From 2028, satisfy the quarterly certificate-holding requirement using only certificates bought in the same year, so certificates carried over from earlier years no longer count.

Authorised CBAM declarants 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(13), adding a subparagraph to Art. 22(2) 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 2028. as of 2026-08-14
It names 4 industries by name: Steel, Aluminium, Cement and Chemicals. as of 2026-08-14
Compliance is checked by competent authority, per quarter. as of 2026-08-14
Importers of cement pay for the carbon in what they bring into Europe, currently €75.46 per tonne. as of 2026

Addressee Authorised CBAM declarantsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(13), adding a subparagraph to Art. 22(2) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor

Trigger

quarterly calculation of the CBAM certificate holding requirement

Obligation

From 2028, satisfy the quarterly certificate-holding requirement using only certificates bought in the same year, so certificates carried over from earlier years no longer count.

Who is affected

Addressee

Authorised CBAM declarants

Class

Businesses

Sectors

Names Steel, Aluminium and metals, Cement and concrete, Chemicals and refining

Applies

from 2028

Burden drivers

D5 · D6 — 2 of 7 marks fire on this provision.

Source text

Verbatim

‘From 2028, the calculation referred to in the first subparagraph shall be based only on CBAM certificates purchased by the authorised CBAM declarant during that same year.

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