CBAM Reporting Compliance ChecklistFree Printable PDF — 20 Actionable Items

Gather quantities of natural gas, diesel, coal, and fuel oil used across each installation or production line.

Use the standard emission factors from IR (EU) 2025/2621 Annex II. Verify factor versions against the latest regulation update.

Apply the formula Σ(fuel × emissionFactor) for each fuel type and sum to get total direct emissions per CN-code category.

Collect kWh consumption data and confirm the country of grid connection to apply the correct indirect emission factor.

Use the factor from IR (EU) 2025/2621 Annex III for the relevant country. Apply the default factor with 10% markup when no country-specific factor exists.

Cross-check production tonnage against internal records, shipping manifests, and supplier invoices for each CN-code category.

Ensure emissions and production data are broken down per installation where multiple lines exist under a single reporting entity.

Retain invoices, meter readings, supplier certificates, and laboratory analysis reports that substantiate every data point submitted.

Flag sudden drops in production volume, abnormal fuel consumption ratios, or unexplained changes in emission intensity for investigation.

CBAM reports are due one calendar month after the end of each quarter (31 Mar, 30 Jun, 30 Sep, 31 Dec). Mark your calendar.

Late submissions incur penalties. Submit via the national competent authority's CBAM portal within the 30-day window.

Ensure your entity is registered with the national competent authority of the EU member state where goods are imported.

Compare current quarter emission intensity (tCO₂e per ton of product) with prior quarters. Investigate variances >15%.

Confirm that total facility emissions are correctly allocated across CN-code categories based on production share.

If total production is ≤50 tons per quarter, confirm exemption eligibility per IR (EU) 2025/2621 Art. 2 and document the reason.

If using actual supplier data instead of default values, verify the source, methodology, and validity period of the factor.

Log every data change with user identity, timestamp, and before/after values to support regulatory audits.

Keep copies of all regulation annexes, national grid operator data, and supplier certifications used as factor sources.

EU CBAM regulation requires retaining all submitted reports and supporting data for a minimum of four years from the submission date.

Record justification for every instance where actual values replace default values, including methodology and third-party verification.