How CBAM certificates will work: buying, holding and surrendering from February 2027

Much of the CBAM commentary thisyear has focused on prices. Less has been written about the machinery: howcertificates are actually bought, how many you must hold, and what happens atsurrender. With sales opening in February 2027, this guide sets out themechanics that every authorised declarant's finance team needs to understand.

What a certificate is

A CBAM certificate representsone tonne of CO2e embedded in imported goods. Your annual liability is thetotal embedded emissions in your imports, less the deductions the rules allow:the free allocation adjustment, and credit for carbon prices already paid inthe country of origin. One certificate is surrendered for each remaining tonne.

Buying

Certificates are bought throughthe CBAM registry, not on an open market. There is no trading betweencompanies. For 2026 imports the price is the quarterly figure already beingpublished, which has sat close to €75 per tonne across the first half of theyear. From 2027 the price moves to a weekly average of EU ETS auctions, so itwill follow the carbon market far more closely and deserves proper treasuryattention.

The holding rule

You cannot simply wait until thesurrender deadline and buy everything at once. At the end of each quarter, thecertificates in your registry account must cover at least half of the liabilityaccrued since the start of the year [verify the final percentage in theimplementing rules before publishing; the original regulation required 80 percent and the Omnibus package reduced the requirement]. In practice this meansbuying steadily through the year, broadly in step with your imports, whichturns CBAM into a rolling cash-flow item rather than an annual bill.

Surrender

Surrender happens once a year.By 30 September you surrender certificates covering the previous calendaryear's imports, so the first deadline, 30 September 2027, settles everythingimported during 2026. The declaration behind that surrender must be supportedby verified emissions data or defaults, which is why the quality of yourmonitoring and reporting feeds directly into what you pay.

Buy-back and cancellation

Over-buying is only partlyrecoverable. The registry will buy back a limited proportion of surpluscertificates at the price you paid, and the cap is set so that hoarding orspeculation does not pay [state the final buy-back limit once the implementingrules confirm it]. Certificates beyond the buy-back limit are eventuallycancelled without compensation. The planning consequence is simple: forecastyour liability honestly, buy to the holding rule, and avoid building a largesurplus.

Getting the estimate right

Everything above depends on onenumber, your accrued embedded emissions, and that number is only as good as thedata behind it. Underestimate and you breach the holding rule. Overestimate andyou strand cash in certificates you may not fully recover. The importers whowill find 2027 easy are the ones treating emissions data as a live managementnumber through 2026, updated quarterly, checked against supplier declarations,and verified before it reaches the registry.

That groundwork is whereCBAM-Assured comes in. We train teams on the certificate mechanics and helpimporters and suppliers build verifiable emissions data. Contact us beforeFebruary makes it urgent.

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