As of 2026, the CBAM mechanism will not only represent an additional administrative burden but may also have a significant impact on the operating costs of importers of CBAM goods. It is therefore primarily important for importers to assess the additional cost of importing CBAM goods and decide whether they will manage the CBAM area within the company or seek assistance from an external expert.

1. Status of authorised CBAM declarant

The first step is obtaining the status of an authorised CBAM declarant. The procedure begins by accessing the CBAM registry, where the importer completes the application, attaches the relevant internal act, and submits it to FURS. The status of an authorised CBAM declarant is a condition for importing CBAM goods and enables the fulfilment of all CBAM obligations within the CBAM registry.

2. Assessment of CBAM obligations

It is very important for importers to collect all data required to assess their future CBAM obligations as soon as possible. This is the only way to determine in time what additional financial burdens will arise from the import of CBAM goods. A timely cost assessment allows importers to appropriately adjust the sales prices of goods or services.

3. Calculation of emissions based on actual or default values

The importer must decide whether emissions will be calculated on the basis of actual or default values. If the importer decides to use actual data, they must obtain data on actual emissions from the producers of CBAM goods, which must be duly verified or confirmed by accredited verifiers. If data on actual emissions has not been verified, it cannot be used.

4. Purchase of CBAM certificates

The value of CBAM certificates will fluctuate, so it is important for the importer to assess in advance how many certificates they will need and when it would be reasonable to purchase them. The first purchases of CBAM certificates will be possible after 1 February 2027.

5. Annual CBAM declaration

The annual CBAM declaration should be prepared by a person who is familiar with CBAM legislation, understands the data required for reporting and monitors all changes in this area. This is the only way for the importer to ensure that obligations are fulfilled correctly, on time and without unnecessary complications. Importers will submit the first CBAM declaration (for 2026) no later than 30 September 2027.

You can also entrust your CBAM obligations to an external partner

If you wish to avoid an additional administrative burden and ensure that the CBAM area is handled professionally and on time, you can transfer all CBAM obligations to an external CBAM expert. At ANOVA, we can take over the entire CBAM management process for you – from monitoring imports and communicating with suppliers to purchasing CBAM certificates, preparing the annual CBAM declaration and providing support in the event of a possible inspection. For more information, please write to us at info@anova.si or call us on +386 30 730 505.

Article prepared by: Mojca Müller, Certified Tax Adviser at SIR