From 2026, CBAM moves from reporting to financial enforcement.

Every authorised CBAM declarant must submit an Annual CBAM Declaration covering:

• Total quantity of imported goods
• Total embedded emissions
• Number of CBAM certificates required
• Certificates surrendered

Who Must File?

Any EU-based importer bringing in goods covered by CBAM.

This includes:

• Construction suppliers
• Steel importers
• Engineering firms
• Manufacturing SMEs
• Distributors sourcing outside the EU

If you are the customs declarant of record, you are likely responsible.

The Financial Impact

The cost of CBAM certificates will be linked to the EU Emissions Trading System (ETS) carbon price.

This means:

• Costs fluctuate
• Budget planning is essential
• Exposure must be forecast

Businesses that fail to surrender sufficient certificates face significant penalties.

Why Preparation in 2025 Is Critical

2025 should be used to:

• Conduct emissions data audits
• Establish internal reporting systems
• Apply for Authorised CBAM Declarant status
• Model financial exposure
• Train finance and procurement teams

Smart CBAM works with SMEs across Ireland and the UK to manage this entire process.

👉 Book a strategy call and ensure your 2026 declaration is accurate, compliant and cost-controlled.