CBAM reporting in 2026: requirements, records and workflow

What CBAM reporting means in 2026

The transitional reporting period ended in 2025. During the definitive period, authorised CBAM declarants account for covered imports through an annual CBAM declaration and the associated certificate process under Regulation (EU) 2023/956, as amended.

Reporting is therefore more than copying an emissions number into a form. The working record has to keep goods scope, import quantities, supplier and installation context, emissions basis, evidence, assumptions, and deadlines connected so a reviewer can understand where each figure came from and which issues remain open.

Who reports, what period is covered, and when it is due

The regulated filing route sits with the authorised CBAM declarant. Regulation (EU) 2025/2083 sets 30 September 2027 as the deadline for the first annual CBAM declaration covering goods imported during 2026, together with the corresponding certificate surrender timetable.

Importers, customs teams, suppliers, advisers, finance teams, and verifiers can all contribute records, but their roles are not interchangeable. Keep the responsible legal entity, importer or declarant context, import year, record owner, and review date visible from the start.

Build the goods register before the emissions register

Start with a goods register for the 2026 import file. Record the customs or internal shipment reference, CN code, commercial description, origin, supplier, net mass, import date or period, and the reviewed current-scope status for each line.

Do not begin by collecting generic corporate carbon figures. A reporting record needs to connect emissions information to the goods that were actually imported. Use the CBAM goods checker as a source-linked preparation check, while keeping customs classification and final applicability decisions in the appropriate official or qualified-review process.

• Keep legal entities separate so annual mass and threshold context are not blended across importers.
• Label current Annex I scope separately from proposal-stage downstream products.
• Preserve the exact CN code used in the customs record rather than relying only on a product name.

Connect supplier data to the installation and production process

For each relevant goods row, record the supplier, production installation, production route or process, reporting period, direct and indirect embedded-emissions values where provided, data basis, and contact for follow-up. Supplier-level averages without installation and period context are harder to review and reuse.

A useful supplier workflow separates requested, received, needs clarification, reviewed internally, sent for qualified review, and unresolved states. The supplier data request template helps draft the questions; the evidence checklist helps keep replies, source records, and open gaps visible.

Separate actual emissions, official defaults and missing data

Regulation (EU) 2023/956 distinguishes actual emissions from official default values. Commission Implementing Regulation (EU) 2025/2547 sets detailed calculation and reporting information for actual-emissions routes, while the applicable official defaults come from the adopted source framework.

Label each figure by basis, unit, period, source, and version. A supplier-reported value, an official default, a mixed calculation, and a value that is still unavailable are different record states. Do not collapse them into one unlabelled emissions column or choose a basis only because it produces a lower planning estimate.

Keep evidence and accredited verification status distinct

Supporting records can include calculation notes, monitoring information, emissions reports, source data, supplier correspondence, and references to official defaults. Record what each item appears to support, who provided it, the period covered, and which goods or installation row it belongs to.

Where a declaration uses actual emissions, Article 8 requires the declared actual emissions to be verified by an accredited verifier. Commission Implementing Regulation (EU) 2025/2546 governs that verification process. A supplier file, consultant review, or completed checklist is not by itself an accredited verification opinion.

Document assumptions, versions and unresolved questions

A reviewable CBAM reporting set keeps assumptions separate from sourced facts. Record the source URL, source date, effective period, value or interpretation used, owner, and reason for any planning assumption. When an official value, supplier response, or rule changes, preserve the superseded version instead of silently overwriting the history.

Use a gap log tied to the relevant goods or supplier row. Concrete gaps include missing CN confirmation, missing net mass, supplier data not received, installation unknown, actual/default basis unclear, precursor information missing, evidence reference absent, or a question requiring adviser or National Competent Authority review.

Use a monthly reporting workflow instead of an annual rescue

A lightweight monthly workflow reduces the 2027 reconstruction problem. Add new import lines, review scope, update cumulative mass, trigger supplier requests, attach evidence references, and assign every open gap to an owner and next date. Review price and rule changes separately so proposal-stage material does not overwrite current assumptions.

For a small, stable set of imports, a controlled spreadsheet may remain workable if every row keeps its source, owner, status, and version visible. Quarterly, reconcile supplier follow-ups, evidence versions, current official sources, and high-impact unresolved rows. Before the annual declaration work begins, reconcile final 2026 imports, data-basis coverage, verification status, and the questions that still require qualified review.

What CBAM Pulse can and cannot do

CBAM Pulse can help check reviewed goods scope, organise threshold and cost planning inputs, request supplier data, track official prices and dates, and structure evidence gaps. The tools show their sources and assumptions so the preparation record is reproducible.

CBAM Pulse does not assign customs classifications, decide whether a declaration is correct, verify actual emissions, act as an accredited verifier, file through the CBAM Registry, or replace the authorised declarant, National Competent Authority, or qualified adviser.