From CBAM reporting to the definitive period: emissions data in 2026

The transitional period ended in 2025

From October 2023 to the end of 2025, the transitional period required reports on embedded emissions without buying or surrendering CBAM certificates. That reporting-only period did not make a transitional supplier figure automatically suitable for a definitive-period declaration.

The definitive period changed the consequence of the data

From 1 January 2026, importing covered goods is tied to authorised CBAM declarant status. Authorised declarants report embedded emissions in an annual CBAM declaration and surrender certificates against the resulting obligation under Regulation (EU) 2023/956, as amended.

Certificate sales open on 1 February 2027. The first annual declaration, covering 2026 imports, and the corresponding surrender are due by 30 September 2027 under Regulation (EU) 2025/2083.

Separate the emissions route before comparing values

For goods other than electricity, current Article 7(2) permits actual emissions under points 2 and 3 of Annex IV or official default values under point 4.1. The correct basis is a source and evidence question, not whichever number produces the lower comparison.

Imported electricity follows a different starting point. Current Article 7(3) uses default values under point 4.2 of Annex IV unless the authorised CBAM declarant demonstrates that the criteria in point 5 of Annex IV for actual emissions are met.

Actual electricity emissions require evidence and verification

Commission Implementing Regulation (EU) 2025/2547 specifies information and evidence for assessing the electricity actual-emissions conditions. A supplier statement or power-purchase agreement alone is not a decision that point 5 of Annex IV is met.

Where a declaration uses actual emissions, Article 8 requires the declared actual emissions to be verified by an accredited verifier. Keep the installation, reporting period, contracted amount, technical and market evidence, emissions report, calculation basis, and verification report linked without treating an evidence checklist as a verification opinion.

The regulation is binding; the workbook is a navigation aid

Commission Implementing Regulation (EU) 2025/2621 sets the legally binding definitive default values. The European Commission legislation-and-guidance page states that its downloadable Excel workbook is made available for information purposes only.

The CBAM Pulse default-value comparison reads checksum-pinned country worksheets for goods other than electricity. It does not calculate electricity default values, select which value applies, test the Annex IV criteria, or turn supplier-reported information into verified actual emissions.

COM(2025)989 remains an ongoing proposalProposal — not law

COM(2025)989 proposes changes to the electricity emission-factor method and the conditions for using actual embedded emissions. EUR-Lex lists procedure 2025/0419(COD) as an ongoing ordinary legislative procedure; the proposal has not been adopted.

Proposed methodology must stay out of current calculations and current-law instructions unless a final act enters into force and its text and application dates are reviewed.

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.

Use a source-led preparation sequence

Identify the goods type and current emissions route, preserve the exact official source and period, attach supplier data to its installation and calculation context, and arrange accredited verification where actual emissions are used. Route unresolved criteria or applicability questions to the national competent authority or a qualified adviser.

CBAM Pulse can organise source references and comparisons. It does not decide which emissions basis applies, verify actual emissions, prepare a CBAM declaration, or determine the final certificate obligation.