HMRC Issues Guidance for Overseas Installations Monitoring UK CBAM Emissions

16 oktober 2026

HMRC has released operational guidance instructing overseas installation operators on how to monitor and verify emissions data so that UK importers can use actual values rather than default rates.

HM Revenue & Customs (HMRC) has published targeted guidance for overseas installation operators that produce CBAM-covered goods destined for the UK market.

The guidance clarifies the critical role overseas producers play in the UK CBAM compliance chain. If a UK importer (the liable person) wishes to report actual emissions rather than relying on HMRC's newly published sector default values, the overseas installation must actively monitor and verify those emissions.

HMRC outlines three main operational steps for overseas producers:

  • Monitoring: Emissions data must be tracked over a full calendar year (1 January to 31 December) in strict accordance with the methodologies laid out in the newly released CBAM technical guidance.

  • Verification: The installation must appoint an independent, accredited verifier to review the accuracy of the monitored data and generate a formal verification report. This report may include a specific verification summary for each CBAM good produced at the facility.

  • Handoff to Importer: Once verified, the overseas operator is responsible for giving the UK importer either the full verification report or the good-specific verification summary.

The UK importer is then legally required to retain this verification documentation as evidence when reporting actual emissions values on their official CBAM tax return.