What is due, when, and for whom: CBAM dates from October 2026 to November 2027

By Ahmed Medhat · Published26 September 2026

These are the CBAM dates from October 2026 to November 2027 that an act we can quote sets. Here they are in order, each with the act and the party the provision addresses. Four bind the authorised CBAM declarant: the importer, or the indirect customs representative, that holds the status. Five bind the Commission. One binds the Member States, and one binds importers of CBAM goods into the United Kingdom, under a different law.

October 2026: the Q3 2026 price

The Commission calculates the price of CBAM certificates for each 2026 quarter "during the first calendar week of the following quarter" (IR (EU) 2025/2548, Article 1(2)). It publishes it on its website on the first working day of the calendar week after that (Article 4(1)). So the price for goods imported between July and September 2026 is calculated in the first calendar week of October 2026. From the third quarter of 2026 the Commission also makes the 2026 quarterly prices available to authorised declarants in the CBAM registry (Article 4(2)).

Binds: the Commission.

1 January 2027: four things change at once

• The price becomes weekly. From 1 January 2027 the Commission calculates the price every calendar week, as the average of auction clearing prices (IR (EU) 2025/2548, Article 5(1)). Binds: the Commission.
• The default value mark-up rises to 20 % for goods in the cement, iron and steel, aluminium and hydrogen sectors. Fertilisers stay at 1 % (IR (EU) 2026/1740, Annex I, opening paragraph). Binds: declarants who declare 2027 imports on default values.
• The CBAM factor falls to 95 % (Directive 2003/87/EC, Article 10a(1a)). The Directive sets EU free allocation; it reaches declarants through the adjustment under Article 31 of Regulation (EU) 2023/956 and IR (EU) 2025/2620, Annex, point 4, Equation 6, so the free allocation deducted from 2027 imports is smaller.
• UK CBAM starts. Part 5 of the UK Finance Act 2026 "has effect in relation to goods imported into the United Kingdom on or after 1 January 2027" (section 158(1)), and "the person liable to CBAM on the emissions embodied in a CBAM good is the importer" (section 146(1)). Binds: the importer of a CBAM good into the United Kingdom (section 146(1)), unless an exception in section 147 applies. It is a separate law from the EU regulation.

Early January 2027: the Q4 2026 price

The last quarterly price, for goods imported between October and December 2026, is calculated in the first calendar week of January 2027 (IR (EU) 2025/2548, Article 1(2)).

Binds: the Commission.

1 February 2027: certificates go on sale

"From 1 February 2027, a Member State shall sell CBAM certificates on a common central platform to authorised CBAM declarants established in that Member State" (Regulation (EU) 2023/956, Article 20(1)). Certificates for 2026 imports are bought from that date too (Articles 21(1a) and 23(2a)).

Binds: Member States (Article 20(1)). The declarant's duty to hold and surrender certificates comes from Article 22(1) and (2).

31 March 2027, and every quarter after: the holding

From 2027, at the end of each quarter, an authorised declarant must hold certificates corresponding to at least 50 % of the embedded emissions in all goods it has imported since the beginning of the calendar year (Article 22(2)). Those emissions are measured either on default values without the mark-up, or on the number of certificates surrendered for the preceding year for the same goods by CN code and country of origin. The Article 31 adjustment for free allocation is taken into account. The first quarter end is 31 March 2027. A declarant that crosses the 50-tonne threshold during the year complies by the end of the quarter after the one in which it crossed it (Article 22(2a)).

Binds: authorised declarants.

30 April 2027: the threshold review

"By 30 April of each calendar year, the Commission shall assess, on the basis of the import data for the preceding 12 calendar months, whether the single mass-based threshold ensures that paragraph 1 of this Article applies to no more than 1 % of the emissions embedded in the imported goods and processed products" (Regulation (EU) 2023/956, Article 2a(3)).

Binds: the Commission.

30 September 2027: the first declaration and the first surrender

By 30 September of each year, "and for the first time in 2027 for the year 2026", the authorised declarant submits its CBAM declaration for the preceding year (Article 6(1)) and surrenders the certificates for it (Article 22(1)). Where the declaration uses actual emissions, they must be verified by an accredited verifier (Article 8(1)).

Binds: authorised declarants.

For operators of installations outside the EU, we looked in IR (EU) 2025/2547 and IR (EU) 2025/2546 for a date by which the operator's emissions report must reach the verifier or the declarant, and found none. The only date the acts set in this chain is the declarant's 30 September 2027 (Articles 6(1) and 22(1)); it does not bind the operator.

31 October 2027: the repurchase deadline

A declarant with excess certificates submits its repurchase request "by 31 October of each year during which CBAM certificates were surrendered" (Article 23(1)). Certificates bought in 2027 for 2026 emissions may only be repurchased in 2027 (Article 23(2a)).

Binds: authorised declarants.

1 November 2027: cancellation

"On 1 November 2027, the Commission shall cancel any CBAM certificates purchased in respect of the embedded emissions for the year 2026", without compensation (Article 24(2)).

Binds: the Commission.