All importers that exceed, or expect their imports of CBAM goods to exceed, 50 tonnes per year must obtain the status of authorised CBAM declarant. From 31 March 2026, imports of CBAM goods without this status will simply no longer be possible. The status of authorised CBAM declarant is also essential for meeting all CBAM obligations.
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Internal organisation of CBAM matters
The CBAM mechanism provides for oversight of all importers bringing CBAM goods into the EU. The status of authorised CBAM declarant may be obtained only by importers that demonstrate that they (1) have control over the implementation of CBAM obligations and (2) have sufficient financial resources to pay for the appropriate number of CBAM certificates. Based on the information submitted by the importer, the competent authority (in Slovenia, the Financial Administration of the Republic of Slovenia (FURS), specifically the Kranj Financial Office) verifies whether the importer meets the conditions for obtaining the status. It is essential that the importer attach to the application an internal policy explaining in greater detail how CBAM matters are organised internally. In particular, the policy should describe the internal procedures and the persons responsible for CBAM matters. The form and content of the internal policy are not prescribed.
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Appointment of persons responsible for CBAM matters
In the application for the status of authorised CBAM declarant, the importer names at least three persons responsible for CBAM matters, namely:
- the company’s legal representative (director),
- the employee responsible for carrying out CBAM-related tasks, and
- the employee’s deputy, who takes over CBAM tasks in the employee’s absence.
For each responsible person, the following information must be provided: full name, address, tax identification number, contact telephone number and email address.
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Declaration regarding infringements of customs or other legislation
The status of authorised CBAM declarant may be obtained only by an importer that, during the five years preceding the year in which the application for the status is submitted, has not been involved in any serious or repeated infringements of customs legislation, tax rules or market abuse rules, and has not committed any criminal offences relating to its economic activity.
The importer attaches to the application a declaration in which the persons responsible for CBAM matters confirm that they have not been involved in any of the infringements listed above.
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Data on the expected type, quantity and value of imported CBAM goods
The application for the status also includes the importer’s estimate of the type, quantity and value of CBAM goods to be imported in the current and following calendar year. This estimate is prepared by the importer based on previous imports of CBAM goods.
- Importer’s financial information
The importer’s financial information also forms part of the application for the status. The importer provides data from its last three annual reports, including information on:
- net profit,
- net sales revenue,
- total assets, and
- total liabilities excluding equity.
Importers that have been operating for less than two years must provide a bank guarantee to secure their CBAM obligations.
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Assignment of a CBAM account number in the CBAM registry
FURS usually processes complete applications for the status of authorised CBAM declarant within two to three weeks of submission. The importer’s contact person is notified by email when the status has been granted. The importer proves the validity of the status of authorised CBAM declarant by means of a CBAM account number with the following structure: CBAM – country abbreviation – year in which the status was obtained – a 14-character combination of numbers and letters. The CBAM account certificate is available in the CBAM registry under “My authorisations”.
An external expert can also handle the process of obtaining the status of authorised CBAM declarant for you
Obtaining the status of authorised CBAM declarant requires a considerable amount of your employees’ time and effort, so it may be easier to entrust this task to external CBAM experts. ANOVA, our team of CBAM experts, will be happy to assist you. Write to us at info@anova.si or call us on +386 30 730 505.
Article prepared by: Mojca Müller, Certified tax expert
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