The European Commission has launched a public consultation on a draft implementing regulation under Regulation (EU) 2023/956, establishing detailed rules governing the sale and repurchase of Carbon Border Adjustment Mechanism (CBAM) certificates, the operation of the common central platform, applicable fees and the interaction between the platform and the CBAM Registry.
Beginning in February 2027, authorized CBAM declarants will purchase CBAM certificates through a common central platform managed by the European Commission in cooperation with the member states under an agreement that entered into force on December 16, 2025.
CBAM Registry and common central platform to have separate functions
Under the draft regulation, the CBAM Registry and the common central platform will perform separate functions.
The CBAM Registry will serve as the electronic system for submitting CBAM declarations and managing the issuance, holding, surrender and cancellation of CBAM certificates.
The common central platform will be responsible exclusively for financial transactions related to the purchase and repurchase of CBAM certificates, including payment processing and settlement. According to the Commission, this separation is intended to improve operational efficiency, strengthen digital security and reduce unnecessary data exposure.
Member states to sell certificates without quantitative limits
Member states will sell and repurchase CBAM certificates solely through their designated competent authorities.
Unlike the EU Emissions Trading System (EU ETS), the CBAM will not function as a cap-and-trade system. Consequently, there will be no limit on the number of certificates member states may sell, and they will not be permitted to delay or restrict sales. Each certificate will be assigned exclusively to the purchasing declarant, carry a unique identification number and will not be transferable or tradable.
Draft regulation sets purchase and repurchase procedures
To purchase CBAM certificates, authorized declarants must submit a purchase request through the CBAM Registry specifying between 1 and 99,999 certificates, together with the applicable certificate price, fees and total payment amount. Each request will receive a unique identification number and cannot be amended after submission, although it may be withdrawn before payment is completed. Certificates will only be created in the declarant’s CBAM account after the common central platform confirms receipt of payment.
Authorized CBAM declarants will generally be permitted to submit one repurchase request per year, except where requests arise following a review of CBAM declarations. Repurchase requests cannot be amended or withdrawn after submission and will only be accepted if the declarant has complied with the annual surrender obligation by September 30 or qualifies for the exemption provided under Regulation (EU) 2023/956. Competent authorities must approve eligible repurchase requests within 42 calendar days following April 1, July 1 or November 1, subject to the availability of sufficient funds.
Euro-only payments and €0.05 certificate fee proposed
All purchase and repurchase payments must be made exclusively in euro. Payments received for certificate purchases must be transferred to the relevant member state by the end of the same calendar day, while repurchase payments must be transferred in cleared funds to the declarant’s nominated bank account. The exclusive use of the euro is intended to eliminate exchange-rate risks and ensure consistency between the CBAM Registry and the common central platform.
The operation of the common central platform will be financed through fees paid by authorized CBAM declarants. A fixed fee of €0.05 per CBAM certificate sold will apply regardless of the certificate price or the member state involved. The fee will be collected at the time of purchase and, during the initial procurement contract, transferred monthly to the European Commission. No additional fees or charges may be imposed on the purchase or repurchase of CBAM certificates.
Reporting, data retention and legal remedies defined
Information relating to purchases, repurchases, payment status and member state identification must be exchanged through a secure electronic interface in a reliable and near-immediate manner. The common central platform will submit daily reconciliation reports, monthly operational reports, monthly fee management reports and annual activity reports to the Commission. Competent authorities must designate the bank accounts used for certificate sales and repurchases, while transaction data may only be retained for five years following the calendar year in which it was recorded.
Finally, decisions concerning the purchase or repurchase of CBAM certificates may be challenged before national courts in the member state where the authorized CBAM declarant is established. The common central platform will also be required to establish an extra-judicial complaints mechanism.
The regulation is scheduled to enter into force on the third day following its publication in the Official Journal of the European Union and will apply from February 1, 2027.