CBAM Certificate Purchase Date and Declaration Deadline: The 2026-2027 Timetable

There is no CBAM certificate to buy in 2026. Under the amended Regulation (EU) 2023/956, Member States begin selling certificates on 1 February 2027. Authorised declarants must submit their first annual declaration and surrender the matching certificates for goods imported in 2026 by 30 September 2027. The price of each 2026 certificate follows the average EU ETS auction price of the quarter in which the goods were imported. For a UK supplier, the quarter in which you deliver now affects your customer's CBAM bill in 2027.

Why the money moved to 2027

The deadlines were set by the Omnibus simplification, Regulation (EU) 2025/2083, published on 17 October 2025. Article 20(1) now reads: "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." Articles 6(1) and 22(1) fix the declaration and surrender date at 30 September, "for the first time in 2027 for the year 2026". Recital 27 says the 2027 price for 2026 emissions "should reflect the prices of EU ETS allowances in 2026".

This is a definitive-period rule. During the transitional period (1 October 2023 to 31 December 2025), nothing was bought. Importers filed quarterly reports within one month of each quarter's end, and the last one, for October to December 2025, was due by 31 January 2026.

The timetable, quarter by quarter

2026: import, record, prepare

• 1 January: the definitive period begins. Only authorised declarants may import CBAM goods, unless the importer stays within the 50-tonne annual threshold (Arts 4 and 2a).
• 31 March: the cut-off for applying for authorisation while continuing to import provisionally (Art. 17(7a)).
• April, July, October 2026 and January 2027: in the first calendar week of each quarter, the Commission calculates the previous quarter's price, then publishes it on the first working day of the following week (IR 2025/2548, Arts 1(2) and 4(1)).
• From Q3 2026: quarterly prices are also shown in declarants' CBAM registry accounts (IR 2025/2548, Art. 4(2)).
• From 1 September: accredited verifiers can apply for registration in the CBAM registry (Art. 10a(1)).

2027: buy, declare, surrender

• 1 January: weekly pricing begins, and the quarter-end holding obligation starts to apply (IR 2025/2548, Art. 5; Art. 22(2)).
• 1 February: certificate sales open on the common central platform (Art. 20(1)).
• 15 February: the surrender deadline for declarants whose authorisation was revoked during 2026 (IR 2025/2549).
• 30 September: the first annual declaration and surrender, covering 2026 (Arts 6(1) and 22(1)).
• 31 October: the last day to ask for excess certificates to be repurchased (Art. 23(1)).
• 1 November: certificates bought for 2026 emissions and still unused are cancelled without compensation (Art. 24(2)).

Pricing: quarterly for 2026, weekly afterwards

Prices are calculated in euros and rounded to the nearest cent. If a week has no auctions, the previous auction week's price applies (Art. 21(1)). The knowledge base contains the method but not the auction results, so it cannot give a euro figure for any quarter. The Commission's website is the only publisher of the official price (IR 2025/2548, recital 9).

A worked illustration using only these rules. An EU customer receives 300 tonnes of UK steel in February 2026 and 300 tonnes in August 2026. The embedded emissions of the first delivery are priced at the Q1 2026 average, and those of the second at the Q3 2026 average. Both sets of certificates are bought after 1 February 2027 and surrendered by 30 September 2027.

What the declaration must contain

Filed in the CBAM registry, the declaration covers (Art. 6(2)):

1. quantities of each type of goods imported in the previous year, including those below the single mass-based threshold;
2. total embedded emissions, verified by an accredited verifier where actual emissions are used;
3. the number of certificates due, after the deduction for any carbon price paid abroad and the free-allocation adjustment;
4. verification reports, where applicable.

Preparing and submitting the declaration may be delegated, but the declarant remains responsible (Art. 5(7a)). Records must be kept until the end of the fourth year after the year in which the declaration was or should have been submitted (Art. 7(6)).

Missing the 30 September deadline

If a declaration is not filed, the Commission assesses the declarant's obligations on the information available. By 31 December of the following year, it sends the competent authority a preliminary calculation of the certificates that should have been surrendered. The authority then sets the definitive number and orders the additional certificates to be surrendered within one month (Art. 19(4) and (5)). For each certificate not surrendered by 30 September, a penalty equal to the EU ETS excess emissions penalty applies, and paying it does not cancel the duty to surrender (Art. 26(1) and (3)). The amount of the ETS penalty comes from Directive 2003/87/EC, which is not part of the knowledge base.

What UK suppliers can do now

The timetable gives UK producers a clear window to help their EU customers:

• Date every delivery. The quarter of importation sets the 2026 price, so customers will want customs dates matched to your invoices.
• Get 2026 emissions verified in 2027. Verification of a calendar year cannot be completed before January of the following year. The Commission's verification guidance suggests declarants will want reports by mid-August at the latest, ahead of 30 September.
• Explain the production year. Goods are presumed produced in the year of import unless the actual production period is shown, and never before 2026 (IR 2025/2620, recital 12).
• Share data once. Registering your installation in the CBAM Registry, which is voluntary, lets every declarant use the same verified data set (Commission Guidance No. 2).

Three cash-flow rules finance teams should know

For date-specific questions, such as "Can I get a refund for certificates bought in 2027 that I did not need for 2026?", the EU CBAM knowledge base answers with the relevant article quoted.

Information current to the consolidated regulation of 20 October 2025 and the implementing acts of December 2025. This is not legal advice. The knowledge base covers EU law only and says nothing about any UK equivalent.