This page is a working record, not a marketing page. Each entry states the instrument, what changed, why it carries commercial consequence and what it requires of the board. Entries are dated and appear newest first. Nothing is removed when it is superseded; it is marked.
Two mechanisms, two rulebooks and two different scopes now attach to the same imported tonne. The EU regime is live; the UK regime commences on 1 January 2027 with electricity outside scope and indirect emissions deferred. The dates that matter to importers are set out below.
1 January 2026European UnionEU CBAM
The definitive regime is live, and the first verification cycle is the near-term exposure
InstrumentRegulation (EU) 2023/956 as amended; nine implementing and delegated acts adopted December 2025 and now in force.
CBAM entered its definitive regime on 1 January 2026. From that date only authorised CBAM declarants may import CBAM goods into the Union, and the certificate obligation attaches. The first annual declaration for 2026 imports is not due until 30 September 2027, and that gap is where importers are misreading the calendar: the declaration is late, but the evidence that supports it is being generated now and cannot be reconstructed retrospectively.
Certificate pricing for 2026 imports runs on quarterly EU ETS averages, moving to weekly averages from 2027, published in the CBAM Registry. Carbon price paid in a third country is deductible on a two-track basis — the actual price paid, certified by an independent person with four-year record retention, or Commission default carbon prices from 2027. Default emission values carry mark-ups rising to 30 per cent for most CBAM products from 2028, which is the mechanism by which the Commission makes actual-data collection cheaper than the alternative.
Separately, the Commission's proposal to extend scope to downstream steel and aluminium goods remains within the ordinary legislative procedure. Timing and final scope are not settled, and importers of finished goods should not plan on the current perimeter holding.
Why it mattersVerifiers must carry out an on-site inspection in the first reporting year. Verification capacity is finite, and it is being booked now by the importers who read the implementing acts in January rather than waiting for the declaration deadline to concentrate the mind.
Action for the boardTwo actions this quarter: secure an accredited verifier slot for the 2026 reporting year, and open the four-year evidence file for any third-country carbon price you intend to deduct. The mark-up schedule makes actual-data collection a pricing decision, not a compliance chore.
Covered in OGEMEX Regulatory Monitor No. 001, week ending 31 July 2026.
2026HM Revenue & CustomsUK CBAM
Primary law is done; the second tranche of secondary legislation is the outstanding variable
InstrumentFinance Act 2026; draft Carbon Border Adjustment Mechanism (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026.
The Finance Act 2026 has put UK CBAM into law and granted HMRC the powers to operate and enforce it from 1 January 2027. HMRC consulted on the first tranche of draft secondary legislation and accompanying force-of-law notices between 10 February and 24 March 2026, covering registration, weight of CBAM goods, record-keeping, returns, rate calculation and carbon price relief. A second tranche was signalled for Spring 2026 with a further technical consultation, and final secondary legislation is intended later in 2026.
Registration is triggered at £50,000 of CBAM goods imported over a rolling twelve months. Indirect emissions are excluded until 2029 at the earliest, and electricity sits outside scope entirely — the principal divergence from the EU regime and the one most likely to be missed by groups running a single global compliance model. The overpayment reclaim window is three years.
Why it mattersImporters with both EU and UK exposure are running two rulebooks with two scopes and two data sets. The UK carbon price relief mechanism requires the qualifying scheme to be mandatory in law and the emissions data independently verified by a full member of Global Accreditation Cooperation Incorporated — a narrower gate than most assume, and one that will exclude several voluntary schemes currently being relied upon.
Action for the boardConfirm whether your rolling twelve-month import value crosses £50,000 on current volumes. If it does, registration is a 2026 decision, not a 2027 one. Where you hold both EU and UK exposure, build one data set that satisfies the stricter of the two rather than two parallel processes.
Covered in OGEMEX Regulatory Monitor No. 001, week ending 31 July 2026.