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CBAM authorisation under Article 5: checklist, requirements, and transitional provision

Art. 5 of Reg. (EU) 2023/956 requires every importer of CBAM goods to be authorised as a CBAM declarant before importing. The application requires specific information under Art. 5(5): EORI, economic activity, tax certification, declaration of honour, financial capacity and estimated import volumes. Once granted, authorisation is valid across the entire EU (Art. 17(1)). Art. 17(7a) provides a transitional safety net: importers who apply before 31 March 2026 may continue importing provisionally while their application is being processed.

Generate your CBAM dossier — €299Free check: does CBAM affect you?

€299 · One-time · 12 professional deliverables · Your data never leaves your browser

Built on Reg. (EU) 2023/956 · Modified by Reg. (EU) 2025/2083 · 13,566 default values (Reg. 2025/2621) · 100% browser-side — your data never leaves your device

The numbers that matter for your CBAM authorisation application

Art. 5(5)
6 information requirements: EORI, activity, tax cert, declaration of honour, financial capacity, volumes
Art. 17(1)
Authorisation granted in one member state is valid across all 27 EU countries
Art. 17(7a)
Apply before 31 March 2026 → may import provisionally while application is processed

Your Art. 5 authorisation timeline

1
Prepare the 6 Art. 5(5) information requirements
Gather your EORI number, description of main economic activity, tax compliance certification, sworn declaration of honour, evidence of financial and operational capacity, and estimated volume and value of CBAM imports.
2
Submit your application through the AMM module
Access the CBAM Registry via the EU Customs Trader Portal. Open the Authorisation Management Module and submit your complete application.
3
Deadline: 31 March 2026 for Art. 17(7a) provisional importing
If you submit before this date, you may continue importing CBAM goods provisionally while your NCA processes the application. Missing this deadline means no imports until authorisation is granted.
4
NCA review: up to 90 working days
Your NCA reviews the application. They may request additional information. The decision must be issued within 90 working days of a complete application.
5
Authorisation granted: valid EU-wide
Once authorised, you can import CBAM goods through any EU port. No need for separate authorisations per member state.
6
Begin quarterly certificate purchases and annual declarations
From 1 February 2027 (certificate sales start), purchase certificates quarterly (Art. 22(2)). First annual declaration by 30 September 2027.

Three authorisation mistakes importers should avoid

MISTAKE 1 — MISSING THE 31 MARCH 2026 DEADLINE

Failing to submit before the Art. 17(7a) cut-off

Art. 17(7a) allows provisional importing only if you applied before 31 March 2026. After this date, you cannot import CBAM goods until your application is fully approved. This deadline is critical for supply chain continuity.

MISTAKE 2 — INCOMPLETE FINANCIAL CAPACITY EVIDENCE

Submitting without adequate proof of financial and operational capacity

Art. 5(5)(e) requires evidence of financial and operational capacity. This may include audited accounts, bank references or insurance certificates. Incomplete evidence triggers additional requests and delays.

MISTAKE 3 — ASSUMING AUTHORISATION IS AUTOMATIC

Expecting rubber-stamp approval

NCA review is substantive. The NCA assesses your compliance record, financial capacity and import plans. Prepare your documentation thoroughly — CBAMCheck helps by structuring your emissions data and import analysis before you apply.

What you receive: 12 deliverables in one ZIP file

CBAMCheck generates a complete CBAM compliance dossier — not a single PDF. 12 structured documents delivered as a ZIP file, each citing the specific article of Reg. (EU) 2023/956 it addresses.

1

Scope Assessment

Determines whether your imports fall under CBAM and which obligations apply. Art. 2 + Art. 2a of Reg. (EU) 2023/956.

2

Embedded Emissions Calculation

Calculates embedded emissions per tonne using default values from Implementing Reg. (EU) 2025/2621 or your actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Estimates the number of certificates required and the projected cost, adjusted for free allocation (Art. 31).

4

Draft CBAM Declaration

Pre-structured declaration following Art. 6(2) requirements: quantities, emissions, certificates, carbon price.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction. Pre-formatted for the CBAM Registry.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements. Ready for verifier review.

7

Verification Preparation

Structured preparation for Art. 8 verification by an accredited verifier. Annex VI checklist included.

8

Supplier Letter Template

Model letter in English requesting emissions data and installation information from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations (Art. 22(2)), annual declaration deadline (30 September), and key milestones.

10

Executive Summary

One-page overview of your CBAM exposure: cost estimate, timeline, risk areas. Ready for management or board reporting.

11

Interactive HTML Dashboard

Standalone HTML dashboard with 2026–2032 projections reflecting free allocation phase-out (Art. 31). Works offline, no subscription.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines, reporting windows and certificate purchase schedules.

Generated from your input data, in your browser. No data leaves your device.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company's actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emissions calculations.

Estimate your CBAM exposure

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What CBAM compliance costs with each alternative

FeatureFree toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoHTML, 7-year projectionPlatform-locked
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoVia Professional PackYes

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML dashboard (2026–2032 projection)
  • 13,566 official default values integrated
  • English supplier letter template
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
PROFESSIONAL PACK
€1,999
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs brokers
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription. The 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

The EU CBAM portal ASKS for data. CBAMCheck CALCULATES it.

THE EU CBAM PORTAL

Asks you to declare data

The EU CBAM Registry (Art. 14) requires you to submit total embedded emissions, number of certificates and carbon price documentation. It does not calculate these for you. You must arrive with the numbers ready.

CBAMCHECK

Calculates the data you need to declare

CBAMCheck takes your import data (tonnes, CN codes, country of origin) and generates the embedded emissions calculation, certificate estimation, carbon price documentation and all supporting records. You download the dossier and use it to complete your declaration in the CBAM Registry.

Enforcement: what happens when CBAM certificates are missing

Art. 26 of Reg. (EU) 2023/956 sets the penalties.

⚠️
Authorised declarant: penalty identical to EU ETS rate
EU ETS rate per certificate

Art. 26(1): an authorised CBAM declarant who fails to surrender the required certificates by 30 September faces a penalty identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased per Art. 16(4). The penalty applies per certificate not surrendered. Payment does not release the obligation to surrender outstanding certificates (Art. 26(3)).

⚠️
Unauthorised importer: penalty 3–5 times the standard rate
3–5×

Art. 26(2): anyone introducing goods without authorisation faces a penalty of 3 to 5 times the standard penalty, depending on duration, gravity, scope, intent and cooperation. Also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Preparing authorisation applications for multiple importing companies?

The Professional Pack covers 70 dossier generations. Prepare the emissions data, volume estimates and supporting documentation for 70 companies before they submit to the CBAM Registry.

Request Professional Pack →
70 generations · 1 key · Ideal for customs brokers managing multiple Art. 5 applications

What CBAMCheck guarantees and what it does not

CBAMCheck generates a document structured according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 from the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer or authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours forever.
Can I request a refund?
By activating the licence you give express consent for the immediate generation of digital content under Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for reproducible technical faults.
What if the regulation changes?
If the regulation changes during your licence validity, you can regenerate the document with the updated version of the generator at no extra cost.
What information does Art. 5(5) require?
Art. 5(5) requires: (a) EORI number, (b) main economic activity, (c) certification of tax compliance by the tax authority of establishment, (d) sworn declaration of honour of no serious infringements, (e) evidence of financial and operational capacity, (f) estimated volume and value of CBAM goods imports by type.
What is the Art. 17(7a) transitional provision?
Art. 17(7a) allows importers who submitted their authorisation application before 31 March 2026 to continue importing CBAM goods provisionally while their application is processed. This prevents supply chain disruption during the authorisation ramp-up period.
Is CBAM authorisation valid in all EU countries?
Yes. Art. 17(1) provides that authorisation granted by the NCA of one member state is valid for importing CBAM goods into any EU member state. You do not need separate authorisations per country.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

Art. 5 requires data you do not have yet. CBAMCheck calculates it. Apply with confidence.

12 deliverables. Emissions calculation. Volume estimation. Certificate projection. Art. 5(5) data ready. €299.

€299 one-time
12 professional deliverables · Browser-side · No subscription · Reg. (EU) 2023/956
Generate your CBAM dossier — €299