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On 7 April 2026, the Commission published the first quarterly CBAM price at EUR 75.36 per certificate for the first quarter of 2026. The prices for the remaining quarters will be released on 6 July 2026, 5 October 2026, and 4 January 2027, respectively. Each quarterly price will apply to the sale of CBAM certificates for emissions from CBAM goods imported into the Union during that quarter. From 2027 onwards, the price will be published weekly.
How Many Certificates Must Be Surrendered?
The number of CBAM certificates to surrender is determined by the amount of imported CBAM goods and their specific embedded emissions. This amount is reduced by the emissions covered by EU ETS free allocation, and—where relevant—further reduced by emissions already covered by a carbon price that has been effectively paid in the country of origin or a third country. One CBAM certificate equals one tonne of CO₂ equivalent.
How and When Are Certificates Purchased?
There is no obligation to hold CBAM certificates during 2026. As certificate sales on the common central platform begin only from February 2027, there is no legal obligation to hold certificates during 2026.
From 1 February 2027, Member States will sell CBAM certificates to authorised CBAM declarants on a common central platform managed by the Commission. Certificates are sold at the applicable price, each has a unique identification number, and sale details are recorded daily in the CBAM Registry. Authorised CBAM declarants may purchase certificates at any time throughout the year.
The Quarterly Holding Obligation — From 2027
From 2027, authorised CBAM declarants must ensure that, by the end of each quarter, they hold CBAM certificates covering at least 50% of embedded emissions in all goods imported since the beginning of the calendar year. This is determined by either default values (without the mark-up) or by the number of certificates surrendered for the preceding year for the same goods by CN code and country of origin. The quarterly holding obligation takes account of the free allocation adjustment. This obligation is assessed at the end of each quarter: 31 March, 30 June, 30 September, and 31 December.
Annual Surrender and Key Deadlines The deadline for both the first CBAM declaration and the first certificate surrender is 30 September 2027, covering the year 2026. These two obligations must be met at the same time. After certificates are surrendered, any excess certificates may be repurchased at the original purchase price, provided a request is made by 31 October of the year of surrender. On 1 November 2027, any certificates purchased for 2026 embedded emissions that remain in accounts will be cancelled by the Commission without compensation. If the required certificates are not surrendered, a significant penalty applies. The penalty for uncompensated emissions is EUR 100 per tonne, indexed to the European consumer price index. Importantly, paying the penalty does not release the declarant from the obligation to surrender the outstanding certificates.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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