CBAM Compliance ChecklistsStep-by-Step Implementation Guide
Expert-created checklists covering every phase of CBAM compliance. Follow these comprehensive guides to ensure successful implementation and avoid costly penalties.
37 days until full CBAM implementation - preparation is critical
1
Initial CBAM Setup Checklist
Complete setup and registration for CBAM compliance
Critical
2-4 weeks
Legal & Registration
Identify if your imports fall under CBAM scope (cement, steel, aluminum, fertilizers, electricity, hydrogen)
Determine your national competent authority and registration requirements
Register in the CBAM Transitional Registry through your national portal
Obtain necessary business licenses and import authorizations
Review and understand applicable EU regulations (2023/956 and 2023/1773)
Internal Organization
Appoint a CBAM compliance officer and internal team
Establish reporting workflows and approval processes
Set up document management systems for CBAM records
Create internal training programs for relevant staff
Develop emergency response procedures for compliance issues
Data & Systems
Inventory all CBAM-covered imports and suppliers
Implement emissions tracking systems and databases
Establish supplier data collection protocols
Set up automated reporting tools or software
Create backup and disaster recovery procedures
2
Quarterly Reporting Checklist
Complete quarterly CBAM reporting requirements
High
Monthly process
Data Collection (First 2 weeks of quarter)
Collect import documentation for all CBAM-covered goods
Obtain emissions data from suppliers or use default values
Verify product classifications and CN codes
Calculate embedded emissions using approved methodologies
Cross-reference with customs declarations and shipping documents
Report Preparation (Week 3)
Compile all required data in CBAM reporting format
Perform internal quality checks and validations
Obtain necessary approvals from compliance team
Prepare supporting documentation and evidence
Review report against previous quarter for consistency
Submission (Week 4)
Submit quarterly report through national registry portal
Confirm successful submission and obtain confirmation receipt
Archive all supporting documents and evidence
Update internal tracking systems and databases
Schedule follow-up for any requested clarifications
3
2026 Full Implementation Checklist
Prepare for full CBAM implementation and certificate obligations
Critical
6-12 months
Authorization Process (April-December 2025)
Apply for Authorized CBAM Declarant status with national authorities
Provide financial guarantees and compliance demonstrations
Complete required training and certification programs
Establish financial arrangements for certificate purchasing
Implement enhanced verification and audit procedures
Certificate Management Systems
Set up systems for certificate purchasing and tracking
Establish price monitoring and hedging strategies
Implement certificate inventory management
Create annual declaration preparation processes
Develop certificate surrender and compliance verification
Operational Readiness
Test all systems with simulated 2026 scenarios
Train staff on new certificate management procedures
Establish relationships with certificate trading platforms
Create contingency plans for price volatility and supply issues
Conduct full compliance dry runs and mock audits
Recommended Implementation Timeline
Immediate (Next 30 days)
Critical foundation setup
- • Complete registration
- • Identify covered imports
- • Appoint compliance team
Short-term (2-6 months)
Operational implementation
- • Establish reporting workflows
- • Train internal teams
- • Complete quarterly reports
Long-term (6-12 months)
2026 preparation
- • Apply for Declarant status
- • Set up certificate systems
- • Conduct compliance testing
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