Authorised CBAM declarant status: what it is and how to prepare

What is authorised CBAM declarant status?

Authorised CBAM declarant status is the authorisation tied to importing CBAM goods during the definitive period and performing the declaration and certificate-account duties in the CBAM Regulation.

In defined cases involving indirect customs representation, the indirect customs representative can hold the authorisation and obligations rather than the importer. The actor depends on the import arrangement and the Regulation's conditions; this guide does not decide that allocation for a specific chain.

The authorised declarant is the certificate-account actor

From 1 February 2027, Member States sell CBAM certificates through the common central platform to authorised CBAM declarants established in their territory. The purchased certificates are recorded in the authorised declarant's CBAM registry account.

A public price page or planning calculator does not purchase certificates or create a registry balance. Those are account actions performed within the official system by the authorised actor.

Holding and annual surrender are different duties

From 2027, the authorised CBAM declarant must ensure that its registry account at each quarter end holds certificates corresponding to at least 50 % of cumulative embedded emissions since the calendar-year start, calculated on the Article 22 bases and free-allocation adjustment.

If the declarant exceeds the single mass-based threshold during the year, its first compliance with that holding requirement is due by the end of the following quarter under Article 22(2a).

By 30 September each year — first in 2027 for 2026 imports — the authorised CBAM declarant must submit the annual CBAM declaration and surrender the corresponding certificates. The quarter-end holding balance is not the final annual surrender.

Repurchase and cancellation come later

After surrender, the authorised CBAM declarant may request repurchase of eligible excess certificates by 31 October. Article 23 normally caps eligibility at the number the declarant was obliged to purchase under Article 22(2) in the calendar year of purchase, with a separate full-repurchase rule where certificates were bought in expectation of exceeding the mass threshold but the threshold was not ultimately exceeded. Repurchase is not automatic and uses the price paid for each eligible certificate.

Article 24 then governs cancellation of remaining older certificates. For the first cycle, certificates bought for 2026 emissions are cancelled on 1 November 2027 unless cancellation is suspended to the disputed extent while a surrender-number dispute is pending.

The national competent authority remains the process owner

Each Member State designates a national competent authority for authorisation and oversight. The authoritative application process, evidence requests, decisions, and company-specific contact point are those of the relevant national competent authority.

Use this guide to map the role and lifecycle questions, then route situation-specific authorisation and account questions to that authority or a qualified adviser.

Draft platform details are not settled account instructions

The Commission's 9 July 2026 draft delegated regulation proposes detailed sale and repurchase operations for the common central platform. The initiative currently labels it ‘In preparation’; its feedback period closed on 6 August 2026, and the page does not show a final adopted act.

The draft delegated regulation is not an adopted act. Its proposed request, payment, processing, and fee details should not be treated as final instructions for an authorised declarant.

How to prepare with CBAM Pulse

CBAM Pulse does not apply for authorised status, buy certificates, hold certificates, surrender certificates, request repurchase, or manage certificates. It provides source-linked guides, dates, published prices, and editable planning estimates outside the official Registry and platform.

• Confirm which imported goods may be CBAM goods with the goods checker.
• Separate price publication, sales, quarter-end holdings, annual surrender, repurchase, and cancellation in the internal calendar.
• Use the readiness checklist to assign owners for authorisation, imports, supplier data, and adviser or authority follow-up.