EU CBAM Certificate Purchase, Holding, and Surrender System — Quarterly Holding Requirement (50%) and Annual Settlement Schedule
ENFORCEMENT TIMELINE
Charging on embedded emissions begins with the start of the definitive period on January 1, 2026; actual certificate purchases begin February 1, 2027
Overview
This card focuses on the specific operational practice for the purchase, holding, and surrender (settlement) of "CBAM certificates" under the CBAM Regulation (Regulation (EU) 2023/956, simplification amending Regulation (EU) 2025/2083).
CBAM certificates are the mechanism for imposing on importers of CBAM goods a carbon cost equivalent to the EU ETS carbon price. While the charging basis on embedded emissions begins with the start of the definitive period in 2026, the actual obligation to purchase certificates has been pushed back by one year under the simplification amendment, beginning February 1, 2027 via the central platform. From 2027, importers must hold, at the end of each quarter, certificates covering at least 50% (originally 80%) of the emissions embedded in goods imported since the beginning of the year, easing the cash-flow burden on importers. The price of certificates purchased in 2027 (corresponding to 2026 imports) is based on the quarterly average EU ETS certificate price for 2026, after which the weekly average price applies.
Enforcement Timeline
January 1, 2026: The CBAM definitive period begins. Charging on embedded emissions begins, though the obligation to purchase certificates has not yet arisen.
During 2026: The quarter-end certificate-holding requirement does not apply (Article 22(2) applies from 2027).
February 1, 2027: Sale of CBAM certificates begins via the central platform.
September 30, 2027: Deadline for the first surrender of certificates corresponding to 2026 imports.
During 2027: The obligation to hold, at each quarter-end, certificates covering at least 50% of the emissions embedded in goods imported since the start of the year begins (Article 22(2)).
October 31, 2027: Deadline for requesting the repurchase of excess certificates remaining after surrender (Article 23(1)); certificates bought in 2027 for 2026 can only be repurchased in 2027 (Article 23(2a)).
Business Impact
Importers need to establish financial planning and cash-flow management arrangements in 2026 in preparation for certificate purchases beginning in 2027. While the reduction of the quarterly holding requirement to 50% eases the immediate cash burden, managing the timing of certificate procurement ahead of the concentrated annual surrender period (end of September) remains an important practical task.
Because certificate prices are linked to the EU ETS price, businesses need to build procurement plans and hedging strategies that account for EU ETS market price volatility. There is also a mechanism to deduct CBAM certificate requirements for carbon prices already paid in the country of export, so understanding whether and how much carbon price has been paid in a supplier's country of operation is directly relevant to optimising certificate procurement costs.