Free CBAM Reporting Checklist (15 Items)

A comprehensive CBAM reporting checklist ensures you never miss a step in your quarterly compliance workflow. This checklist covers everything from company registration to final submission.

"Importers must maintain supporting documentation for at least four years after the submission of the CBAM declaration." — EU Regulation 2023/956, Article 21

How to Use This Checklist

Print this checklist at the beginning of each quarter. Tick off each item as you complete it. Store completed checklists with your quarterly CBAM records for audit evidence.

Why a Structured Checklist Saves More Than Time

Under EU Regulation 2023/956 Article 21, importers must retain supporting documentation for at least four years after submission. A gap in documentation — even a minor one like a missing mill certificate — can trigger enhanced scrutiny during an audit. In our experience working with CBAM declarants, the importers who follow a structured checklist from day one are the ones who pass audits with no findings. Those who rely on ad-hoc processes are disproportionately represented in penalty cases. The checklist below is built from our team's direct experience reviewing hundreds of CBAM submissions during the transitional phase.

Pre-Quarter Preparation

Task	Status
Verify EORI number is current and valid	☐
Check CBAM Registry access credentials	☐
Review CN codes for annual updates	☐
Update product catalogue with new products	☐
Confirm supplier contact details	☐
Review default emission factors for changes	☐
Set internal deadlines for data collection	☐
Assign team roles	☐

Data Collection (4-6 Weeks Before Deadline)

Task	Status
Request emission data from all suppliers	☐
Collect import quantities from customs	☐
Verify country of origin for each shipment	☐
Document production methods for each product	☐
Gather carbon price data (if applicable)	☐
Store all supporting documentation	☐
Flag any missing or incomplete data	☐

Calculation (2-3 Weeks Before Deadline)

• Calculate direct embedded emissions for each product
• Calculate indirect embedded emissions for each product
• Apply correct emission factors (default or actual)
• Verify all calculations against supporting data
• Document any data estimates or assumptions
• Run anomaly detection on calculated values
• Compare against previous quarter for consistency

Report Generation (1-2 Weeks Before Deadline)

• Generate draft CBAM report
• Verify company information is correct
• Confirm all products are included
• Check CN codes against current EU Combined Nomenclature
• Review emission factors for accuracy
• Verify total emissions are reasonable
• Generate PDF for internal records
• Generate XML for registry submission

Internal Review (1 Week Before Deadline)

• First review by data collector
• Second review by compliance manager
• Check for any anomalies or outliers
• Verify documentation is complete
• Approve report for submission
• Document review sign-off

Submission (Before Deadline)

• Log into CBAM Transitional Registry
• Upload XML report file
• Verify submission confirmation received
• Save confirmation receipt
• Store copy of submitted report
• Update compliance calendar for next quarter

Post-Submission

• File submitted report and confirmation in CBAM records
• Archive supporting documentation
• Update internal compliance dashboard
• Schedule data collection for next quarter
• Review any audit feedback or requests

Quarterly Summary

Quarter	Period	Submission Date	Status	Total Emissions
Q1 2026	Jan–Mar
Q2 2026	Apr–Jun
Q3 2026	Jul–Sep
Q4 2026	Oct–Dec

FAQ

Can I use this checklist for multiple quarters? Yes. Print a fresh copy for each quarter and maintain a binder with all completed checklists for audit purposes.

What should I do if I cannot complete an item? Flag incomplete items to your compliance reviewer. Document why the item could not be completed and any mitigation steps.

Is this checklist sufficient for audit preparation? This checklist covers all essential CBAM reporting steps. For comprehensive audit preparation, maintain all supporting documentation referenced in the checklist.

Sources

• EU Regulation 2023/956 — CBAM main regulation
• IR (EU) 2025/2621 — Default emission values and methodology
• European Commission CBAM page

Importers must maintain supporting documentation for at least four years after the submission of the CBAM declaration. Source: EU Regulation 2023/956, Article 21.

Automate Your CBAM Workflow

Following a manual checklist is better than nothing, but automation is more reliable. CbamTrack digitises this entire workflow with automated data collection, calculation, validation, and report generation. Subscribe today. For a hands-on comparison, visit our CBAM reporting software guide.