls are essential since accountability does not shift to the representative.

3. Certificates, submissions & timing

Annual CBAM declarations are due 30 September of the year following the import period.
CBAM certificates become available for purchase in 2027, covering emissions attributed to 2026.
The requirement for certificates has been reduced from 80% of embedded emissions to 50% throughout the year.
In some cases, verified data from the prior year may be applied for comparable goods from the same origin.

Implications:

Compliance planning and cash-flow projections must reflect the later start to certificate purchasing and the reduced certificate coverage.
Companies reliant on supplier data will need timely verification processes to meet the reporting deadline.
Reuse of verified historical data may streamline reporting for stable supply chains.

4. Emissions calculation & scope refinements

For selected aluminium and steel items, emissions accounting focuses largely on precursor inputs, which means that finishing steps outside the ETS may be omitted, except for integrated operations.
Precursor materials already priced under the ETS or linked regimes must not be counted twice.
The Commission will publish default emissions figures, meaning that verification is only needed where actual values are used instead.
Items in Annex II require reporting of direct emissions only.
Non-kaolinic clays are removed from scope.

Implications:

Narrowed emissions boundaries may simplify data gathering for downstream processors.
Avoiding double accounting is essential to ensure certificate quantities are calculated correctly.
Default values provide a fallback for importers lacking granular data, though companies with lower real-world emissions may prefer verified actuals.

5. Carbon price deductions & verifiers

Each year, the Commission will publish the average effective carbon price (€/tCO₂e) paid in non-EU jurisdictions.
Importers may claim reductions in required certificates for carbon costs paid abroad, as long as these relate to emissions not already covered under the ETS or an aligned pricing mechanism.
Verification must be carried out by accredited legal entities consistent with the original CBAM rules and Regulation (EU) 2018/2067, with verifier access to the CBAM registry.

Implications:

The accuracy and availability of verified foreign carbon-price data will directly influence certificate obligations.
Improper deductions could increase compliance exposure, making documentation and verification essential.
Demand for accredited verifiers may create capacity pressures, favouring early engagement.

6. Penalties & compliance risk

Unauthorised imports exceeding the threshold will trigger penalties equal to the full volume of embedded emissions, and payment of those penalties removes the requirement to submit a declaration.
Minor or unintentional errors (e.g., reliance on inaccurate third-party information) may result in reduced penalties.
Minor infringements (such as importing after authorisation is rejected) may also qualify for reduced penalties.

Implications:

Failure to secure Authorised Declarant status on time carries significant financial risk, potentially exceeding certificate costs.
Documented due diligence and supplier-data controls can help demonstrate good-faith errors and mitigate penalties.
Repeated or systemic issues may still attract heightened scrutiny despite reduced penalties for isolated minor infringements.

What this means for your business

If you import small quantities (under ~50 tonnes/year) of covered goods, you may now fall outside the full CBAM scope, meaning substantially reduced reporting and administrative effort.

If you operate above that threshold, or you import hydrogen or electricity, the core CBAM duties still apply, but the streamlined measures (longer lead times, the ability to delegate tasks, reuse of last year’s verified data, reduced certificate coverage, etc.) offer meaningful relief.

In short: many traders will benefit from a lighter compliance load, but CBAM remains significant for higher-volume importers and for sectors where the threshold doesn’t apply.

What to do next

Review your product list: Confirm whether your imports fall under CBAM’s scope (iron and steel, aluminium, fertilisers, cement, hydrogen, electricity).

Assess your quantities: Determine whether you sit below or above the 50-tonne threshold, and whether you may cross it in future years.

Secure emissions data: Ensure access to supplier emissions information, verified values where applicable, and any carbon pricing applied in the country of origin.

Plan for Authorised Declarant status: Decide whether you need it and whether to involve an accredited third-party representative.

Prepare for certificates and reporting: Build internal processes for registry use, certificate management, and meeting the 30 September annual deadline from 2026 onward.