How to Apply for Authorised CBAM Declarant Status: A Step-by-Step Guide
To become an authorised CBAM declarant, you apply through the CBAM registry to the competent authority of the EU Member State where you are established. The authority has 120 calendar days to assess the application. That period can be extended, but not beyond 180 days when it asks for more information. Since the October 2025 Omnibus amendment, consulting other Member States is optional, and any consultation is capped at 15 calendar days. A newly established applicant must also post a guarantee.
Do you need the status, and who should hold it?
Article 4 of Regulation (EU) 2023/956 is short: "Goods shall be imported into the customs territory of the Union only by an authorised CBAM declarant." It has applied since 1 January 2026. The 50-tonne de minimis exemption in Article 2a is the main way out. For a US group, the question is usually which entity holds the status:
- An EU subsidiary that imports in its own name applies itself. Article 5(1) requires any importer established in a Member State to apply before importing.
- A US parent with no EU establishment cannot. Article 17(2)(c) requires the applicant to be established in the Member State where it applies, and Implementing Regulation 2025/486 (Art. 4(4)) says the application must be refused otherwise. Under Article 5(2), the indirect customs representative must obtain the status instead.
- An indirect customs representative acting for an EU importer must hold the status before importing, whether or not that importer is exempt (Art. 5(1a)).
- Electricity importers using explicit capacity allocation are treated as authorized without applying (Art. 5(4)).
In the regulation, "established" means having your registered office, central headquarters or a permanent business establishment in a Member State (Art. 3(19)). Once granted, the status is "recognised in all Member States" (Art. 17(1)). The CBAM knowledge base contains these definitions alongside the implementing acts.
Step 1: Gather the information Article 5(5) requires
The application form in the CBAM registry follows Article 5(5). Prepare:
- Name, address and contact details.
- Your EORI number (a separate criterion under Art. 17(2)(d)).
- Your main economic activity in the EU.
- A tax authority certificate showing no outstanding recovery order for national tax debts.
- A declaration of honor that you were not involved in serious or repeated infringements of customs, tax or market-abuse rules in the previous five years, and have no record of serious criminal offenses related to your business.
- Evidence of financial and operational capacity. If the authority decides so based on risk, this can mean profit-and-loss accounts and balance sheets for up to the last three closed financial years.
- Estimated imports by type of goods and Member State of import, for the current and the following calendar year.
- Your AEO certificate number, if you hold authorized economic operator status (added by the Omnibus).
- Names and contacts of the persons you act for, if you are a representative.
Your import estimate drives the guarantee
The estimate in point (g) is used to size the guarantee and to judge your financial capacity (Implementing Regulation 2025/486, Art. 10(3)). Build it from real purchase plans. If it changes after submission, Article 2 of that regulation requires you to ask for an adjustment, with justification for points (d) to (ga).
Step 2: Check the criteria the authority will apply
Article 17(2) lists four criteria. Implementing Regulation 2025/486 explains how they are checked:
Authorization criteria and how they are assessed
| Criterion (Art. 17(2)) | How it is assessed (IR 2025/486) |
|---|---|
| No serious or repeated infringements | No decision finding serious or repeated infringements in the 3 years before the application; no serious criminal offenses in the 5 years before (Art. 9). Covers the applicant, its CBAM managers and those controlling it. |
| Financial and operational capacity | Not in bankruptcy; no material arrears on import duties and taxes; sufficient financial standing; an administrative organization and internal controls able to manage declarations and certificates (Art. 10). |
| Established in the Member State of application | Otherwise the application is refused (Art. 4(4)). |
| EORI number | Assigned under Article 9 of the Union Customs Code. |
The authority may rely on expert conclusions, third-party conclusions or audits you provide (IR 2025/486, Art. 4(2)). Since Implementing Regulation 2025/2549, it may also retrieve information digitally from other national authorities, if you consent or national law allows.
Step 3: Plan for the guarantee
Under Article 17(5), the authority must require a guarantee if the applicant "was not established throughout the two financial years preceding the year" of application. A newly formed EU import vehicle for a US group falls in this category.
- Amount: the value of the CBAM certificates you would have to surrender for the imports you estimated, after the free-allocation adjustment.
- Form: a bank guarantee payable at first demand from a financial institution operating in the EU, or an equivalent form the authority accepts.
- Timing: if a guarantee is required, the decision granting the status only takes effect when the guarantee is registered (IR 2025/486, Art. 7(2)).
- Top-ups: if imports outgrow the guarantee, the authority can require an adjustment within a deadline of up to 2 months, extendable to 3. Failing to provide it triggers revocation proceedings (IR 2025/486, Art. 16).
- Release: immediately after 30 September of the second year in which you surrendered certificates (Art. 17(7)).
Step 4: Submit and track the timeline
You apply electronically in the CBAM registry, which gives the application a unique reference number (IR 2025/486, Art. 1). These are the deadlines that then apply:
Decision timeline
| Event | Time limit | Source |
|---|---|---|
| Standard assessment | 120 calendar days from receipt | IR 2025/486, Art. 4(1) |
| Applications filed before 15 June 2025 | 180 calendar days | IR 2025/486, Art. 4(5) |
| Authority requests more information | You reply within the deadline set, max 30 days; assessment extended up to 30 days, total capped at 180 days | IR 2025/486, Art. 5 |
| You request a change to your application | Authority may extend by 30 calendar days | IR 2025/486, Art. 2(4) |
| Optional consultation of other authorities | Max 15 calendar days (+ max 15 if a consulted party asks) | Reg. 2023/956, Art. 17(1); IR 2025/2549 |
| Intended refusal | You may submit observations within max 30 calendar days | IR 2025/486, Art. 6 |
What the 2025 Omnibus changed about consultation
Before the Omnibus, Implementing Regulation 2025/486 required the authority to start a consultation of other Member States and the Commission within 45 calendar days. Answers were due within 5 working days if estimated annual imports were 1 tonne or less, or 15 working days above that. Regulation 2025/2083 made consultation optional: the authority "may consult" (Art. 17(1), second subparagraph). Implementing Regulation 2025/2549 then rewrote the procedure. The authority "may initiate" a consultation, which must finish within the 120-day assessment period. The deadline for observations cannot exceed 15 calendar days. If consulted parties do not answer in time, the criteria are deemed met.
After the decision: what comes next
- Effective date: the decision takes effect when it is registered in the CBAM registry and you are notified there (IR 2025/486, Art. 7).
- Account: the Commission opens your CBAM account and assigns a unique account number, which shows the Member State that granted the status (Art. 16; IR 2025/486, Art. 17).
- Delegation: you may delegate filing of CBAM declarations to someone acting in your name, but you stay responsible (Art. 5(7a)).
- Changes: report changes to your application information without delay (Art. 5(7)). The authority reassesses your status periodically (IR 2025/486, Art. 18).
- Refusal: a refusal must give reasons and explain how to appeal (Art. 17(3)).
The 31 March 2026 window
Article 17(7a) let importers and representatives that applied by 31 March 2026 keep importing provisionally until the authority decides. If the application is refused, emissions on goods imported from 1 January 2026 are calculated using default values and penalized under Article 26(2a). Applications filed after that date do not have this protection.
To check a specific situation, such as a US parent selling to EU customers through an EU subsidiary or through a customs broker, you can ask the EU CBAM knowledge base directly. Each answer cites the article of Regulation 2023/956 or the implementing act it relies on.
Prepare your application with the source texts at hand
Regulation 2023/956 as amended, Implementing Regulations 2025/486 and 2025/2549, and the Commission's 2026 guidance, all searchable and cited.
This guide summarizes the rules in force after Regulation 2025/2083 (in force since October 2025) and Implementing Regulation 2025/2549 (December 2025). It is not legal advice. National competent authorities may publish their own practical instructions, and those are not part of this knowledge base.
Frequently asked questions
How long does it take to get authorised CBAM declarant status?
The competent authority must assess the application within 120 calendar days of receipt (Implementing Regulation 2025/486, Art. 4(1)). Where it requests additional information, the assessment may be extended but must not exceed 180 calendar days in total.
Is consultation with other Member States still mandatory?
No. Since Regulation 2025/2083, the competent authority may consult other competent authorities or the Commission, but is not required to. Any consultation may not exceed 15 calendar days (Art. 17(1); Implementing Regulation 2025/2549).
Can a US company without an EU entity become an authorised CBAM declarant?
Not directly. The applicant must be established in the Member State where it applies (Art. 17(2)(c)). Where the importer is not established in a Member State, the indirect customs representative must obtain the status (Art. 5(2)).
When is a guarantee required?
When the applicant was not established throughout the two financial years before the year of application (Art. 17(5)). It equals the value of certificates for the estimated imports, after the free-allocation adjustment.
Can I outsource the annual CBAM declaration?
Yes. Article 5(7a) lets an authorised CBAM declarant delegate submission of declarations to a person acting on its behalf and in its name. The declarant remains responsible for compliance.
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