During the transition period from 1 October 2023 to 31 December 2025, registrants subject to reporting requirements must submit a report to the EU Commission every quarter of each calendar year. According to the CBAM Regulation, the CBAM report should contain information on the volume of imported goods, the actual total grey direct emissions and indirect emissions, and the carbon price payable in the country of origin for grey emissions from imported goods that are not subject to deduction or any other form of compensation upon export.
Impact of the amendment to the CBAM Regulation by the European Commission’s Omnibus I Package on the reporting obligation during the transition period
With the entry into force of the Omnibus Regulation on 20 October 2025, important amendments to Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism (CBAM Regulation) were introduced.
The amendments to the CBAM Regulation mainly affect the regulatory phase, which begins on 1 January 2026, and who will require authorisation to import CBAM goods from the start of the regulatory phase.
The new mass-based threshold of 50 tonnes introduced by Article 2a will only take effect from 1 January 2026 (Article 36 of the CBAM Regulation). It therefore has no impact on the reporting obligation during the transitional period. During the transitional period, the obligation to submit a quarterly CBAM report to the CBAM transitional registry in accordance with Article 35 of the CBAM Regulation will remain in place.
The DEHST has summarised an overview and further details of the changes resulting from the Omnibus Regulation on its website.
Status of the correction procedure
The DEHSt (for German companies) has contacted companies as part of the correction procedure under Article 14(3)(b) of Implementing Regulation (EU) 2023/1773.
It requests that companies use the legally prescribed communication channel via the CBAM transitional register when communicating directly with the DEHSt as the competent authority
If you have difficulties registering in the transitional register, please visit the customs help page or contact the customs service desk.
Amendment and correction of CBAM reports
In accordance with Article 9(1) of the CBAM Implementing Regulation (EU) 2023/1773, amendments to a CBAM report that has already been submitted may, in principle, be made by the declarant themselves two months after the end of the respective reporting quarter – i.e. up to one month after the deadline for submitting a CBAM report.
After this deadline, the status of the CBAM report changes to ‘registered’ and the declarant can no longer edit the report. If changes are required after this point, the declarant may, in accordance with Article 9(3) of the CBAM Implementing Regulation (EU) 2023/1773, apply to the DEHSt for the CBAM report to be reassigned by means of a notification in the CBAM transitional register, stating the reasons and specific changes.
If you wish to correct a report, please send your request via the enquiry function in the CBAM transitional register, providing the following information:
- the report ID of the report in question
- the reason for the requested change
- the corrections you intend to make
Please contact the authorised authority in your Member State.
Note for reporting entities
You have submitted an application for authorisation via the authorisation module in the CBAM register before 31 March 2026. In this case, you may continue to import CBAM goods on a provisional basis without the status of an authorised CBAM declarant until the competent authority has made a decision (see Article 17(7a) of the CBAM Regulation). This exception only applies to applications received by 31 March 2026. Please note that such an application should be made before the goods are imported to avoid subsequent penalties or rejection of the goods.
Further information:
Source: DEHSt
