Importing into the UK
It owes UK CBAM to HMRC: records from 2027, registration at £50,000 of value, returns from 31 May 2028.
FA 2026 Sch 17UK CBAM · Requirements
CBAM reporting requirements in the UK: register, file, pay and keep records
The CBAM reporting requirements in the UK are a tax’s requirements: an importer of aluminium, cement, fertiliser, hydrogen, or iron and steel goods keeps records from 1 January 2027 and, at £50,000 or more of imports, registers with HMRC, files returns and pays.
They are set by Part 5 of the Finance Act 2026 and three statutory instruments, and the first return is due on 31 May 2028.
Before the detail
UK CBAM reporting requirements, in brief
The UK Carbon Border Adjustment Mechanism is a tax on the emissions embodied in certain imported goods, administered by HMRC, and its reporting requirements are those of any tax: a registration, a return, a payment and records.
It is not a disclosure duty, and nothing about it goes in the annual report, unlike the regimes gathered on the UK sustainability reporting requirements hub.
The liable person is the importer: the person in whose name, or on whose behalf, the customs declaration is made, according to HMRC’s CBAM policy summary.
Record-keeping applies to every business importer of CBAM goods from 1 January 2027; registration, returns and payment apply at £50,000 or more of imports.
How the tax itself is computed, instrument by instrument, is on our UK CBAM guide; this page sorts the same law by requirement.
In one table
The CBAM reporting requirements, one line each
Every requirement on a UK importer of CBAM goods, with the provision that sets it.
Dates are those of the first cycle under the transitory regulations.
| Requirement | Who | When | Provision |
|---|---|---|---|
| Keep a record of each CBAM good: 8-digit commodity code and description, import date, value, weight | Any business importer, at any value | From 1 Jan 2027 | S.I. 2026/802 reg 5 |
| Preserve records in writing for six years | Any business importer | Six years from period end or creation | S.I. 2026/802 reg 6 |
| Test the £50,000 value limbs on the first of each month and on expected imports | Any business importer | Monthly, from 2027 | FA 2026 Sch 17 para 2(2) |
| Register with HMRC, with EORI, value and estimated weight by sector | Importer that triggered registration | By 31 Jan 2028 for 2027 triggers; then 30 days | Sch 17 para 2(4); S.I. 2026/830 reg 2(2); S.I. 2026/802 reg 7 |
| Notify changed or incorrect registration information | Registered person | Within 30 days | Sch 17 para 4 |
| Make a return for each accounting period | Registered or registrable person | 31 May 2028 for 2027; then quarterly | Sch 17 para 7; S.I. 2026/830 reg 2(4) |
| Pay CBAM for each accounting period | Registered or registrable person | Same dates as the return | Sch 17 para 6; S.I. 2026/830 reg 2(3) |
| Use verified actual emissions data or the default value | Importer making a return | Each return | S.I. 2026/995; Sch 17 paras 10–11 |
| Keep evidence of verification, origin and any Carbon Price Relief | Importer making a return | Six years | S.I. 2026/802 reg 11; HMRC records guidance |
The emissions arithmetic behind the return, from the eight-step actual route to the default value, is set out on the carbon border adjustment mechanism page.
Who is in scope
Who must register: the £50,000 value test
Schedule 17 paragraph 2(2) sets two limbs, and either triggers registration.
The backward limb applies on the first day of a month if, in the preceding 12 months, the person imported CBAM goods with an aggregate value of £50,000 or more in the course of a business.
The forward limb applies if the person is expected to import £50,000 or more of CBAM goods before the end of a period of 30 days.
The statute says “£50,000 or more”, so imports of exactly £50,000 trigger registration.
Value means the customs value, under regulation 3 of S.I. 2026/802, not tonnes and not the emissions.
Goods of UK origin, returned goods, and goods charged under a special customs procedure and then exported are disregarded, and for other special-procedure goods only the CBAM portion counts.
The government raised the threshold from the £10,000 first proposed, according to its 2024 consultation response.
A customs agent can file returns but, the policy summary says, cannot register on the importer’s behalf and carries no liability.
- 1
Import a CBAM good
A business import of a listed commodity code from 1 January 2027 creates the record-keeping duty at once.
- 2
Test the value
On the first of each month, or on expected imports over 30 days, compare the aggregate customs value with £50,000.
- 3
Trigger registration
At £50,000 or more the importer is a registrable person and owes returns and payment from that point.
- 4
Register with HMRC
Within 30 days, or by 31 January 2028 for anyone who triggered in 2027.
- 5
Return and pay
One return for 2027 by 31 May 2028, then one for each quarter.
Which goods
Five sectors, defined by commodity code
Schedule 16 lists the CBAM goods in five sectors: aluminium, cement, fertilisers, hydrogen, and iron and steel.
Scope is set by commodity code, so a business checks the 8-digit codes on its import declarations, not the sector description.
Some goods within those sectors are expressly excluded, and HMRC gives imported scrap in the aluminium and iron and steel sectors as the example.
Electricity, which the EU CBAM covers, is not a UK CBAM sector, and glass and ceramics were consulted on and left out.
The tax applies across the whole UK, including Northern Ireland, and goods arriving from the Crown Dependencies, the Overseas Territories and the UK Continental Shelf are within it.
Private individuals importing for non-commercial purposes are outside the charge.
What is reported
What goes on the registration and the return
Registration asks for identity, the trigger date and value, and an estimate of the weight the importer expects to bring in over the next 12 months in each sector.
The return asks, for each CBAM good imported in the accounting period, the commodity code, the weight, any Carbon Price Relief and the place of origin, under regulation 10 of S.I. 2026/802.
The emissions figure comes from one of two places: verified actual data from the installation that made the good, or a default value the Treasury sets by notice.
Liability is the embodied emissions multiplied by the CBAM rate, less Carbon Price Relief, as the policy summary puts it.
The UK charges direct emissions, with the boundaries fixed by the system boundaries document, version 1.00 dated 10 July 2026, published on HMRC’s force of law notices page.
For goods imported in 2027, verified data for 2027 is used if it exists, and otherwise verified data for 2026.
A return may be amended only to correct an error, and paragraph 8(2) of Schedule 17 bars swapping default-value emissions for actual data afterwards.
As at 11 October 2026 neither the default values nor the rates guidance had been published, and HMRC’s CBAM collection still says it will publish them soon.
| Item | Registration or return | Provision |
|---|---|---|
| Name, addresses, contact, business form | Registration | S.I. 2026/802 reg 7(1)(a)–(d) |
| EORI number, and VAT number if any | Registration | reg 7(1)(e)–(f) |
| Date registration was triggered | Registration | reg 7(1)(g) |
| Value imported or expected in the trigger period | Registration | reg 7(1)(h) |
| Estimated weight by sector for the next 12 months | Registration | reg 7(1)(i) |
| 8-digit commodity code of each good | Return | reg 10(1)(a) |
| Weight, in kilograms, net of packing | Return | regs 4, 10(1)(b) |
| Carbon Price Relief claimed | Return | reg 10(1)(c) |
| Place of origin | Return | reg 10(1)(d) |
| Default value used, or verified emissions intensity | Return | S.I. 2026/995 |
| Declaration that the return is true and accurate | Return | reg 10(2) |
When
The CBAM reporting calendar: one long year, then quarters
The tax starts a full year before HMRC’s register opens, and the transitory regulations bridge the gap.
Liability is not deferred; only the paperwork is.
| Accounting period | Return due | Payment due | Provision |
|---|---|---|---|
| 1 Jan – 31 Dec 2027 | by the end of 31 May 2028 | by the end of 31 May 2028 | S.I. 2026/830 reg 2(3)–(4) |
| 1 Jan – 31 Mar 2028 | by the end of 31 Jul 2028 | by the end of 31 Jul 2028 | S.I. 2026/830 reg 2(3)–(4) |
| 1 Apr – 30 Jun 2028 | by the end of 29 Sep 2028 | by the end of 29 Sep 2028 | S.I. 2026/830 reg 2(3)–(4) |
| Each quarter from 1 Jul 2028 | Last working day of the second month after the quarter | Same day | FA 2026 Sch 17 paras 6(2)–(3), 7(2) |
Registration opens on 1 January 2028, and anyone who triggered registration during 2027 must register by 31 January 2028.
Under the ordinary rule a person registers within 30 days beginning with the day registration was first triggered, and an HMRC officer may register a person who fails to.
The other UK dates for 2027 and 2028 sit together on the UK sustainability regulation timeline.
Records
Records, even below the threshold
Regulation 5 of S.I. 2026/802 requires anyone who imports a CBAM good in the course of a business to keep a record of its 8-digit commodity code and description, its date of import, its value and its weight.
There is no value floor on that duty, and HMRC’s records guidance says the records are what prove an importer is not liable.
Weight is the net mass in kilograms at import, without packing materials, under regulation 4.
An importer that files returns also keeps evidence of the place of origin, and, where it reports actual emissions, the verification report or summary from the producer.
Carbon Price Relief needs the carbon pricing verification form, the scheme relied on and the exchange rates used, and HMRC’s provisional list of qualifying schemes was published on 27 August 2026.
Records are preserved in writing for six years from the day after the end of the accounting period, or from the day they are created, under regulation 6.
Verification of the producer’s data is done by an accredited verifier, and how accreditation works in the UK is explained on our UKAS accreditation page.
Enforcement
Penalties for missing a CBAM requirement
| Failure | Penalty regime | Provision |
|---|---|---|
| Failing to register | Failure-to-notify penalty, based on the tax lost from the end of the 30-day window | FA 2008 Sch 41, via FA 2026 Sch 17 para 34 |
| Failing to make a return | Late-return penalty points and penalties | FA 2021 Sch 24, via Sch 17 para 35; S.I. 2026/830 reg 3 |
| Errors in a return | Inaccuracy penalty | FA 2007 Sch 24, via Sch 17 para 36 |
| Paying late | Late-payment penalty | FA 2021 Sch 26, via Sch 17 para 37 |
| Not notifying changed registration details | £500, plus £40 a day while the failure continues | Sch 17 para 38 |
| Not keeping or preserving records | £500 | Sch 17 para 39 |
| Fraud and evasion | Criminal offences | FA 2026 Sch 18 |
The paragraph 38 and 39 penalties are not payable where the person has a reasonable excuse, and insufficiency of funds is not one.
Where an importer fails to give a correct weight or keep weight records, an HMRC officer may determine the weight using estimates and comparisons, under regulation 12 of S.I. 2026/802.
UK and EU
UK CBAM and EU CBAM: two taxes, two sets of requirements
The EU CBAM definitive regime has applied since 1 January 2026 and is a different law, run by the EU’s national competent authorities.
Its threshold is a single mass-based one: an EU importer bringing in more than 50 tonnes of CBAM goods must apply to be an authorised CBAM declarant.
It covers electricity as well as the five sectors the UK taxes.
It is annual: the first declaration, for 2026 imports, and the surrender of certificates are due by 30 September 2027, according to the Commission’s September 2026 webinar note.
A UK exporter is not the EU declarant, but its EU customers need verified emissions data from its installations, so its practical requirement is to produce that data.
The UK and EU agreed in the May 2025 Common Understanding to work towards linking their emissions trading systems, with mutual CBAM exemptions as one aim.
Their December 2025 joint statement aimed to conclude the linking negotiations by the next summit.
Press reports on 7 October 2026 said a linking deal had been reached, but neither government had published an agreement by 11 October 2026, so both CBAMs apply as written.
How the EU’s wider reporting rules reach UK groups is on the CSRD reporting requirements for UK companies page.
A UK business trading steel with the EU
Exporting to the EU
Its EU customer owes the EU CBAM and will ask it for verified installation emissions data.
European CommissionOther UK regimes
How UK CBAM sits beside the UK ETS and carbon reporting
UK CBAM prices imports so that they bear a carbon price comparable to that paid by UK producers under the UK Emissions Trading Scheme.
In step, free allocation of UK ETS allowances to CBAM sectors begins to phase out in 2027, with a reduction factor of 0.975 for 2027 set by S.I. 2026/278.
A UK producer in a CBAM sector therefore has UK ETS monitoring, reporting and verification duties, set out on the UK ETS reporting requirements page, and may face EU CBAM data requests too.
Embedded emissions in purchased goods are also Scope 3, category 1, for a company that reports its value chain, and the overlap is covered on the Scope 3 reporting requirements page.
The CBAM charge is a tax, not an emissions disclosure, so it does not satisfy SECR or the other GHG reporting requirements, and they do not satisfy it.
Packaging has its own tax on imports, separate from CBAM, described on the packaging EPR reporting requirements page.
Myths
What the CBAM reporting requirements do not include
There is no UK CBAM disclosure in the annual report, and no CBAM statement to publish.
There is no exemption from records for small importers: the £50,000 test decides registration, not record-keeping.
There is no reprieve for 2027: the tax runs from 1 January 2027 even though registration opens on 1 January 2028.
The overseas producer does not register, file or pay UK CBAM.
There is no UK CBAM certificate to buy, as there is under the EU scheme; UK CBAM is paid to HMRC as tax.
Figures that circulate but are wrong or not yet set
“More than £50,000” — the statute says “£50,000 or more”.
“Register in 2027” — the register opens on 1 January 2028.
“A 50-tonne UK threshold” — 50 tonnes is the EU test; the UK test is value.
Any UK CBAM rate or default value — none was published as at 11 October 2026.
What is changing
Still to come before 1 January 2027
HMRC has said it will publish guidance on rates and default emissions values for the five sectors, and on monitoring, reporting and verifying embodied emissions.
The force of law notices published so far are drafts, which HMRC says do not have the force of law until commenced on 1 January 2027.
The system boundaries document is versioned, so a later version would change what counts as embodied emissions without any change to the regulations.
Any UK–EU linking agreement would need implementing law before it changed a requirement on this page.
Check yourself
Six statements about UK CBAM requirements
Each answer names the provision it turns on.
The same structure of duties, for the other UK regimes, is gathered on the reporting requirements hub.
HMRC’s own working of the registration date is in its check if you’ll need to register collection.
True or false?
UK CBAM registration is triggered by 50 tonnes of imports.
An importer under the threshold still has to keep records.
Nothing is owed for 2027 because registration does not open until 2028.
A return made with default values can be amended later to use verified actual data.
Records must be kept for six years.
Paying the EU CBAM on a consignment satisfies the UK CBAM on the same goods.
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Frequently asked
CBAM reporting requirements, answered
What are the CBAM reporting requirements in the UK?
UK CBAM is a tax, so its reporting requirements are a registration with HMRC, a return and payment for each accounting period, and records.
An importer of CBAM goods must keep records from 1 January 2027 whatever its volume.
One that imports £50,000 or more of CBAM goods in a rolling 12 months, or expects to within 30 days, must also register, file returns and pay.
The law is Part 5 of, and Schedule 17 to, the Finance Act 2026, with S.I. 2026/802, 830 and 995.
Who has to register for UK CBAM?
A person who triggers registration under Finance Act 2026 Schedule 17 paragraph 2: on the first day of a month, it imported CBAM goods worth £50,000 or more in the preceding 12 months in the course of a business, or it expects to import £50,000 or more in the next 30 days.
The liable person is the importer, meaning the person in whose name or on whose behalf the customs declaration is made.
Is the UK CBAM threshold £50,000 of value or 50 tonnes?
Value.
The UK test is an aggregate value of £50,000 or more of CBAM goods, measured as the customs value under S.I. 2026/802 regulation 3.
The 50-tonne threshold belongs to the EU CBAM, which uses a single mass-based threshold for authorised declarant status.
When does UK CBAM registration open?
On 1 January 2028, a year after the tax starts on 1 January 2027.
Anyone who triggers registration during 2027 must register by 31 January 2028 under S.I. 2026/830.
After the transitory period the ordinary rule is 30 days from the day registration is first triggered.
When is the first UK CBAM return due?
The first accounting period is the whole of 2027, and its return and payment are both due by the end of 31 May 2028.
Two quarters follow under the transitory rules, due by 31 July 2028 and 29 September 2028.
From the quarter ending 30 September 2028 the ordinary rule applies: the last working day of the second month after the quarter ends.
What goes on a UK CBAM return?
For each CBAM good imported in the period, S.I. 2026/802 regulation 10 requires the 8-digit commodity code, the weight, the amount of Carbon Price Relief and the place of origin, with a declaration that the return is true and accurate.
S.I. 2026/995 adds fields for the default value or verified emissions intensity used.
HMRC may require further information by notice.
Do I need records if I am under the £50,000 threshold?
Yes.
S.I. 2026/802 regulation 5 applies to anyone who imports a CBAM good in the course of a business, whatever the value: the 8-digit commodity code and description, the date of import, the value and the weight of each good.
HMRC says the records prove you are not liable, and a fixed £500 penalty applies for failing to keep them.
How long must UK CBAM records be kept?
Six years: from the day after the end of the accounting period where the record relates to one, otherwise from the day the record is created, under S.I. 2026/802 regulation 6.
Records must be kept in writing, which includes electronic form.
How are embedded emissions calculated for UK CBAM?
Either from verified actual data supplied by the installation that made the good, under S.I. 2026/995, or from a default value set by Treasury notice.
Liability is embodied emissions multiplied by the CBAM rate, less Carbon Price Relief.
The UK charges direct emissions, measured against the system boundaries document version 1.00 of 10 July 2026.
Have the UK CBAM default values been published?
Not as at 11 October 2026.
HMRC’s collection page, updated 9 September 2026, says guidance on rates and default emissions values for the five sectors will be published soon, and its records guidance says the default values will be set later this year.
Does the overseas producer report to HMRC?
No. The UK importer is the taxpayer and the only person who registers and files.
The overseas installation’s part is to supply verified emissions data and, for Carbon Price Relief, a carbon pricing verification form completed by its accredited verifier.
What are the penalties under UK CBAM?
Finance Act 2026 Schedule 17 Part 11 brings CBAM into HMRC’s standard penalty codes for failing to register, failing to file a return, errors in returns and late payment.
It adds its own: £500 plus £40 a day for failing to notify changed registration details, and £500 for failing to keep or preserve records.
Schedule 18 creates criminal offences.
Does an EU CBAM declaration cover UK CBAM?
No. They are two separate regimes.
A UK importer pays UK CBAM to HMRC on goods entering the UK; an EU importer of UK-made goods is liable under the EU CBAM and will ask the UK producer for verified emissions data.
No linking agreement or mutual exemption was in force as at 11 October 2026.
What do UK exporters to the EU have to report under the EU CBAM?
Nothing directly: the EU importer, as an authorised CBAM declarant, declares and surrenders certificates.
The UK producer’s practical requirement is to provide verified installation emissions data to its EU customers.
The first EU annual declaration, covering 2026 imports, is due by 30 September 2027.
Is UK CBAM a sustainability disclosure?
No. It is a tax with a registration duty, a return, a payment and records.
Nothing about it appears in the annual report, and it is separate from SECR, UK SRS and the UK ETS, although the emissions data a supplier provides may also feed a buyer’s Scope 3 work.
Can a customs agent register for CBAM on my behalf?
No. HMRC’s policy summary says a tax agent can file but cannot register for CBAM on behalf of the liable person, and carries no liability.
The importer registers and remains liable.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 21 sources fromlegislation.gov.ukHMRCHM Treasury / HMRCHM TreasuryEuropean CommissionGOV.UK (Cabinet Office)
- legislation.gov.ukFinance Act 2026 (2026 c. 11), Part 5 — the charge to CBAM
Sections 142–158: the charge, the liable person, reliefs and the map of Schedules 16 to 19.
- legislation.gov.ukFinance Act 2026, Schedule 16 — CBAM goods
The five sectors, defined by commodity code.
- legislation.gov.ukFinance Act 2026, Schedule 17, paragraph 2 — duty to register with HMRC
The £50,000-or-more value test, its two limbs, the disregards and the 30-day window.
- legislation.gov.ukFinance Act 2026, Schedule 17 — administration of CBAM
Accounting periods, returns, records, and the penalties in Part 11.
- legislation.gov.ukS.I. 2026/802 — CBAM (Administrative Provisions) Regulations 2026
Value and weight (regs 3–4), records (regs 5–6), registration contents (reg 7), the return (reg 10).
- legislation.gov.ukS.I. 2026/830 — CBAM (Transitory Provision) Regulations 2026
Registration by 31 January 2028, the 2027 accounting period, first return and payment by 31 May 2028.
- legislation.gov.ukS.I. 2026/995 — CBAM (Emissions and Verification) Regulations 2026
Made 8 September 2026: how embodied emissions are determined and verified.
- legislation.gov.ukS.I. 2026/809 — CBAM (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026
The quarterly rate method and the qualifying-scheme conditions.
- legislation.gov.ukS.I. 2026/994 — CBAM regulations on Carbon Price Relief
Claiming, verifying and calculating the relief.
- HMRCPrepare for the Carbon Border Adjustment Mechanism (CBAM)
Updated 9 September 2026: registration opens 1 January 2028; rates and default values guidance still to come.
- HM Treasury / HMRCCarbon Border Adjustment Mechanism (CBAM): policy summary
Liable person, tax point, liability formula and data-year rule.
- HMRCKeeping records for CBAM
Records for six years, the £500 fixed penalty, and what to keep for actual emissions and reliefs.
- HMRCCheck if you’ll need to register for CBAM
HMRC’s working of the registration date.
- HMRCCBAM: force of law notices and reference document
Draft notices (not yet in force), the system boundaries document and the carbon pricing verification form; updated 9 October 2026.
- HMRCUK CBAM: current qualifying carbon pricing schemes
The provisional list for Carbon Price Relief, 27 August 2026.
- HM TreasuryIntroduction of a UK CBAM from January 2027 — government response (PDF)
The rise of the threshold from £10,000 to £50,000.
- legislation.gov.ukS.I. 2026/278 — UK ETS free allocation for CBAM sectors
The UK CBAM reduction factors for UK ETS free allocation, 2027–2030.
- European CommissionCBAM definitive regime
EU CBAM from 1 January 2026: the 50-tonne mass threshold, authorised declarants and certificates.
- European CommissionWebinar follow-up: CBAM from policy to practice (30 September 2026)
The first EU CBAM declaration and certificate surrender are due by 30 September 2027.
- GOV.UK (Cabinet Office)UK–EU Summit: Common Understanding (19 May 2025)
The commitment to work towards linking the two ETSs and mutual CBAM exemptions.
- GOV.UK (Cabinet Office)UK–EU Joint Statement (December 2025)
The aim to conclude ETS linking negotiations by the next summit.
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