EU Reg 2023/956, Art. 21–26

CBAM certificates: pricing, cadence, and surrender

The certificate price isn't fixed — it tracks the EU ETS auction average on a schedule that changes in 2027. Here's exactly how it works and what happens if you surrender too few.

By Sridhar Mothe · Founder, CarbonAtlas

Last verified: 02 September 2026

How the certificate price is set

The CBAM certificate price tracks the average auction price of EU ETS allowances over the preceding period. The publication cadence itself is a common point of confusion: in 2026, prices are published quarterly — on the first Monday after each quarter closes. From 2027, publication moves to weekly, matching the standard EU ETS cadence.

PeriodPricePublished
Q1 2026€75.36/tCO₂e7 April 2026
Q2 2026€75.28/tCO₂e6 July 2026
Q3 2026due 5 October 2026
Q4 2026due 4 January 2027

A declaration or calculator that hardcodes a single "current" price without checking the publication date is at real risk of using a stale figure — the Q1→Q2 2026 move alone was an €0.08/tCO₂e change, small per tonne but compounding at volume.

Surrendering certificates

You owe one certificate per tonne of CO₂-equivalent in your net obligation — gross embedded emissions, reduced by any free-allocation benchmark credit and any Article 9 deduction for a carbon price already paid in the country of origin. The result is the number of certificates to surrender by the annual deadline.

Article 26: the under-surrender penalty

If you surrender fewer certificates than you owe, Article 26 (as amended by EU Reg 2025/2083) imposes a penalty on the shortfall, with two distinct tiers:

TierRateApplies to
Authorised Declarant, insufficient certificates€100/tCO₂e (indexed annually to EU inflation)A registered declarant who under-surrenders
Unauthorised import€300–€500/tCO₂e (3–5× the standard rate)Importing CBAM goods without Authorised Declarant status at all

Both are distinctly higher than the €10–€50 range that applied only during the earlier transitional reporting-only phase (Oct 2023–Dec 2025, before certificate surrender existed at all).

This penalty is charged in addition to still owing the underlying certificates — it doesn't substitute for them.

Frequently asked questions

In 2026, quarterly — published on the first Monday after the end of each quarter. From 2027 onward, weekly. This is a real cadence change year-over-year, not a static rule.

See how CarbonAtlas applies this automatically