European Commission Releases Factsheet on CBAM Certificate Lifecycle and Compliance Cycle

The European Commission has published an official factsheet outlining the end-to-end operational lifecycle of CBAM certificates within the CBAM Registry. The document provides definitive clarity on how EU importers must manage certificate purchases, quarterly holdings, annual surrenders, and buy-backs.

As a baseline rule, 1 CBAM certificate equals 1 tonne of CO₂ equivalent embedded in imported goods. To determine the final net volume of certificates required, declarants must deduct any applicable free allocation adjustments and carbon prices paid in the country of origin.

The Commission outlines a structured four-stage cycle for managing certificates:

• Sales Launch & 2026 Transition: CBAM certificates will officially go on sale in the CBAM Registry on 1 February 2027. There is no quarterly holding obligation for calendar year 2026. Declarants reporting 2026 embedded emissions must purchase all required certificates between 1 February 2027 and 30 September 2027.

• Quarterly Purchase Obligation (2027 Onwards): Starting in 2027, importers must purchase certificates at the end of each quarter to meet their ongoing holding obligation. By the end of each quarter, declarants must hold certificates corresponding to at least 50% of embedded emissions in all CBAM goods imported since the beginning of that calendar year.

• Annual Surrender (By 30 September): Following the submission of the annual CBAM declaration, importers must surrender the required number of certificates by 30 September of the following year.

• Repurchase & Cancellation Mechanics:

  • Repurchase (By 31 October): If an importer holds excess certificates following annual surrender, they can request a buy-back from the Commission until 31 October. The buy-back is capped at the number of certificates purchased to satisfy quarterly obligations. Excess 2026 certificates can only be repurchased in 2027.

  • Cancellation (1 November): On 1 November, two years after purchase, any remaining un-repurchased excess certificates expire and are cancelled by the Commission without financial compensation. For 2026 excess certificates, cancellation occurs on 1 November 2027.

"Pricing for CBAM certificates will be available quarterly for 2026 emissions and on a weekly basis from 2027 onwards via the official CBAM Certificate Price page and within the CBAM Registry."