Compliance & deadlines
The CBAM rules that set what you file and when: the 50-tonne threshold, key dates, default values and their mark-up.
Am I in scope? The 50-tonne de minimis
Below 50 tonnes a year you are exempt — but crossing it pulls in the whole year.
Since the 2025 Omnibus (Reg (EU) 2025/2083) there is a single mass threshold: 50 tonnes of net mass per importer (EORI) per calendar year, added up across cement, iron & steel, aluminium and fertilisers.
- Below 50 tonnes for the whole year: you are exempt from the CBAM obligations for that year.
- Crossing 50 tonnes at any point: the WHOLE year is in scope — every tonne, not just the excess.
- Electricity and hydrogen never count toward the 50 tonnes; importing them is always in scope.
- The old EUR 150 per-consignment value rule no longer applies.
Note: Check your year-to-date mass on the Compliance page (de-minimis check); the calculator gives any figure you need.
Key dates & obligations
The deadlines and thresholds that structure CBAM.
The definitive period reflects the 2025 Omnibus simplification. The structural facts the app is configured with:
- Annual declaration and surrender: by 30 September of the following year.
- Certificate sales open: 1 February 2027 (for 2026 emissions).
- Quarterly minimum holding: reduced to 50% by the Omnibus.
- De-minimis: a single 50-tonne net-mass threshold per importer per year (aggregate across cement, iron & steel, aluminium, fertilizers). Electricity and hydrogen are excluded.
Note: These are the app's configured values — always confirm the exact current figures and their EU sources in the Regulatory module, which is the live source.
Default values & the mark-up
When defaults apply and why they carry a premium.
If you don't have verified emissions data, the engine uses the official country-specific default value — plus a regulatory mark-up applied on top (phasing 10/20/30% for aluminium, cement, iron & steel; a flat 1% for fertilizers). The mark-up is applied only to defaults, never to your verified actual data.
The practical takeaway: verified data almost always costs less than defaults. That's the incentive to use the Balance Twin and supplier portal.