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Requirement · FIN-02

Leave the guarantee in place until after 30 September of the second surrender year, and for longer where the competent authority justifies an extension.

Authorised CBAM declarants that have provided an Art. 17(5a) guarantee must comply, and it sits in an act that is partly law and partly a proposal.

Why it matters

The act this comes from is partly law in force and partly a proposal that can still change.

  • It is Art. 1(9)(b), replacing Art. 17(7) of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
  • The act gives its timing as: from entry into force (third day after publication), Art. 2. as of 2026-08-14
  • It names no industry: it applies across the economy rather than to one of them. as of 2026-08-14
  • Compliance is checked by competent authority, per period. as of 2026-08-14
Addressee Authorised CBAM declarants that have provided an Art. 17(5a) guaranteeAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(9)(b), replacing Art. 17(7) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

guarantee required under Art. 17(5a)

Obligation

Leave the guarantee in place until after 30 September of the second surrender year, and for longer where the competent authority justifies an extension.

Who is affected

Addressee
Authorised CBAM declarants that have provided an Art. 17(5a) guarantee
Class
Businesses
Sectors
No sector named — applies by size or activity
Applies
from entry into force (third day after publication), Art. 2

Burden drivers

D6 — 1 of 7 marks fire on this provision.

Source text

Verbatim

Where a guarantee is required in accordance with paragraph 5a, the competent authority shall release the guarantee immediately after 30 September of the second year in which the authorised CBAM declarant has surrendered CBAM certificates in accordance with Article 22. Notwithstanding the foregoing, the competent authority may decide to extend the duration of the guarantee where such extension is duly justified.

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