UK CBAM Regulatory Tracker

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 list of approved verifiers. HMRC has confirmed in writing (16 October 2026) that it has no current plans to publish a list of accredited verifiers, so vetting a specific provider means checking its accreditation with the accreditation body. Further guidance on monitoring, reporting and verification is due in Autumn 2026.

HMRC's policy summary (updated 16 October 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. From Q3 2028 the window is the standard two months. HMRC has confirmed in writing (16 October 2026) that SI 2026/830 regs 1(3) and 2(3)–(4) amend the accounting and returns periods between 1 January 2027 and 30 June 2028; from 1 July 2028 the periods are those in Part 3 of Schedule 17 (quarters ending March, June, September and December, with returns due within two months of period end).

Yes, on 16 October 2026. HMRC published default values by CN code for each of the five sectors: iron and steel (478 codes, from 0.494 to 9.121 tCO₂e per tonne), aluminium (58 codes, 2.030 to 6.023), fertilisers (27 codes, 0.457 to 3.247), cement (6 codes, 0.240 to 2.075) and hydrogen (one code, 28.378). The values apply to each CBAM good regardless of origin, and HMRC says they replicate the Force of Law notice and must be used if you are not reporting actual verified emissions. A return that uses defaults cannot later be amended with actual data, and actual data cannot be used for a precursor with a default for the final good. By design, a default cannot offer an advantage over verified data, including the advantage of not paying to verify. HMRC has said in writing (16 October 2026) that it is considering the feasibility of an alternative approach to calculating default values and will set out any future methodology when it publishes the values. HMRC's written statement to Parliament (16 October 2026) adds how the values are built: single product-level values calculated on a trade-weighted average basis with EU data excluded, plus a 10% mark-up in every sector except fertiliser, where there is none. The values apply for 2027 and 2028; HMRC has committed to country-specific defaults from 2029, when the level of mark-up will also be reviewed. The statement describes a UK–EU commitment to link emissions trading schemes that "will result in EU-origin goods being exempt from UK CBAM"; it gives no date, so treat any EU-origin exemption as not yet in force.

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.

Made law: the CBAM (Transitory Provision) Regulations 2026 (SI 2026/830) were made 14 July 2026, in force 1 January 2027. Anyone who triggers registration during 2027 has until 31 January 2028 to register, rather than the standard 30-day window (reg. 2(2)). 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 →. HMRC has confirmed in writing (16 October 2026) that the registration service opens on 1 January 2028 and that there are no plans for an interim registration route. SI 2026/830 regs 1(2) and 2(2) extend the registration deadline to 31 January 2028 for anyone who triggers registration in 2027.

Made law as SI 2026/995 on 8 September 2026, laid 9 September, in force 1 January 2027. Sets out the 8-step actual-emissions methodology (reg. 5), GWP factors (N₂O ×265, CF₄ ×6,630, C₂F₆ ×11,100 — reg. 8), monitoring periods (reg. 9), verifier independence and accreditation requirements (regs. 12, 15), and 6-year record retention (reg. 16). One change from the April draft worth flagging directly: reg. 9(2)'s monitoring-period fallback is now more generous than drafted — for goods imported before 1 January 2028, you may use the most recent of the import year's own verified data or the preceding calendar year's, not just the import year alone. Given final verification of a full calendar year's data can't complete until after that year ends, this makes already-verifiable prior-year data usable as a real fallback for 2027 imports. Part 5 of the same instrument also amends SI 2026/802 (reg. 17) to add the default value used, or the verified emissions intensity, to what must be reported on a return — closing a gap the administrative regulations had left to a future HMRC notice.

Made law as SI 2026/802 on 13 July 2026, in force 1 January 2027. Covers registration particulars (reg. 7 in the made numbering — EORI, VAT number, trigger date, value of goods, estimated 12-month sector weight), return contents on 8-digit commodity codes (reg. 10), a new record-keeping duty on place-of-origin evidence (reg. 11), reimbursement, and 6-year record retention. The return-contents list was originally shorter than the February draft — explicit per-good emissions detail wasn't listed — but this has since been closed: SI 2026/995 (made 8 September 2026, reg. 17) amends reg. 10(1) to add the default value used, or the verified emissions intensity, plus a flag for certain precursor-good cases. Renumbering vs the February draft: registration particulars moved from reg. 2 to reg. 7; return contents from reg. 6 to reg. 10; Schedule 16 (Bill numbering) is Schedule 17 (enacted).

Yes. Made law as SI 2026/809 on 13 July 2026, laid 14 July, in force 1 January 2027. Because they were made under the made affirmative procedure, they would have ceased to have effect unless the House of Commons approved them within 28 days (not counting recesses or adjournments of more than four days). A Delegated Legislation Committee debated them on 12 October 2026 and the Commons approved them on 14 October 2026. Approval did not change the rules. The regulations set the two rate inputs — the previous quarter's average UK ETS auction clearing price (reg. 3), adjusted for sector free allocation (reg. 4) — and the conditions for Carbon Price Relief, including verification and record-keeping. Illustrative sector rates were published on 16 October 2026; the final rates for Q1 2027 are not yet published. Default emission values were published the same day (see the default-values card).

No. This is blocked outright, in force since commencement. General error correction remains available as a separate, narrower power: HMRC's policy summary (updated 16 October 2026) says an amendment to correct an error must be made within 3 years of the end of the accounting period, and overpayments are repayable only where paid within 3 years of the claim. See our full breakdown of this myth →. HMRC has confirmed in writing (16 October 2026) that using default values is not an error for the purposes of paragraph 8(1), so it falls outside the permitted corrections; errors that are corrigible should be corrected as soon as possible.

HMRC's confirmed list of Qualifying Carbon Pricing Schemes, announced 27 August 2026 (based on information as of 19 June 2026), names sixteen schemes: Australia's Safeguard Mechanism, Canada's Federal OBPS, Chile's Carbon Tax, China's National ETS, the EU ETS, India's CCTS, Japan's GX-ETS, Kazakhstan's ETS, South Korea's K-ETS, Montenegro's ETS, New Zealand's ETS, Serbia's Carbon Tax, Singapore's Carbon Tax, South Africa's Carbon Tax, the Swiss ETS, and Taiwan's Carbon Fee. Turkey's TR-ETS is notably absent from this list — as of the published version, it does not currently meet HMRC's qualifying criteria, a more fundamental gap than a free-allocation problem. The list is explicitly non-exhaustive and under active review; HMRC has committed to adding schemes that meet the criteria, including ones still in development, via a published submission route. Qualifying on the list is still not the same as receiving meaningful relief: China and South Korea both allocate close to 100% of allowances free to steel as a carbon-leakage sector, so the effective price actually paid — and therefore the relief available — can remain close to zero even though both schemes are confirmed to qualify. India's CCTS also qualifies but has no confirmed £/tCO₂e price yet. See our full breakdown of this myth →. HMRC has confirmed in writing (16 October 2026) that the list is not exhaustive and is kept under review. Importers can assess for themselves whether a scheme qualifies, and may send details of a scheme they think qualifies but is not listed to cbampolicyteam@hmrc.gov.uk; the government says it is committed to adding schemes that meet the criteria.

No — UK CBAM covers direct (Scope 1) emissions only from January 2027. HMRC's policy summary (updated 16 October 2026) says the CBAM charge is based on the direct emissions embodied in the goods. Reports that indirect emissions will be brought in from 2029 at the earliest come from a secondary source and are not in HMRC's published guidance. We track this line for any change announcement.

Made law as SI 2026/994 on 8 September 2026, in force 1 January 2027. This is a commencement order, not a bespoke CBAM interest regime — it simply switches on the UK's existing general tax interest framework (Finance Act 2009, ss.101–102) for CBAM specifically: late payment interest on sums owed to HMRC, and repayment interest on sums HMRC owes back, including in relation to any CBAM penalties assessed. No CBAM-specific interest rate or mechanism exists separately from this.

No final sector CBAM rate has been published yet. On 16 October 2026 HMRC published illustrative rates, calculated on current data and expressly not forecasts: iron and steel £9.69/tCO₂e, aluminium £9.79, cement £8.78, fertiliser £1.45, hydrogen £9.24. The method: the previous quarter's average UK ETS auction price (£58.15 for July–September 2026 in HMRC's worked example) × [1 − (baseline free allocation percentage × free allowance phase-out reduction factor)]. The 2027 reduction factor is 97.5% for all five sectors. Each quarter's rate rests on the previous quarter's auction prices, so the rate for Q1 2027 imports will use Q4 2026 auctions. HMRC says the rates for 1 January–31 March 2027 will be published before the end of 2026 and updated quarterly. The baseline data is still being checked by the UK ETS Authority and may change. The £55/tCO₂e figure used in many planning tools is a UK ETS price proxy, not a CBAM rate — sector rates are far lower because free allocation is deducted. HMRC has confirmed in writing (16 October 2026) that rates are published at the start of each quarter and are based on the average UK ETS auction price from the preceding quarter, adjusted for free allocation, so they can move up or down. HMRC suggests businesses monitor the fortnightly UK ETS auctions when planning contracts.

HMRC's commodity-code annex, as updated on 16 October 2026, now lists ‘7202 2 — Ferro-silicon’ as an exception, which takes in 7202 29 as well as 7202 21. Until now the enacted Schedule 16 exceptions named only 7202 21, which HMRC had acknowledged as a drafting error. We have not yet found the legal instrument that makes this correction, so treat the exclusion as HMRC's stated position, not yet confirmed in law, and check the code before relying on it. HMRC has confirmed in writing (16 October 2026) that the policy intention is for ferro-silicon to be excluded, that it is aware of the discrepancy between that intention and the enacted drafting (7202 21 only), that it intends to address this as soon as possible, and that it expects ferro-silicon including 7202 29 to be excluded as a result. The correcting instrument has not yet been identified.