EU Reg 2023/956, Art. 4 & 17 · Art. 6(1)

Who can file a CBAM declaration, and when

From the definitive phase, filing isn't just a form — it requires Authorised Declarant status first, and the deadline itself was amended after the original regulation was published.

By Sridhar Mothe · Founder, CarbonAtlas

Last verified: 02 September 2026

Authorised Declarant status comes first

From the definitive phase (1 January 2026 onward), you can't simply file a CBAM declaration as any EU importer — Article 4 and Article 17 of EU Regulation 2023/956 require Authorised Declarant status first. This is a separate authorisation process from customs registration, handled by each Member State's own competent authority.

Authorisation requires a clean 5-year compliance record — no serious infringements of customs rules, tax rules, or (once applicable) CBAM rules specifically. Apply well before you need to file; this isn't a same-week approval.

The real annual deadline

The annual CBAM declaration deadline is 30 September of the year following the reporting year — the 2026 reporting year's declaration is due 30 September 2027.

Reporting yearDeclaration due
202630 September 2027
202730 September 2028
202830 September 2029

This is worth double-checking against any older source: the original EU Regulation 2023/956 text specified 31 May of the following year, amended to 30 September by EU Reg 2025/2083, Art. 1. A declaration process, calendar, or tool built against the original date is working from a superseded deadline.

What the declaration itself needs to contain

Once authorised and inside the deadline, the declaration's structure is set by EU Implementing Regulations 2023/1773 and 2024/3214 — declarant details, per-good CN code and country of origin, direct and indirect embedded emissions, calculation method, and declaration-level totals, among other required elements.

See the full field-by-field breakdown on our CBAM declaration software page.

Frequently asked questions

No — from 1 January 2026, only an Authorised Declarant may submit a CBAM declaration (Art. 4 and Art. 17). Authorisation requires, among other things, a 5-year record with no serious infringements of customs, tax, or CBAM rules.

See how CarbonAtlas applies this automatically