[Regulatory Update] EU's CBAM Applies in Full from 2026 — Verification and Reporting of Emissions Data Becomes a New Practical Requirement

The EU's Carbon Border Adjustment Mechanism (CBAM) moved to its definitive regime from January 2026. Covered EU importers now need to complete procedures as authorised CBAM declarants and respond to CBAM certificate requirements based on the emissions embedded in imported goods. Where actual emissions are used in declarations, third-party verification is required for emissions calculated at production facilities outside the EU. On 24 August 2026, the Commission published guidance for CBAM verifiers and National Accreditation Bodies, together with the procedure for verifiers to obtain access to the CBAM Registry. Accredited verifiers must register in the CBAM Registry within two months of receiving their accreditation, but not before 1 September 2026; from January 2027 they will issue verification reports in the Registry, allowing importers to use actual verified emissions in their CBAM declarations. For sectors covered by CBAM — steel, aluminium, cement, fertilisers and hydrogen — building up data collection, calculation methodology and evidence management at the supply chain level is now the foundation for CBAM compliance going forward.