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What is still not finalised, CBAM 2026

CBAM implementation in 2026 is currently based on Regulation (EU) 2023/956 and the implementing acts already adopted. Further regulatory clarifications have been announced by the European Commission, but no specific publication dates have been formally indicated.

Despite the CBAM legal framework being in force for 2026, several operational elements remain unresolved and require additional implementing acts by the European Commission.

At this stage, the Commission has not published final default emission values to be applied under the definitive CBAM regime where verified data is unavailable. These values are expected to be updated through implementing acts; however, their final levels and sectoral differentiation have not yet been formally confirmed.

Further technical guidance remains pending, particularly regarding verification rules for embedded emissions, acceptable documentation to demonstrate carbon prices paid outside the EU, and the operational alignment between customs declarations and CBAM reporting.

At the same time, no extension of CBAM to additional product categories has been formally adopted for 2026. Any potential expansion remains subject to future legislative initiatives and does not apply under the current legal framework.