CBAM 2026: Mandatory Compliance, Missing Data, and the Need for Proactivity

The European Union’s Carbon Border Adjustment Mechanism (CBAM) is quickly approaching a critical milestone. Designed to complement the EU Emissions Trading System (ETS) by imposing a carbon price on imports, CBAM aims to equalize the carbon cost between domestic EU production and foreign imports to prevent carbon leakage and allow for the phase-out of EU free allowance allocations to industry.

The mechanism is now transitioning from the transitional reporting phase (2023–2025) to the definitive compliance period on January 1, 2026. Therefore, CBAM obligations will have a compliance cost, tied to EU ETS allowance pricing, as of 2026. This shift mandates the eventual purchase of CBAM certificates by importers, priced directly against volatile EU ETS allowances.

This transition creates significant exposure for importers and manufacturers in energy-intensive sectors, including iron & steel, cement, aluminum, fertilizers, hydrogen, and electricity. Companies face uncertainty in forecasting these costs due to fluctuating carbon prices, inconsistent emissions data, and complex, country-specific schemes.

In a recent webinar hosted by ClearBlue Markets with a special guest from CBAMBOO, subject matter experts took a deep dive into the current and future challenges of CBAM.

Read coverage of this webinar as reported by Sarah Sobanski, Environmental Markets Correspondent, Americas, Carbon Pulse → US exporters should prepare to comply with EU CBAM

Section 1: Definitive Timelines and Regulatory Changes

Despite persistent rumors of delays, the European Commission has consistently reassured stakeholders that CBAM will start in 2026. The first compliance period begins on January 1, 2026.

Goda Aglinskaite, Senior Carbon Market Analyst at ClearBlue, confirmed the regulatory posture:

“The European Commission has stepped out and reassured multiple times that the CBAM will start in 2026, but there might be some further simplifications”.

Key dates for the first compliance year are:

• First CBAM Certificate Sales: Start February 1, 2027. CBAM certificate pricing will be tied to EU ETS auction prices on a quarterly basis in 2026 and then weekly starting 2027.
• Compliance Deadline: The first CBAM declaration for 2026 imports must be submitted by September 30, 2027, which is also the deadline to surrender the required CBAM certificates.

Approved Simplifications

The recently approved Omnibus simplification package introduced several important changes to reduce the administrative burden on small businesses:

• De-Minimis Threshold: The threshold shifted from a customs value (€150 per shipment) to a mass-based annual threshold of 50 tonnes per importer. This change excludes roughly 90% of importers but ensures that at least 99% of embedded emissions remain captured.
• Extended Deadlines: Compliance and declaration deadlines were moved from May 31 to September 30.
• Advance Purchase Reduction: The quarterly advance certificate purchase requirement, starting in Q1 2027, decreased from 80% to 50% of embedded emissions.
• Carbon Price Deduction: Importers can now claim a reduction in CBAM liability based on carbon costs paid in any third countries prior to import, not just the country of origin.

Section 2: Policy Gaps and Missing Data

Despite the certainty of the start date, critical policy gaps remain, placing importers in a difficult position.

Gabriel Rozenberg, co-founder and CEO of CBAMBOO, addressed the frustration over missing regulatory inputs:

“The benchmark, as you can see from the mathematics of what's in front of you, could mean that your CBAM bill is massive or zero. And the fact that the benchmark hasn't been published yet... is not acceptable”.

Missing Key Data Points

Final values for two critical components of the CBAM cost calculation formula are currently unavailable:

1. CBAM Benchmarks: The final benchmark values, which adjust for EU ETS free allowances, are not expected until Q1 2026. A provisional list is, however, expected by the end of October.
2. Default Emission Values: The Commission has yet to publish the default emission values by product and country, which are expected in Q4 2025. These values have been expected to be conservative—based on the worst-performing producer in each country—and include a mark-up of up to 30% to incentivize the use of actual supplier data. However, there are indications the approach to default values may also be subject to revision. This could be addressed in the upcoming legislation.

Upcoming Legislation

Three key Implementing Acts are expected in Q4 2025 following August consultations. These acts will clarify complex rules regarding:

• The adjustment mechanism for carbon prices already paid in non-EU countries, including accounting for any rebates or free allocations received.
• The reporting methodology for the definitive period, simplifying emission calculation rules and detailing the use of default values.
• The exact rules for calculating the adjustment for EU ETS free allowances, specifically addressing the challenge of matching production-based EU ETS benchmarks to individual CBAM goods.

Section 3: Pricing Forecasts and Strategic Action

CBAM certificates are non-tradeable but their price is fixed to the price of EU ETS allowances (EUAs). ClearBlue Markets forecasts that prices are projected to increase rapidly from 2026 onwards, driven by the rapidly decreasing EU ETS cap and the continuous phase-out of free allowances for EU industry.

• 2026 Forecast: Prices are projected to end the year within the EUR 88.24 – 96.14 range (Most Likely forecast).
• 2030 Forecast: Prices are expected to rise significantly, reaching EUR 91.79 – 197.11.

Mandatory Corporate Response

Since costs accrue from January 1, 2026, companies importing substantial volumes of covered goods must integrate CBAM liability into every part of the purchase and sale process.

• Supplier Data is Paramount: Gabriel Rozenberg stressed the need for accurate data:
  
  "The fundamental point here is. Whatever your supplier data, as long as your supplier data is accurate, you can pretty much guarantee that the supplier data will be a lower carbon intensity figure than the default value that you could also use. So, in any circumstance, it will pay you to get supplier data.".
  
  
• Establish Governance: Organizations should set up a CBAM Working Group involving Trade and Customs, Procurement, CFO, and Sales teams to track costs, manage financial risk, and ensure accurate internal accounting.
• Exporters’ Advantage: Exporters must proactively collect and verify embedded emissions data. This is an opportunity, particularly for regions like Canada with low-carbon production, as having low-carbon intensity can be a significant competitive advantage.
  
  "You know, this is also an opportunity if you have a low carbon product, because then you can essentially have low or no cost and that is the intention...", said Adi Dunkelman, ClearBlue’s Director of Policy and Strategy.

The EU CBAM is also catalyzing global carbon pricing adoption, with 80 jurisdictions now implementing or developing such policies. Ms. Dunkelman noted that this drive is intentional:

"The goal of CBAM of course is to protect the competitiveness of EU industry as they phase out the free allowances, but it's also to catalyze global carbon pricing in other jurisdictions".

Section 4: Announcing CBAM Market Insight: Leveraging Proprietary Intelligence

The persistent uncertainty surrounding definitive benchmarks, default values, and the volatile price of certificates mandates a sophisticated forecasting solution.

ClearBlue Markets announced the launch  of CBAM Market Insights, a new offering designed to support companies navigating this environment. The service leverages proprietary Data Insights within the ClearBlue Vantage carbon intelligence platform and ClearBlue's award-winning Market Intelligence services.

Read our news release →

Jennifer McIsaac, ClearBlue’s Chief Market Intelligence Officer, highlighted the tool’s analytical focus:

“The main driver of that exposure is going to be the carbon intensity of the good. Also critical is minimizing the exposure in light of carbon pricing in the exporting jurisdiction. CBAM Market Insight provides the tools to accurately model this exposure over time at the product level.”

Key CBAM Market Insight Features

The proprietary solution focuses on three core areas: Forecasting, Compliance, and Advanced Analytics:

A. Accurate Price Forecasting (Proprietary Data)

This feature provides the critical pricing outlooks necessary for budgeting and risk management.

• CBAM Certificate Pricing: Delivers CBAM Certificate prices linked directly to EU ETS auctions.
• Proprietary Forecasts: Includes ClearBlue’s proprietary near and long-term price forecasts, along with next-week outlooks.
• Market Intelligence Integration: Offers access to market reports, datasets, news updates, and a sentiment scorecard.

B. Comprehensive Compliance Support (Global Coverage)

The service enables clients to calculate and mitigate liabilities, particularly concerning carbon prices paid abroad.

• Certificate Needs Calculation: Helps companies calculate future CBAM certificate needs and related costs to support planning and budgeting.
• Carbon Price Deduction Tracking: Assesses how current and future expected carbon pricing in the country of origin affects CBAM certificate needs, leveraging ClearBlue's worldwide carbon Market Intelligence.

C. Advanced Analytics and Reporting via ClearBlue Vantage (Interactive Tools)

The most powerful analytical features reside within the proprietary ClearBlue Vantage platform.

• Scenario Modeling: Clients can run forecasts across several products, aggregate results, and track both per-product certificate obligations and total estimated costs. The underlying calculations utilize ClearBlue’s carbon pricing forecast scenarios (High, Most Likely, and Low) for both the EU and the jurisdiction of origin.
• Interactive Visualizations: Users can create interactive visualizations of CBAM obligations, certificate needs, and the effective carbon price.
• Data Management: Allows clients to save and reuse forecasts for ongoing evaluation and analysis.
  
  

Conclusion: Act Now to Turn Liability into Advantage

The definitive period for CBAM begins on January 1, 2026. The system is law, and its implementation is non-negotiable despite policy gaps. As Gabriel Rozenberg observed, compliance is not a single reporting event, but rather "merely the last step in a continuous process of CBAM management". Businesses must proactively integrate this complex liability across their organizations now.

ClearBlue Markets is uniquely positioned to guide companies through this transition. Our newCBAM Market Insights solution, leveraging proprietary data and the ClearBlue Vantage platform, provides the essential price forecasts and advanced analytical tools necessary to understand and optimize CBAM obligations over time.

By securing verified supplier data and leveraging proprietary market intelligence, businesses can move beyond mere compliance to quantify their exposure and turn this regulatory cost into a strategic, long-term competitive advantage.

Take Action: To secure accurate forecasting, understand your total CBAM exposure, and integrate carbon costs into your strategic business planning, inquire about the proprietary CBAM Market Insights feature today.