Complete Guide to CBAM Reporting — Requirements, Deadlines & Templates for 2025–2026

What Is CBAM Reporting?

The Carbon Border Adjustment Mechanism is the European Union's landmark policy to prevent carbon leakage — the practice of moving production to countries with weaker climate regulations. CBAM requires importers of carbon-intensive goods into the EU to report the embedded emissions of their products and eventually purchase certificates to cover those emissions. The regulation entered its transitional phase on October 1, 2023, and will become fully operational on January 1, 2026.

During the transitional period (2023–2025), importers must submit quarterly reports detailing the embedded greenhouse gas emissions of their imported goods. These reports are filed through the CBAM Transitional Registry and do not yet require financial payments. However, starting in 2026, importers must purchase CBAM certificates at the EU ETS carbon price, making accurate reporting essential for cost management.

CBAM currently covers six sectors: iron and steel, aluminium, cement, fertilisers, electricity, and hydrogen. The regulation also extends to certain precursors and downstream products within these sectors.

Who Needs to Report?

Any person or company established outside the EU who imports CBAM-covered goods into the customs territory of the European Union must file quarterly CBAM reports. This includes manufacturers who sell directly to EU buyers and trading companies that import covered products. The reporting obligation falls on the importer of record — the entity named on the customs declaration.

If you import iron, steel, aluminium, cement, fertilisers, hydrogen, or electricity — regardless of quantity — you are subject to CBAM reporting. However, there is a de minimis exemption: if your total embedded emissions per quarter remain below 50 tons per product group, you may claim exemption. Even then, you must register with the national competent authority and declare the exemption. Use our CBAM reporting checklist to determine whether your imports qualify for the exemption.

Importers based in Turkey, the United Kingdom, Canada, the United States, Australia, China, India, and other non-EU countries are all affected. If you are unsure about your obligations, get started with CbamTrack and our compliance wizard will assess your product portfolio against current CBAM rules.

CBAM Reporting Deadlines for 2025–2026

CBAM reports must be filed quarterly. Each report covers a full calendar quarter and is due one month after the quarter ends. Missing these deadlines triggers automatic penalties, so it is critical to plan ahead. Below is the complete deadline table for 2025 and 2026.

Quarterly Filing Deadlines

Because the filing window is only one month, many importers start preparing their report as soon as the quarter closes. With CbamTrack's dashboard, you can track live progress across all quarters, set automated reminders, and generate your report in minutes rather than days. The built-in compliance calendar syncs with iCal and sends email notifications as deadlines approach.

Required Data for CBAM Reports

Each CBAM report must include product-level data for every imported good covered by the regulation. The EU requires both general information (CN code, country of origin, quantity) and emission-specific data (direct and indirect embedded emissions, electricity consumption, and the emission factors applied). The table below summarises every field you need to complete.

You can use default emission factors from IR (EU) 2025/2621 Annex III, actual supplier data, or a combination of both. When using default factors, a 10% markup is applied if the country does not have a specific factor assigned. CbamTrack's pricing plans include access to our full emission factor database with automatic mapping to your products.

Step-by-Step Guide to Filing a CBAM Report

Filing a CBAM report involves six main stages, from registration to final submission. Below is a detailed walkthrough that covers each step, including practical tips for avoiding delays and ensuring your report passes validation on the first attempt.

Common CBAM Reporting Mistakes to Avoid

Even experienced importers make errors in their CBAM reports. The most frequent mistakes involve incorrect CN codes, wrong default values, missing deadlines, and inconsistent data across quarters. Below are the most common pitfalls and how to avoid them.

• Using incorrect CN codes — a minor digit error can lead to the wrong emission factor and an inaccurate report. Always verify against the latest EU Combined Nomenclature updates.
• Omitting the de minimis check — if your total quarterly imports fall below 50 tons per product group, you may be exempt. Failing to check this wastes time and resources.
• Applying wrong default values — default emission factors vary by country and product. Using a generic factor instead of a country-specific one can understate or overstate emissions significantly.
• Missing the filing deadline — late submissions incur penalties of €10–€50 per ton of unreported emissions. Set automated reminders and start your report at least two weeks before the due date.
• Inconsistent data across quarters — regulators compare reports over time. Sudden unexplained swings in emission values trigger audits. Maintain consistent methodology across all quarters.
• Forgetting to update supplier information — if you switch suppliers or a supplier changes its production process, the embedded emission data must be updated before the next report.

CbamTrack helps you avoid every one of these mistakes. Our built-in validation engine checks CN codes against the latest EU database, verifies emission factors against country of origin, and flags anomalies before you submit. Subscribe now and see how automated validation saves hours of manual review.

CBAM Penalties for Non-Compliance

The EU takes CBAM non-compliance seriously. Penalties apply for late filing, incomplete data, and inaccurate reporting. During the transitional period (2023–2025), penalties are set at €10 to €50 per ton of unreported embedded emissions, depending on the severity and duration of the non-compliance. After 2026, these penalties increase along with the full enforcement of the certificate-purchase requirement.

If you identify an error in a previously submitted report, you should file a correction immediately. Voluntary corrections before an audit can reduce penalties significantly. National competent authorities can also impose additional sanctions, including publication of the infringement, which can damage business reputation.

The best defense against penalties is a robust reporting process with built-in quality checks. Download our CBAM reporting checklist to build a repeatable workflow that catches errors before submission.

Frequently Asked Questions

Answers to the most common questions about CBAM reporting requirements, exemptions, and the transition to the full regime in 2026.