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UK CBAM Regulatory Tracker

Every item verified against primary legislation — not commentary, not a competitor's summary, not a prior draft. This is the page to check before you check gov.uk.

Page last reviewed: 16 July 2026. Sources: Finance Act 2026 c.11 (enacted); HMRC CBAM guidance batch published 16 July 2026 (gov.uk) — Policy paper CBAM; Get a carbon pricing verification form; What you need to work out Carbon Price Relief; Check if your goods have been subject to a qualifying carbon pricing scheme; Work out the date you'll need to register; Force of Law Notice (draft); System Boundaries Document v1; draft CBAM (Administrative Provisions) Regulations 2026.
5 confirmed 5 draft 1 pending
In force
Has HMRC published the UK CBAM verifier accreditation standards?
CONFIRMED
Yes. HMRC guidance published 16 July 2026 confirms the full accreditation standards a verifier must meet: accredited by a body that is a full member of Global Accreditation Cooperation Incorporated (GACI), a signatory to the GACI Multilateral Recognition Agreement, and independent of the installation, the importer, and the jurisdiction of the qualifying carbon pricing scheme. The verifier must also be accredited to ISO/IEC 17029:2019, ISO 14064-3:2019, ISO 14065:2020, and ISO 14066:2023. Note: this confirms the qualifying standards, not a curated named list of individually approved verifiers — that distinction still matters when vetting a specific provider.
Source: HMRC guidance, “Get a carbon pricing verification form” (gov.uk, published 16 July 2026), verbatim: verifier must be “accredited by an accreditation body which is a full member of the Global Accreditation Cooperation Incorporated” and “a signatory to the Global Accreditation Cooperation Multilateral Recognition Agreement”, accredited to ISO/IEC 17029:2019, ISO 14064-3:2019, ISO 14065:2020, and ISO 14066:2023. GACI requirement also confirmed in draft CBAM (Emissions and Verification) Regulations 2026, Reg. 13(1)(a).
Last checked: 16 Jul 2026 Status since: 16 Jul 2026
What are the 2028 transitional accounting periods and deadlines?
CONFIRMED
HMRC's Policy Paper (published 16 July 2026) confirms the full transitional table. First accounting period: 1 January–31 December 2027, return and payment due 31 May 2028. From 1 January 2028, periods move to a quarterly cycle with a gradually narrowing return/payment window: Q1 2028 (Jan–Mar) due 31 July 2028; Q2 2028 (Apr–Jun) due 29 September 2028; Q3 2028 (Jul–Sep) due 30 November 2028; Q4 2028 (Oct–Dec) due 28 February 2029. The window narrows to the standard 2-month cycle from 2029 onward.
Source: HMRC “Policy paper CBAM” (gov.uk, published 16 July 2026), Section 7 ‘Accounting periods, returns, payments and repayments’, Table 2, verbatim.
Last checked: 16 Jul 2026 Status since: 16 Jul 2026
What are the UK CBAM accounting periods and deadlines?
CONFIRMED
The statutory default is confirmed and in force: quarterly accounting periods ending March, June, September and December, with payment and returns due by the last working day of the second month after each period ends.
Statutory basis (verbatim): FA 2026 Sch 17 Part 3 para 6(2)–(3) sets the periods; para 7(2) sets the same deadline for returns.
DRAFT First-year transitional periods: The draft CBAM (Transitory Provision) Regulations 2026 (published 10 Feb 2026, verbatim confirmed) set three transitional periods before standard quarterly cycles resume: (1) 1 Jan–31 Dec 2027, return/payment due 31 May 2028; (2) 1 Jan–31 Mar 2028, due 31 July 2028; (3) 1 Apr–30 Jun 2028, due 29 Sept 2028. Standard quarterly periods resume from Q3 2028. Not yet made final.

Enabling power (enacted): FA 2026 s.158(2)(b) — verbatim: "The Treasury may by regulations modify the effect of ... paragraph 6(2) or (3) or 7(2) for the purposes of any accounting period in respect of CBAM falling in 2027 or 2028." (The draft instrument's own recital cites Bill-era "sections 154(1)(b) and 155(2) and (3)" — renumbered to s.158 at enactment.) Exercising instrument (verbatim confirmed): draft CBAM (Transitory Provision) Regulations 2026, reg. 2(3)–(4) (published 10 February 2026, not yet made).
Last checked: 12 Jul 2026 Status since: 18 Mar 2026
Can a filed return be amended to swap defaults for verified data?
CONFIRMED
No. This is blocked outright, in force since commencement. General error correction remains available as a separate, narrower power. See our full breakdown of this myth →.
Statutory basis (verbatim): FA 2026 Sch 17 Part 3 para 8(2): "No amendment may be made to replace information on the emissions embodied in CBAM goods determined using default values set under paragraph 11 with such information determined in accordance with regulations under paragraph 10." Para 8(1): a return may be amended "only in order to correct an error."
Last checked: 12 Jul 2026 Status since: 18 Mar 2026
Does UK CBAM cover indirect (Scope 2) emissions?
CONFIRMED
No — UK CBAM covers direct (Scope 1) emissions only from January 2027. Indirect emissions are excluded until 2029 at the earliest. We track this line for any change announcement.
Source: System Boundaries Document, cross-checked against FA 2026 Part 5 scope provisions.
Last checked: 12 Jul 2026 Status since: 18 Mar 2026
Draft — final version awaited
Have HMRC default emission values been confirmed?
DRAFT
Only draft/illustrative values exist, published in the April 2026 System Boundaries Document. No confirmed HMRC default emission values have been published. By design, any default eventually set cannot offer an advantage over verified data — including the advantage of simply not paying to verify.
Statutory basis for the no-advantage rule (verbatim): FA 2026 Sch 17 Part 4 para 11(3)–(4) — a default may be set so there is "not an advantage to any person liable to CBAM in using the value instead of determining the emissions... in accordance with regulations under paragraph 10"; "advantage" is defined to include "not bearing the cost of determining or verifying emissions."
Last checked: 12 Jul 2026 Status since: 1 Apr 2026
Is the 31 January 2028 registration easement confirmed?
DRAFT
Anyone who triggers registration during 2027 will have until 31 January 2028 to register, rather than the standard 30-day window — this is verbatim confirmed both in the enacted Act's own transitory-power provision (s.158(2)(a)) and in the draft regulation exercising it. The underlying rolling trigger — £50k trailing-12-month value, checked monthly, or a 30-day forward test — is confirmed verbatim in Schedule 17 Part 2 and always applies regardless: liability and record-keeping run from the trigger date, not from any easement date. See our full breakdown of this myth →.
Enabling power (enacted): FA 2026 s.158(2)(a) — verbatim: "The Treasury may by regulations modify the effect of ... paragraph 2(4) of Schedule 17 as regards any person who triggers registration in 2027 or 2028." (The draft instrument's own recital cites "sections 154(1)(b) and 155(2) and (3)" — this is pre-Royal-Assent Bill numbering that renumbered to s.158 at enactment; the same Bill-to-Act shift already identified for schedules also applies to sections.) Exercising instrument (verbatim confirmed): draft CBAM (Transitory Provision) Regulations 2026, reg. 2(2): '31st January 2028' is treated as substituted for the words from 'the period of 30 days' to the end (published 10 February 2026, not yet made). Rolling trigger, confirmed verbatim (Sch 17 Part 2 para 2(2)): £50k trailing-12-month test or 30-day forward test.
Last checked: 12 Jul 2026 Status since: 10 Feb 2026
CBAM (Emissions and Verification) Regulations 2026 — final or draft?
DRAFT
Draft, published April 2026 (post-Royal Assent). Sets out the 8-step actual-emissions methodology, GWP factors (N₂O ×265, CF₄ ×6,630, C₂F₆ ×11,100), verifier independence standards, and the GACI accreditation requirement. Not yet made in final form.
Source: draft CBAM (Emissions and Verification) Regulations 2026, published 9 April 2026.
Last checked: 12 Jul 2026 Status since: 9 Apr 2026
CBAM (Administrative Provisions) Regulations 2026 — final or draft?
DRAFT
Draft, published February 2026 — before Royal Assent (18 March 2026). Covers registration particulars (EORI, VAT number, trigger date, value of goods), return contents, valuation, weight, reimbursement, and record-keeping. Caution: this draft uses Finance Bill schedule numbering, one lower than the enacted Act — its "Schedule 16" corresponds to the enacted Schedule 17. Expect renumbering when the final SI is made.
Source: draft CBAM (Administrative Provisions) Regulations 2026, published 10 February 2026 (pre-Royal Assent numbering).
Last checked: 12 Jul 2026 Status since: 10 Feb 2026
Which overseas carbon pricing schemes qualify for Carbon Price Relief?
DRAFT
Draft rules exist but are not final: the CBAM (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026, published 10 February 2026, set out qualifying-scheme eligibility (mandatory at law, independently verified emissions data, GACI-accredited verifier) and the relief calculation formula (effective carbon price × emissions embodied), including adjustments for compensation or rebates received. Relief is capped at the CBAM liability itself — it cannot exceed 100% of what would otherwise be owed. No list of qualifying schemes has been confirmed. Note: a scheme qualifying on paper does not guarantee relief — relief is based on the carbon price actually paid, not the scheme's headline price. Current scheme structures in Turkey (TR-ETS pilot), China (CN-ETS), and South Korea (K-ETS) allocate close to 100% of allowances free to carbon-leakage sectors including steel, making the effective price paid close to zero. India's CCTS has no confirmed qualifying price. See our full breakdown of this myth →.
Statutory basis: FA 2026 s.150 (Carbon Price Relief power); Sch 17 Part 4 para 12 (determination/evidence regulation power). Draft rules (verbatim confirmed): draft CBAM (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026, reg. 6 (qualifying scheme test), reg. 12 (effective carbon price calculation), reg. 13(1) (relief formula), reg. 13(5) (capped at CBAM liability) (published 10 February 2026, not yet made).
Last checked: 12 Jul 2026 Status since: 10 Feb 2026
Awaited — nothing published yet
What's this quarter's UK CBAM rate?
PENDING
No sector-specific quarterly CBAM rate has been published. The rate is recalculated every quarter by statute, not fixed annually. HMRC's Policy Summary commits to publishing rates at the start of each quarter from 1 January 2027, with an illustrative example rate due in Autumn 2026 — we track for that. The £55/tCO₂e figure used in planning tools across the industry is a UK ETS-derived planning proxy — it is not a published HMRC rate and should never be treated as one.
Statutory basis (verbatim confirmed): FA 2026 s.149(1)–(3) — CBAM is charged at the "sectoral domestic price" × emissions embodied; the sectoral domestic price is defined per sector per quarter (s.149(2)(a)–(b)), and s.149(3) requires the Treasury to "calculate and publish the sectoral domestic price for each CBAM sector for each quarter." Rate calculation mechanics (verbatim confirmed): draft CBAM (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026, regs. 3–4 (average ETS price, free-allocation adjustment) (published 10 February 2026, in consultation). Illustrative rate timing: HMRC CBAM Policy Summary, April 2026.
Last checked: 12 Jul 2026 Status since: 12 Jul 2026
Changelog
12 Jul 2026 — Tracker launched. All citations verified verbatim against Finance Act 2026 Schedule 17, Parts 3 and 4, as enacted.
12 Jul 2026 — Independent source re-check (same day as launch): registration easement, first-year accounting modification, and Carbon Price Relief rules corrected from PENDING to DRAFT — the CBAM (Transitory Provision) Regulations 2026 and CBAM (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026 were published in draft on 10 February 2026 and exercise the relevant powers. Autumn 2026 illustrative CBAM rate milestone added.
16 Jul 2026 — Major update from real HMRC guidance batch published 16 July 2026 (not draft): verifier accreditation standards CONFIRMED (GACI full member + MRA signatory + ISO/IEC 17029:2019, ISO 14064-3:2019, ISO 14065:2020, ISO 14066:2023) — upgraded from PENDING to CONFIRMED. Registration easement (31 Jan 2028) and first return date (31 May 2028) independently reconfirmed in an official HMRC Policy Paper. New: full 2028 transitional quarterly deadline table added. CPR free-allocation-equals-zero-relief logic confirmed verbatim in HMRC guidance.

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