CBAM in 2025 – An Outlook

The new reporting period for Q4 2024 is currently in full swing. At the same time, the European Commission is working intensively to pass additional legislative acts that will further shape the mechanism. In 2025, CBAM will undergo significant refinements.

The Authorised CBAM Declarant

Perhaps the most critical implementing regulation is the one concerning the application for the status of an authorised CBAM declarant. It is currently in the legislative process and is delayed at the European level. Its publication is still expected in January. This regulation is crucial because national authorities cannot facilitate the application process until it is finalized, even though affected companies will be required to have this status as of January 1, 2026.

The Purchase and Sale of CBAM Certificates

Equally significant for affected companies is the trade in certificates. The European Commission plans to release the administrative details of the procedure in Q2 2025. It is currently known that the certificates will be available for purchase from member states through a standardized European platform. Additionally, there are constraints specifying the minimum number of certificates that must be held at specific times and the number of surplus certificates that can be returned.

Verified Emission Data Starting in 2026

From 2026, actual emissions data—currently a major focus for companies—must be verified by an accredited verifier. The European Commission will provide further clarity on this in Q3 2025. This will include not only the requirements and processes for verifiers to become accredited but also the subsequent process for verifying emissions monitoring and collected emissions data. This is an important aspect for companies aiming to reduce CO2 costs starting in 2026.

CBAM Declaration and Emissions Monitoring

Starting in 2026, the CBAM report will be replaced by the CBAM declaration. More detailed requirements for the CBAM declaration are expected in Q3 2025. These requirements will likely resemble the data points currently found in the CBAM report. A key question will be which data is mandatory and which is optional. Additionally, the fundamental rules for emissions monitoring will be revisited and potentially revised. The guidelines under which third-country manufacturers currently struggle to monitor emissions will therefore not entirely match those applicable from 2026 onward. It is also possible that the system boundaries will be further adjusted.

Previously Paid CO2 Price and CBAM Certificate Price

Another key issue will be which foreign CO2 prices can be factored into CBAM cost calculations. The European Commission intends to publish its views on this topic in Q4 2025. Following the climate summit in Baku, it will be particularly interesting to see whether voluntary carbon pricing mechanisms will also be accepted. Details about the pricing of individual CBAM certificates will also be disclosed during this time. It is already known that these prices will be linked to the price of certificates under the European Emissions Trading System.

Interaction with Free Certificates under the European Emissions Trading System

Finally, the interaction with the free allocation of certificates under the European Emissions Trading System will also be clarified in Q4 of this year. This will primarily depend on the so-called CBAM benchmarks, which are critical for cost calculations. These benchmarks will be aligned with those under the European Emissions Trading System. However, unlike CBAM benchmarks, the latter are installation-specific.

Support for Strategic Alignment

If you need assistance implementing the regulatory requirements for your company, feel free to contact us anytime (helge@kolum.earth). We would be happy to help you set the right course now. Best regards, Helge Wieggrefe