CBAM Certificates: 2027 Will Be a Stress Test for Importers

Since 1 January 2026, the era of mere reporting has come to an end: the EU CBAM (Carbon Border Adjustment Mechanism) has entered its definitive phase. For importers of iron, steel, aluminium, cement, fertilisers, hydrogen and electricity, this marks the transition from a purely administrative obligation to a financial liability. Formally, the first settlement will only become visible later: the CBAM declaration for imports made during calendar year 2026, together with the surrender of the corresponding certificates, is due by 30 September 2027. Economically, however, the obligation already arises with imports from 2026 onwards. The timing of CBAM certificate purchases is at the discretion of the authorised CBAM declarant. This creates a new management challenge: companies must not only calculate and report emissions, but also monitor and, in some cases, actively manage certificates, prices, deadlines and holdings of excess certificates.

CBAM Certificate Fundamentals

CBAM certificates are sold exclusively to CBAM declarants by the competent national authorities and cannot be traded between declarants. Sales will be conducted centrally via the Common Central Platform (CCP), which is still under development. The supply of CBAM certificates is unlimited. The price of a CBAM certificate generally corresponds to the average price in the EU Emissions Trading System during the preceding week.

However, special rules apply for 2026: imports made in a given quarter can only be covered by certificates specifically designated for that quarter. The prices of these quarterly certificates are calculated as the weighted average EU ETS price during the same quarter. For the first quarter of 2026, the price is 75.36 euros per certificate and for the second quarter, it is 75.28 euros.

 

Timeline for CBAM Declaration and Certificates

From 1 February 2027, the sale of CBAM certificates to CBAM declarants is expected to begin. By 30 September 2027, certificates covering the imports made during 2026 must be surrendered. Alongside this annual surrender obligation, imports made from 2027 onwards will trigger an additional security requirement: at the end of each quarter, certificates covering 50 per cent of the CBAM emissions embedded in imports made so far during the year must be available in the CBAM account. Any embedded free allocation (SEFA) is taken into account. Although not yet legally adopted, it is planned that this safeguard requirement may only be fulfilled using certificates corresponding to the same vintage year as the imports.

The number of CBAM certificates required to meet the security requirement is calculated either on the basis of default values or using verified actual emissions data that have already been declared. The challenge for 2027 is that, technically, no actual emissions data can yet exist that form part of an earlier CBAM declaration. As a result, only the generally higher default values are initially available, with corresponding implications for liquidity management. In the ongoing legislative process concerning the extension of CBAM, potential easing measures for the 2027 security requirement are being discussed. According to positions in the Council of the European Union, this could include the temporary use of actual emissions data that have not yet been verified. However, this proposal has not yet been adopted into law.

The Lifecycle of CBAM Certificates

As a result, two distinct certificate regimes will effectively coexist in 2027. First, there are certificates for imports made during 2026. These may only be used for the 2026 CBAM declaration. If they are not surrendered, importers can request by 31 October 2027 that the national authority repurchases them at the original purchase price. If no request is submitted, the certificates will expire without compensation on 1 November 2027.

Second, there are the regular CBAM certificates for imports from 2027 onwards. These are needed to satisfy the quarterly security requirements and future surrender obligations. The lifespan of these regular certificates is also limited. Depending on the purchase date, they remain valid for between one year and ten months and two years and ten months. From 2029 onwards, surplus certificates purchased during the year before last will be cancelled annually on 1 November. Surplus certificates can still be preserved through repurchase by the national authority before expiry. The deadline for submitting such repurchase requests remains 31 October.

Conclusions

For importing companies, this means that certificate management becomes a standalone compliance and financial management task. Organisations that focus solely on the annual surrender obligation risk underestimating the operational challenges involved. Going forward, key considerations will include the timing of purchases, purchase prices, certificate vintages, security requirements, repurchase options and certificate expiry dates. Mistakes may result in unnecessary capital lock up, loss of certificate value or regulatory compliance gaps.

Companies should therefore establish early how they intend to meet these complex regulatory requirements reliably while maintaining cost control. In Part 2 of this article, we outline how rule-based procurement strategies for CBAM certificates can help address the challenges described here, and others, in a systematic manner.