CBAM certificates in 2027: holding, surrender and repurchase

The 2027 certificate sequence

Article 20 of the consolidated CBAM Regulation provides that Member States sell CBAM certificates to authorised CBAM declarants through a common central platform from 1 February 2027. The price is calculated under Article 21 and published by the European Commission.

Certificates bought in 2027 to cover 2026 imports use the quarterly average price for the quarter in which the goods were imported. From 2027, the normal certificate price is calculated and published weekly. A 2027 weekly price should therefore not be substituted for the applicable 2026 quarterly price.

By 30 September 2027, an authorised CBAM declarant submits the first annual CBAM declaration for 2026 imports and surrenders the corresponding number of certificates. The number to surrender follows the declared embedded emissions after the carbon-price and free-allocation adjustments set out in the Regulation; a published certificate price alone is not the final amount for an importer.

Quarter-end holdings are not the annual surrender

Article 22 separates two duties. Paragraph 1 governs the annual surrender by 30 September. Paragraph 2 requires an authorised CBAM declarant, from 2027, to hold enough certificates in its registry account at each quarter end.

The quarter-end balance must correspond to at least 50 % of the embedded emissions in goods imported since the start of the calendar year. That holding calculation uses either official default values without the Annex IV mark-up or, where the Regulation's matching conditions are met, the previous year's surrendered certificates for the same CN codes and countries of origin. The free-allocation adjustment is also taken into account.

These holdings are an in-year account balance. They are not the final annual surrender and should not be presented as a final liability figure.

What changes when the mass threshold is crossed

For an importer that exceeds the single mass-based threshold during the year, Article 22(2a) requires the quarter-end holding obligation to be met by the end of the following quarter. Electricity and hydrogen remain outside that mass-based exemption under Article 2a.

The threshold checker can help organise annual mass information, but it does not determine whether a legal entity qualifies for an exemption or calculate the certificate balance that entity must hold.

Repurchase after surrender

After annual surrender, Article 23 allows an authorised CBAM declarant to request repurchase of excess certificates remaining in its registry account. The request must be submitted by 31 October of the year in which certificates were surrendered, and the repurchase price is the price paid for each certificate at purchase.

The number eligible for repurchase is limited by the Regulation. Where a declarant bought certificates because it expected to exceed the single mass-based threshold but did not exceed it, all those certificates may be repurchased on request. For certificates purchased in 2027 for 2026 embedded emissions, Article 23(2a) provides that they may be repurchased only in 2027. This guide does not decide how those limits apply to a particular account.

Cancellation is a separate final step

Article 24 provides for cancellation without compensation of older certificates that remain in an account. For the first cycle, the Regulation specifically provides that certificates purchased for 2026 embedded emissions are cancelled on 1 November 2027 if they remain in the account after the surrender and repurchase windows.

Cancellation is suspended, to the extent of the disputed amount, while a dispute over the number of certificates to surrender is pending in a Member State. The 1 November rule should therefore not be presented without that statutory exception.

That makes purchasing, holding, surrender, repurchase, and cancellation five different events. Internal planning should record which event a date or quantity belongs to rather than treating them as one certificate deadline.

What remains draft as of 15 July 2026

The legal framework for sale, holding, surrender, repurchase, and cancellation is in the adopted CBAM Regulation. The European Commission also published a draft delegated regulation on 9 July 2026 to specify operational details for sales and repurchases through the common central platform.

The Commission initiative lists feedback closing on 6 August 2026 and adoption planned for Q4 2026. The draft delegated regulation is not an adopted act, so its operational details should not be encoded as settled product logic until the final act is published.

A practical preparation record

A useful internal record separates the official certificate price, the import period, the emissions-data basis, the quarter-end holding assumption, the annual surrender calculation, and any later repurchase request. Keep each assumption source-linked and dated, and route situation-specific decisions to the national competent authority or a qualified adviser.

CBAM Pulse provides source-linked price, deadline, cost-planning, and supplier-data tools. It does not buy, hold, surrender, repurchase, or manage certificates and does not calculate a final legal liability.