Start of Registration as an Authorized CBAM Declarant: What Companies Need to Know and Do Now

The European Commission has finalized the conditions for registration as an authorized CBAM declarant with the Implementing Regulation (EU) 2025/486. It is now confirmed that, from March 28, 2025, companies subject to CBAM can submit their application for authorization. This approval is essential to continue importing CBAM-liable goods into the EU from 2026 onwards. But what requirements must companies meet, and how should they prepare?

Who Needs to Register?

The obligation to register as an authorized CBAM declarant applies to all companies importing goods covered by CBAM. This particularly affects sectors such as iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity. Companies without CBAM authorization will no longer be allowed to import these goods into the EU from 2026.

The Registration Process: A Clear Procedure, but Preparation Is Needed

The application must be submitted via the central CBAM registry and requires extensive information. In addition to basic company details, applicants must demonstrate that they have the financial and organizational capacity to meet their CBAM obligations. This includes explaining how emissions are calculated and what internal control mechanisms are in place. Once the application is submitted, the competent national authority has up to 120 days to make a decision. During the initial application phase until June 2025, this period may be extended to 180 days. Companies should therefore plan ahead to avoid delays.

Integrity Check: No Previous CBAM Violations

A key requirement for approval as a CBAM declarant is that the company has not violated the CBAM regulation or its implementing provisions in recent years. If a company has been subject to administrative or judicial proceedings that have found a violation, this could result in the rejection of the application. From a German perspective, it is important to note that the Greenhouse Gas Emissions Trading Act (TEHG) has recently been amended, providing a legal basis for enforcing the EU regulation and imposing sanctions. Companies should therefore conduct internal reviews to determine whether past CBAM-related violations or irregularities have occurred and whether appropriate measures have been taken to prevent future non-compliance. If proceedings are already pending, it is essential to analyze how these could impact eligibility for registration.

Requirements for Corporate Organization and Internal Controls

In addition to the formal application process, companies must also demonstrate that they have a suitable administrative organization to meet CBAM requirements. This is particularly important for ensuring that obligations to surrender CBAM certificates are properly managed. An effective internal control system is a key requirement for registration. Companies must ensure that their internal processes are capable of detecting, correcting, and preventing errors in CBAM declarations and certificate management. They must also be able to identify and prevent irregular or illegal transactions. Establishing a structured compliance management system is not just a matter of efficiency but a prerequisite for successful authorization. Companies that have not yet implemented such mechanisms should now prioritize their development. These control mechanisms should, where possible, be digitally integrated into existing software systems. This enhances transparency across corporate structures and enables rapid intervention if errors in CBAM declarations or certificate calculations are detected.

Key Actions for Companies

With the upcoming deadlines, companies should act now. Those planning to continue importing affected goods from 2026 must first verify whether their products fall under CBAM and require registration. It is also essential to review corporate history for any past violations to avoid complications in the application process. Internal procedures should be analyzed and, if necessary, adjusted to ensure that an effective control system is in place for emissions calculation, reporting, and certificate management. A comprehensive preparation of application documents is crucial to enable a smooth application process and prevent delays in the approval procedure.

Conclusion

With the publication of the Implementing Regulation, CBAM has entered its next phase. Companies must now actively engage with the registration process to avoid delays and import restrictions from 2026. Those who prepare early can ensure smooth authorization and minimize risks related to imports.

Support with Registration

If you need assistance with registering as an authorized CBAM declarant or analyzing its impact on your company, feel free to contact us directly at helge@kolum.earth. We are also happy to support you in implementing an internal control mechanism. Best regards, Helge Wieggrefe