The regulatory landscape for businesses trading carbon-intensive goods with the European Union has shifted considerably. In October 2025, the EU formally adopted the CBAM Omnibus Regulation – a targeted package of amendments designed to simplify compliance, reduce administrative burdens, and prepare importers for the full implementation of the Carbon Border Adjustment Mechanism (CBAM) from 1 January 2026. If your business imports steel, aluminium, cement, fertilisers, electricity, or hydrogen into the EU, understanding what the CBAM Omnibus rule changes mean for you is no longer optional. It is a financial and operational imperative.
What Is CBAM — and Why Does It Matter?
Before diving into the Omnibus changes, a quick recap. The Carbon Border Adjustment Mechanism is the EU’s flagship tool for preventing carbon leakage — the phenomenon where businesses relocate carbon-intensive production to countries with less stringent climate policies to avoid costs. CBAM works by ensuring that goods imported into the EU carry a carbon cost equivalent to what EU-based producers pay under the EU Emissions Trading System (ETS).
CBAM entered its transitional phase in October 2023, requiring importers to report embedded emissions but without any financial liability attached. That grace period ended on 31 December 2025. From 1 January 2026, the definitive regime is in force — meaning real certificates, real costs, and real compliance obligations.
The CBAM Omnibus Regulation (EU 2025/2083), adopted on 8 October 2025 and entering into force on 20 October 2025, amends the original CBAM Regulation to streamline this transition. The EU’s intent is clear: simplify where possible, but maintain the environmental ambition of the mechanism.
The New De Minimis Threshold: A Major Win for SMEs
One of the most significant changes introduced by the CBAM Omnibus rule is the replacement of the old €150 per-consignment value exemption with a new mass-based de minimis threshold.
Under the new rules, importers who bring in 50 tonnes or less of CBAM-covered goods per year are completely free from all CBAM requirements. This includes not having to report, get authorizations, or buy certificates. This change is expected to reduce the compliance load for about 182,000 importers, most of whom are small and medium-sized businesses and individual traders.
Critically, this exemption does not apply to hydrogen or electricity, where all imports remain covered regardless of volume. The European Commission also retains the right to recalibrate this threshold through annual reviews if emission intensities or trade patterns change significantly.
For businesses hovering near the 50-tonne boundary, careful annual monitoring of import volumes will be essential. If your imports are projected to exceed the threshold in any given year, you must register as an authorised CBAM declarant — and failure to do so before exceeding the limit can result in penalties.
Delayed Timelines: Breathing Room, But Not Forever
The CBAM Omnibus regulation also introduced what some have referred to as a “stop the clock” measure — a series of postponed deadlines that give importers more time to prepare their systems and processes.
Key changes to the timeline include:
- Certificate surrender postponed to 2027. The original obligation to surrender CBAM certificates starting 1 January 2026 has been pushed back. Declarants will now acquire and surrender certificates in 2027, covering embedded emissions from 2026 imports. This means there are no certificate purchases required during 2026 itself, though the financial obligations apply retroactively for all 2026 imports.
- Annual declaration deadline extended. The deadline for submitting the annual CBAM declaration has moved from 31 May to 30 September of the year following importation. The first declaration — covering 2026 imports — is due by 30 September 2027, with certificates surrendered by that same date. Repayment requests and certificate cancellations are correspondingly deferred to 1 November.
- Quarterly holding requirement reduced. For importers who do have certificate obligations, the previous rule required holding certificates equivalent to 80% of embedded emissions at the end of each quarter. Under the CBAM Omnibus rule, this has been reduced to 50%, providing meaningful relief on cash flow and financial planning.
These changes offer breathing room, but they do not reduce the underlying liability. Importers who delay preparation risk finding themselves unable to meet the 2027 deadlines.
Registration Rules: Who Must Apply — and When
From 2026 onward, only authorized CBAM declarants will be permitted to import CBAM-covered goods that surpass the annual threshold of 50 tonnes. To obtain authorized declarant status, an application must be submitted to the appropriate National Competent Authority (NCA) in the EU country where the importer is established.
The CBAM Omnibus regulation introduced a transitional relief measure: if an authorisation request is submitted by 31 March 2026, imports may continue while the application is pending. This prevents disruption to supply chains in the critical early months of the definitive regime. However, importers of electricity and hydrogen — which carry no mass-based threshold — should seek specific guidance from their NCA, as it is not fully clear whether this transitional rule applies to them equally.
Indirect customs representatives importing CBAM goods are also subject to the authorisation requirement. Given the complexity of these arrangements, businesses using indirect representation models should urgently review their exposure and confirm their registration obligations.
Simplified Emissions Reporting and Verification
The CBAM Omnibus also brings important changes to how emissions are calculated and verified — changes that reduce burden without weakening the accuracy of the system.
- Default values and simplified calculations. Where actual emissions data from a third-country producer cannot be established — for example, in countries without robust carbon monitoring infrastructure — default emissions values may be used. These defaults are based on the highest recorded emission intensity or regional benchmarks, making compliance viable even where supplier data is limited.
- Verification simplified. Under the revised rules, only actual emissions data used in a CBAM declaration needs to be verified by an accredited third-party verifier. Default values may be applied without requiring separate verification, reducing the cost and time burden of compliance for importers relying on these figures.
- Downstream producers exempted from on-site measurement. Aluminium and steel producers with thermal input capacity below 20 MW are no longer required to measure on-site emissions directly. Instead, they must allocate emissions from upstream precursors — a significant practical simplification for smaller processing operations.
- Accredited verifiers gain registry access. The CBAM Omnibus allows accredited verifiers direct access to the CBAM Registry to submit, review, and revise verification reports. This streamlines the reporting chain and reduces friction between importers, verifiers, and competent authorities.
Carbon Price Deductions: More Flexibility for Third-Country Producers
The CBAM Omnibus rule introduces greater flexibility in how carbon costs already paid in non-EU countries are accounted for.
Importers can now deduct carbon prices paid in third countries other than the country of origin of the imported goods — provided evidence can be furnished. This is particularly relevant for complex global supply chains where a precursor good is produced in one country, processed in a second, and then exported to the EU from a third.
From 2027, the European Commission will publish default carbon prices and related calculation methodologies in the CBAM Registry for third countries where carbon pricing mechanisms are in place but where an actual paid price cannot be confirmed. This will provide businesses with reliable reference figures and reduce the risk of compliance errors stemming from data gaps.
What Should Importers Do Now?
The CBAM Omnibus rule makes compliance easier at the margins, but it doesn’t alter the essential fact: CBAM is now an active financial mechanism for imports in 2026, with certificate costs solidifying in 2027. For most importers exceeding the 50-tonne threshold, the following actions are urgent:
- Confirm your threshold position. Review 2025 import data and forecast 2026 volumes to determine whether you fall below or above the 50-tonne annual threshold for each CBAM-covered product category.
- Apply for authorised declarant status immediately. If your import volumes exceed the threshold, submit your NCA application well before 31 March 2026 to benefit from the transitional continuity rule.
- Engage your supply chain. Non-EU suppliers will need to provide embedded emissions data. The quality of this data will directly affect your CBAM certificate obligations. Begin those conversations now.
- Assess financial exposure. The cost of CBAM certificates is tied to EU ETS allowance prices, which have historically been volatile. Build this cost into pricing models, procurement decisions, and financial forecasts for 2026 and beyond.
- Invest in data infrastructure. Companies that built robust emissions data collection and reporting systems during the transitional phase are now best positioned. If you haven’t started, every month of delay increases risk.
The CBAM Omnibus is not the end of CBAM’s evolution. The European Commission has indicated that further legislative proposals may extend CBAM’s scope to downstream products — for example, finished steel and aluminium goods — potentially as early as 2028. Anti-circumvention measures are also under development, and annual reviews of the de minimis threshold mean the 50-tonne exemption is not guaranteed indefinitely.
CBAM is moving from just being a reporting task to becoming an important trade policy tool with real financial impact. The CBAM Omnibus rule provides some extra time and cuts down on paperwork, but it doesn’t lower the goals. Importers who take this as a chance to ease up will be caught off guard. Those who take this time to set up systems, build supplier relationships, and gain the knowledge needed for full compliance will be much better prepared as the rules get stricter until 2035.
Frequently Asked Questions
What is the CBAM Omnibus, and when did it come into effect?
The CBAM Omnibus, Regulation (EU) 2025/2083, amends the original CBAM Regulation (EU) 2023/956. Adopted on 8 October 2025 and effective from 20 October 2025, it simplifies processes with a new de minimis threshold, delayed timelines, and streamlined verification rules to ease the administrative burden for importers as CBAM transitions to its final phase starting 1 January 2026.
Who is exempt from CBAM obligations under the new Omnibus rules?
Under the CBAM Omnibus rule, importers of 50 tonnes or less of certain goods, like iron and steel, are exempt from CBAM obligations. However, this does not apply to hydrogen or electricity, which require full compliance from all importers.
Do I need to purchase CBAM certificates in 2026?
Under the CBAM Omnibus regulation, the obligation to purchase and surrender certificates has been delayed. Importers won’t need to do this in 2026, but financial liability starts retroactively from January 1, 2026. Certificates for 2026 imports must be bought and surrendered by September 30, 2027, so importers should prepare financially for this cost now.
What happens if I exceed the 50-tonne threshold without registering as an authorised CBAM declarant?
Importing CBAM-covered goods over 50 tonnes without authorized declarant status breaches CBAM rules and may incur penalties. The CBAM Omnibus offers transitional relief; applying for authorization to your National Competent Authority (NCA) by March 31, 2026, allows continued importing during application review. After this date, unregistered importers may face enforcement. It’s recommended to apply early to avoid disruptions in import activities.
Will CBAM expand beyond its current sectors in the future?
The European Commission plans to extend the Carbon Border Adjustment Mechanism (CBAM) to downstream products like processed steel and aluminum by 2028. Anti-circumvention measures are in development, and the de minimis threshold will be reviewed annually, potentially adjusting the 50-tonne limit based on trade patterns or emissions. Businesses should stay updated on legislative changes and develop adaptable compliance frameworks.
