CBAM electricity default values in 2026: current rules

The current Article 7(3) starting point

Current Article 7(3) says embedded emissions in imported electricity are determined by reference to default values using point 4.2 of Annex IV. Actual emissions may be used only where the authorised CBAM declarant demonstrates that the criteria in point 5 of Annex IV are met.

Electricity is also treated differently in the CBAM declaration: quantity is reported in megawatt-hours and embedded emissions in tonnes of CO2e per megawatt-hour. It is excluded from the 50-tonne mass-based exemption, so the threshold checker is not the relevant route for an electricity import.

How the definitive electricity defaults are framed

Commission Implementing Regulation (EU) 2025/2621 sets the legally binding definitive default values. Its electricity methodology uses the average of yearly CO2 emission factors for the most recent five-year period for which reliable data is available, reducing volatility from exceptional years.

The Commission legislation-and-guidance page also provides an Excel workbook for information. The workbook helps users locate published values, but the Commission states that the legally binding values are those in Implementing Regulation (EU) 2025/2621.

Actual electricity emissions are an evidence route

Using actual emissions for imported electricity is not simply a choice to replace the official default with a supplier number. The declarant has to demonstrate the conditions in Annex IV, and Commission Implementing Regulation (EU) 2025/2547 specifies the information and evidence used to assess those conditions.

Keep the producing installation, reporting period, contracted amount, relevant technical and market evidence, emissions report, calculation basis, and any meter or flow information linked. The applicable criteria need to be checked against the official text for the specific import rather than inferred from a general statement about renewable or low-carbon electricity.

Actual emissions must be verified

Where an electricity declaration uses actual emissions, Article 8 requires those emissions to be verified by an accredited verifier. The verification framework tests the emissions report and the evidence supporting the actual-emissions conditions; a power-purchase agreement or supplier statement by itself is not a verification opinion.

For preparation, record what official default row would otherwise apply, what actual-emissions route is being considered, which evidence supports it, and which questions remain for an accredited verifier or national competent authority.

The Commission has proposed methodology changesProposal — not law

COM(2025)989 proposes changes to the method used to calculate the emission factor for imported electricity and to the conditions for applying actual embedded emissions. The proposal says those electricity changes would apply to electricity imported from 1 January 2026 so they can be reflected in the first declarations due in 2027.

COM(2025)989 is in the ordinary legislative procedure and has not been adopted. Until an amending act enters into force, describe the proposal separately and keep current calculations and guidance anchored to the law and implementing acts that are in force.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

A practical source-led sequence

Start with the current Regulation and the official definitive default. If actual emissions are being considered, open the Annex IV criteria and the calculation-method act, assemble the evidence, and arrange accredited verification. Check the proposal only as a possible future change, not as the current rule.

CBAM Pulse can help organise source references and open questions, but it does not decide whether the actual-emissions criteria are met, select a value for an import, or verify an electricity emissions report.