CBAM Regulatory Framework for the Definitive Period Starting in 2026

October 20, 2025

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(UABIO) Starting from January 1, 2026, the European Union’s Carbon Border Adjustment Mechanism (CBAM)is moving from a Transitional to a Definitive period. This means that importers of certain goods will not only have to report their greenhouse gas emissions, as has been the case since October 2023, but will also have to buy and surrender certificates for those emissions.

Thus, the greenhouse gas emissions embedded in goods imported into the EU will become a real operational cost.

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Non-EU producers and exporters whose products fall under the CBAM have just a few months left to prepare for the definitive period, which will commence in 2026. There are currently many uncertainties, as amendments to the CBAM regulation are still being finalised, and several legislative acts are in the pipeline.

To calculate the costs of CBAM, which are necessary for business planning and signing long-term contracts, four key elements are particularly important for businesses:

Benchmarks: These will determine how many CBAM certificates importers must submit. Until these are published, the real values of imports in 2026 will remain unknown.
Verification rules: Companies need to know how emissions data will be verified and which verifiers will be recognised.
Default values: Some importers will have to use default values if data from the supplier is not available. The size of the “mark-up” to these values is not yet known, which makes it difficult to assess financial risks.
Certificate purchase rules: A clear certificate purchase schedule is important for cash flow planning and avoiding disruptions.

Companies are working hard to prepare, but the lack of clear guidance leaves them vulnerable. Goods ordered today will arrive in 2026 and will be subject to CBAM, but companies still lack an understanding of how much tax they will have to pay.

Consider the overview of 10 delegated and implementing acts prepared by CO2iq Solutions GmbH, which define how CBAM will operate from 2026. To date, only two of these acts have been adopted, while the rest are at various stages of development, and some are even delayed compared to the original schedules. These documents detail the rules in three main areas, which are critical for the operational readiness of the finance, procurement and customs departments of importing companies.

CBAM Regulatory Framework for the Definitive Period Starting in 2026

According to data provided by CO2iq Solutions GmbH.

From August 28 to September 25, the European Commission announced the call for applications for the methodological framework for the definitive period of the CBAM, which includes:

determination of the direct embedded emissions based on actual emissions;
determination of embedded emissions for electricity;
determination of indirect embedded emissions;
default values for non-electricity goods that will be used if the embedded emissions are not based on actual data.

Currently, a transition period is in effect until the end of 2025, during which the implementing regulation CBAM 2023/1773, which regulates quarterly reporting by importers, is in effect.

To simplify CBAM and facilitate its compliance, in February 2025, the European Commission proposed several amendments to the main CBAM Regulation (EU) 2023/956 in the Omnibus package, which were described in detail in our publications:

Simplification of CBAM for importers and operators of installations outside the EU: part one

Simplification of CBAM for importers and operators of installations outside the EU: part two

On September 10, the European Parliament officially voted in favour of the agreed simplifications of the Omnibus package. After formal approval by the Council of the European Union, these changes will be reflected in the relevant EU regulatory documents.

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With the transition to a definitive period in 2026, CBAM will transform from an administrative requirement into an important strategic and financial factor for all companies importing products into the EU. Ignoring these changes can lead to serious consequences: from significant financial losses and delays in delivery to loss of market positions. READ MORE