1 January 2026 is the effective date of the definitive CBAM arrangement that ends ng the transitional period. With the definitive mechanism approaching its entry into force, the Council of the European Union adopted a regulation on 29 September 2025 to amend Regulation (EU) 2023/956 (“CBAM Amending Regulation”). The CBAM Amending Regulation is now waiting for publication in the Official Journal.

The new law introduces a number of enhancements designed to mitigate the regulatory and administrative burden and reduce compliance costs, particularly for SMEs, while maintaining the climate ambition. CBAM should cover about 99% of total emissions embedded in imported goods.

Among other things, the CBAM Amending Regulation:

  • exempts certain categories of importers from CBAM reporting (e.g. based on weight of imported goods),
  • changes the due date for submission of CBAM declaration from 31 May to 30 September of the year following the year of import,
  • allows for the outsourcing of the CBAM declaration compliance duties,
  • postpones the deadline for purchase of certificates for 2026 embedded emissions to February 2027,
  • changes the due date for surrender of CBAM certificates from 31 May to 30 September of the year following the year of import, and
  • imposes additional penalties on importers who have failed to comply with their duty to obtain the authorised CBAM declarant status.

The CBAM Amending Regulation enters into force 3 days after publication in the Official Journal.

Importers are advised to verify:

  • compliance with requirements applicable to them during the transitional period (Q4’23 to Q4’25) before introduction of the definitive mechanism;
  • their compliance duties under the definitive mechanism as of 1 January 2026.

If this issue pertains to your business and you are interested in our assistance, do not hesitate to contact us.

This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.