CBAM and the Omnibus Initiative – Easing Certificate Management and Emissions Monitoring

In addition to simplifying registration processes and reporting obligations, the Omnibus Initiative introduces further significant relief for companies subject to CBAM. The adjustments in CBAM certificate management and emissions monitoring are intended to reduce administrative burdens and improve planning security.

Adjustments to the Purchase of CBAM Certificates

One of the biggest challenges for companies so far has been the requirement to hold 80 percent of the estimated emissions in the form of CBAM certificates at the end of each quarter. This requirement is now being eased: companies will only need to cover 50 percent of their expected emissions costs. This significantly reduces liquidity constraints while maintaining oversight of certificate obligations. Additionally, companies will be given a choice between two calculation methods for the number of certificates they need to hold. They can either use public default values, adjusted for surcharges and free allocation under the EU ETS, or they can base the requirement on the number of CBAM certificates surrendered for the same goods in the previous year. A special rule applies for the first year of financial adjustments: companies will only be able to purchase CBAM certificates from February 2027 for imports from 2026. The price of these certificates will be determined based on the average EU ETS price of the respective quarter in which the goods were imported.

Adjustments to the Sale of Certificates

Another important improvement concerns the repurchase of certificates. Previously, companies were only allowed to sell back one-third of the certificates they had acquired. This restriction is now being relaxed, allowing companies to sell back as many certificates as they were required to surrender under the regulation. Simplified Emissions Monitoring and Standard Values Changes are also being introduced to emissions monitoring. Default values will be made simpler and more flexible to use. Companies will no longer have to provide detailed justifications for why actual emissions cannot be determined. Additionally, an alternative method for calculating default values will be introduced. Instead of relying on EU ETS benchmarks, which exist for only a few products, default values will now be based on the average emission intensity of the ten most polluting countries for which reliable data is available. For specific product categories such as aluminum and steel, the final production steps will be excluded from emissions monitoring. This significantly reduces the burden on manufacturers and simplifies CBAM compliance, particularly for more complex goods.

Recognition of CO₂ Prices Already Paid Abroad

The Commission is also introducing a new approach to recognizing CO₂ prices paid in third countries. Companies will have two options. They can either use standardized CO₂ price values per country, based on average national carbon pricing data that is regularly updated, or provide individual evidence of actual CO₂ prices paid in order to apply for a deduction. This flexibility is designed to ensure fair treatment for businesses while preventing unintended loopholes that could undermine the effectiveness of CBAM.

Conclusion and Recommendations

The new Omnibus Initiative regulations make it easier for businesses to manage CBAM certificates and monitor emissions. Lower financial pre-holding requirements, more flexible calculation methods, and simplified default values will ease compliance burdens for importers. However, businesses should prepare for adjustments to their certificate strategy and familiarize themselves with the new emissions calculation methods. The increased flexibility in recognizing CO₂ prices could also have a major impact on the competitiveness of imports.

Support in Preparing for the New Requirements

If you need assistance in implementing the new CBAM requirements or a detailed analysis of their impact on your company, feel free to contact us directly at helge@kolum.earth. Best regards, Helge Wieggrefe