The 2026 CBAM Definitive Phase: The final Tick list

Monday, 3 March 2026

Welcome to Dubrink updates. For importers, suppliers, and representatives, staying ahead of the CBAM curve is no longer optional, it’s essential.

We invite you take a read of this 'recap'- covering exactly what is required of who as the registry cutoff on the 31 March 2026 looms over us.

Securing Authorised CBAM Declarant Status and the AMM

As the transition from the "learning phase" to the CBAM definitive phase hit on January 1, 2026, the European Commission finalized Implementing Regulation (EU) 2025/2550, updating the functional requirements of the CBAM Registry.

A critical operational requirement is the mandatory Authorised CBAM Declarant status application. Under the new rules:

• Delegation of Authority: Authorised declarants may now delegate the submission of CBAM declarations to third parties via the Authorisation Management Module (AMM). However, the legal liability for compliance and the accuracy of the CBAM account number remains with the declarant.

• The 50-Tonne Mass-Based Threshold: A single annual threshold of 50 tonnes has been established. Importers falling below this limit are exempt from surrendering certificates, though they must still declare the exemption to the National Competent Authority during customs entry to prevent artificial splitting of imports.

• Registry Infrastructure: The registry now prioritizes automated XML upload structures over manual entry. This shift is designed to streamline high-volume reporting but requires precise data mapping to avoid a registry validation error.

If you are an active Importer of goods with CBAM relevant CN codes and are not registered by the cutoff, you face import blocks until your registration is complete. Dubrink can assist you in this matter!

Modeling Financial Risk: CBAM Certificate Price Forecasting

Implementing Regulation (EU) 2025/2548 provides the methodology for calculating the cost of CBAM certificates, ensuring they closely reflect the EU Emissions Trading System (EU ETS) price.

For the Financial Department, understanding the pricing transition is vital for financial modeling:

• 2026 Methodology: During the first year of the definitive phase, the certificate price will be based on the quarterly average of auction clearing prices.

• 2027 Transition: Starting January 1, 2027, the calculation shifts to a weekly average carbon price, increasing sensitivity to market fluctuations.

• Transparency: The Commission will publish these prices on the first working day of the week following the calculation period. This price data is the baseline for calculating potential carbon price deductions for taxes paid in third countries.

The Dubrink weekly blog will also include the current developments of the ETS price (which is directly linked to the predicted CBAM cost) on a weekly basis.

*Please be advised that although we monitor relevant events and try to maintain a generally good Idea of the movements of the market- we cannot and will not guarantee certainty in this regard, wit the market based on numerous pillars which are all highly prone to unexpected shifts, it is not possible to accurately predict every development.

The High Cost of Punitive Default Values vs. Actual Emissions Data

The definitive phase introduces a "Data Compliance Wall" regarding the calculation of embedded emissions. Implementing Regulation (EU) 2025/2621 clarifies that when verified actual emissions data is missing, importers must use punitive default values.

• Conservative Mark-ups: Default values are designed to be environmentally conservative. For most sectors, a mark-up is added to reflect the emissions of the 10% most carbon-intensive installations. These mark-ups follow a phase-in schedule: 10% in 2026, 20% in 2027, and 30% from 2028 onwards.

• Sectoral Variation: While steel and aluminum face the standard mark-up schedule, the fertilizer sector has a significantly lower mark-up of 1%.

• Verification Advantage: Providing verified actual emissions data allows importers to avoid these punitive defaults. However, this requires a third-party audit by an accredited verifier, with a primary data verification threshold that must be met to ensure compliance. Although this is not yet available- it is recommended to reach out to ETS accredited verifiers as these are the most likely parties to be cleared to audit soon after the verification becomes possible on the 1 September 2026.

One Mechanism, Many Gateways: National Administrative Nuances

While CBAM is a harmonized Union law, its practical administration is managed through diverse national "gateways," leading to varying experiences for declarants across Member States.

• Physical Paperwork: Despite the digital nature of the Definitive Registry, several Member States still require physical, hard-copy documentation for the initial Authorised CBAM Declarant application.

• Integrated Portals (Austria): The Austrian system is integrated into the existing EU ETS access module, requiring importers to navigate ETS-specific helpdesks.

• Privatized Access (Netherlands): The Netherlands utilizes eHerkenning, a privatized digital identity framework where access to government portals must be purchased from commercial providers.

• Customs Reconciliation (Romania): Romanian authorities emphasize a strict reconciliation between CBAM declarations and customs records, ensuring data aligns with the bill of discharge.

• Role-Based Governance (Belgium): Belgium’s role-based authorization system can grant permissions beyond CBAM, necessitating careful internal oversight by representative firms.

As the 2028 downstream expansion approaches, understanding these national administrative layers will be essential for managing market access and maintaining a competitive edge in the global trade community.

If you happen to Find yourself reading this and coming to the conclusion that you are Ill-prepared in a mentioned topic; Don't hesitate to reach out to us at Dubrink. We are here to help you, and now is not the time for guesswork.

Wishing everyone a smooth ride to compliance and a good weekend.

Dubrink Updates k.conrad@dubrink.com