CBAM Registry
Everything importers need to know about the CBAM Registry — what it does, who needs authorised CBAM declarant status, the application process, deadlines, and how it differs from the Common Central Platform.
Everything importers need to know about the CBAM Registry — what it does, who needs authorised CBAM declarant status, the application process, deadlines, and how it differs from the Common Central Platform.
Since 1 January 2026, no goods covered by the EU's Carbon Border Adjustment Mechanism can legally enter the EU unless the importer is registered in the CBAM Registry as an authorised CBAM declarant. This single requirement sits at the center of CBAM's definitive regime: without it, customs authorities will not release CBAM goods, full stop.
Despite how central it is, the CBAM Registry is often confused with the earlier CBAM Transitional Registry, or with the separate Common Central Platform used for buying certificates. This guide clears that up — covering what the CBAM Registry actually is, who has to register, how the application process works, and what functions are (and aren't) live yet.
The CBAM Registry is the European Commission's official electronic system for managing CBAM compliance. According to Spain's environment ministry, it is a standardised, secure electronic database that holds data on CBAM accounts, CBAM declarations, applications for authorised declarant status, the register of account holders, and verification reports issued by accredited verifiers. It's the single platform through which the Commission, national competent authorities, customs authorities, authorised declarants, applicants, and accredited verifiers communicate, notify, and exchange information.
The Registry went live on 31 March 2025, with the authorised-declarant application module as its first active feature. It's accessed through the Commission's CBAM portal at cbam.ec.europa.eu.
It's important to distinguish it from two related but separate systems:
CBAM Transitional Registry — used during the 2023–2025 transitional period for quarterly emissions reporting. It has now been superseded for compliance purposes by the live CBAM Registry, though transitional-period data remains tied to it.
Common Central Platform (CCP) — a separate system, expected to become operational around 1 February 2027, dedicated exclusively to the financial side of buying and repurchasing CBAM certificates. The Registry handles declarations and certificate issuance/surrender/cancellation; the CCP handles payment and settlement. The Commission has said this split is designed to improve security and reduce unnecessary data exposure between the compliance and financial sides of the system.
Under Article 4 of Regulation (EU) 2023/956, no CBAM goods may be released for free circulation in the EU unless the importer is registered as an authorised CBAM declarant with the competent authority of their member state. This is an absolute prerequisite — customs will not release goods if the authorised declarant number isn't entered on the customs declaration, and shipments will be held at the border until it is regularised.
The authorised CBAM declarant is typically one of the following:
The importer who lodges the customs declaration in their own name and on their own behalf
The indirect customs representative lodging the declaration on behalf of an importer established outside the EU
Any other person legally obligated to declare CBAM goods for free circulation
A freight forwarder or direct customs representative generally does not need to be an authorised declarant, unless they're acting as an indirect representative. In most cases, the obligation sits with the importer of record.
One useful simplification: if you import through customs offices in multiple EU member states, you only need a single authorised declarant registration — it's valid EU-wide. You just apply through the competent authority of the member state where you're established.
If your total CBAM goods imports are expected to stay under the 50-tonne annual threshold (see our companion guide on which goods are covered under CBAM for the full sector breakdown), you may be exempt from the authorisation requirement — though importers unsure whether they'll cross that threshold are generally advised to apply anyway, since being caught without authorisation blocks the shipment at the border.
For background on how CBAM's registry obligations fit into the wider Carbon Border Adjustment Mechanism framework, this CBAM overview offers additional context. (As with any non-governmental resource, treat it as supplementary reading — the authoritative source for registration rules is always the Commission's own CBAM portal and your national competent authority.)
The application procedure is set out in Article 5 of Regulation 2023/956 and detailed further by Implementing Regulation (EU) 2025/486.
Submit your application to the competent authority of the EU member state where you're established, through the Registry's Authorised Declarant Management (AMM) module, accessible at cbam.ec.europa.eu/authorised-declarant.
Provide the required information, typically including: contact details of the responsible person, main economic activity, the types, quantities, and values of goods to be imported, and (for indirect customs representatives) contact details for at least one client.
Meet the eligibility criteria. Applicants must show no serious or repeated infringements of customs, tax, or market-abuse rules — for the applicant itself, the people responsible for CBAM matters, and any beneficial owners — and no serious criminal offences connected to their economic activity in the preceding five years.
Provide a financial guarantee where required, which is typically released after certificates have been surrendered for two consecutive years in line with Article 22 of the Regulation.
Wait for review. The competent authority generally has 120 days to assess an application (180 days for applications submitted before 15 June 2025), and may request additional information, which can extend the timeline further.
Authorisation becomes effective on the date the competent authority records the decision in the CBAM Registry — at which point you receive your authorised CBAM declarant number, which must appear on customs declarations for CBAM goods going forward.
Applications for authorised declarant status opened progressively across member states through 2025, with several national customs authorities confirming their systems were live from spring 2025 onwa
As of early 2026, the Registry's functionality is still being built out in phases:
Authorisation management (live) — submit, track, and manage your authorised declarant application, and communicate directly with your competent authority.
Import tracking module (live from early 2026) — shows the total quantity of CBAM goods imported during a selected year. Notably, this tool can be accessed even by operators who don't yet require authorisation, simply to monitor volumes against the 50-tonne threshold.
O3CI module (live) — lets third-country operators share production and emissions information more easily with their EU importer clients ahead of report submission. From 2027, operators will be able to enter verified values directly for validation by both clients and competent authorities.
Certificate calculation module (expected ~June 2026) — will automatically calculate the number of CBAM certificates due for surrender the following year; until it launches, this calculation must be done manually.
Reporting module (expected ahead of the September 2027 deadline) — will support submission of the first annual CBAM declaration.
Common Central Platform (expected ~1 February 2027) — the separate system for actually purchasing and repurchasing CBAM certificates.
31 March 2025 — CBAM Registry activated; authorised declarant application module opens.
1 January 2026 — Authorisation becomes mandatory; imports of CBAM goods without an authorised declarant number are blocked at customs.
~June 2026 — Certificate calculation module expected to go live.
31 May / September 2027 — First annual CBAM declaration for 2026 imports is due (sources differ slightly on the exact month depending on whether they reference the declaration deadline or the certificate surrender deadline, so confirm the current date on the Commission's CBAM portal); certificates corresponding to declared 2026 emissions must be surrendered by 30 September of the following year under Article 22.
1 February 2027 — Common Central Platform goes live, enabling actual certificate purchase
Because the Registry consolidates declarations, certificate holdings, and verification reports in one place, it also becomes the Commission's primary enforcement and audit tool. Competent authorities can cross-check declared emissions against verification reports, imported quantities against declared certificate surrenders, and applicant compliance history against customs and tax records — all through data that flows into the same system. For importers, this means the accuracy of what's submitted through the Registry has consequences well beyond a single reporting cycle.
Is the CBAM Registry the same as the CBAM Transitional Registry? No. The Transitional Registry was used for quarterly emissions reporting during 2023–2025. The CBAM Registry is the live system for the definitive regime from 2026 onward, and registration there is mandatory even for companies already listed in the transitional system.
Can I import CBAM goods while my authorisation application is pending? Generally, an application reference number from a submitted (but not yet approved) application may allow continued importing during the review period, but the specific rules depend on your national competent authority — check directly with them rather than assuming.
Where do I actually buy CBAM certificates? Not through the CBAM Registry itself. Certificate purchases happen through the separate Common Central Platform, expected to launch around 1 February 2027. The Registry handles declarations and tracks certificate issuance, holding, surrender, and cancellation.
What happens if I import CBAM goods without authorisation? Customs authorities will not release the goods without a valid authorised CBAM declarant number on the declaration, and importing without authorisation can result in penalties.
The CBAM Registry is the operational backbone of the EU's definitive CBAM regime — it's where authorisation is granted, declarations are filed, and certificates are tracked from issuance through surrender. Getting registered early, understanding which modules are live versus still rolling out, and keeping your import volumes and documentation aligned with what the Registry expects will matter far more in 2026–2027 than it did during the transitional reporting years, when the stakes were largely administrative rather than financial.