The road to the 2027 declaration

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A compliance lead who has been tracking CBAM verifier news assumes the September 2026 Registry opening is the main event, then realises it is only the beginning of a longer sequence leading toward a deadline that actually carries financial consequences.
With Registry access now open, the practical countdown to the 2027 declaration has effectively started, even though the deadline itself is still more than a year away.
This article walks through what happens next, step by step, from Registry access toward the deadline that matters most.
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As of September 2026, accredited verifiers can register in the CBAM Registry, with working access following shortly after. This is an enabling step: it allows verifiers to begin the administrative process of connecting with declarants, not a compliance deadline in its own right.
The obligation now shifts to what happens between verifiers and declarants over the following months. Registry access alone does not produce a verified emissions report, purchase a certificate, or satisfy a declaration requirement. It simply opens the door for the next stage of the process to begin, which is where the real work of CBAM compliance actually happens.
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Once registered, accredited verifiers begin engaging directly with declarants and the installations producing their goods, reviewing emissions data and preparing to issue formal verification opinions. This stage is where verifiers translate their Registry access into actual compliance work.
Verification reports are expected to begin appearing in the CBAM Registry from around January 2027, once verifiers are fully operational. This is the point at which declarants can rely on verified, rather than default, emissions values for their eventual declaration.
CBAM certificate sales open on February 1, 2027, giving declarants a working window of several months to purchase certificates ahead of the deadline, rather than needing to do so at the last minute in September.
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Given that verifier accreditation and registration is still a maturing process, compliance teams should start conversations with prospective verifiers now rather than waiting until 2027, when demand is likely to be higher.
Verified emissions data cannot be produced overnight. Preparing plant-level data now, well ahead of engaging a verifier, avoids a scramble as the declaration deadline approaches.
Treat the declaration deadline as the final checkpoint in a longer process, not the point at which preparation begins. A buffer of several months before the deadline allows time to resolve any gaps in verified data or certificate holdings.
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The real work of CBAM compliance happens in the months between Registry access and the declaration deadline, not at either endpoint alone.
From Registry access, to verifier accreditation, to the 2027 deadline, the pieces are now in motion, and the teams that use this window well will find September 30, 2027 far less stressful than those who wait.
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Verifiers move from registration to actively working with declarants, reviewing emissions data and preparing to issue verification reports.
The next major date is February 1, 2027, when CBAM certificate sales open, followed by the September 30, 2027 declaration deadline.
From February 1, 2027, through the EU's common central platform.
Verification reports are expected to begin appearing in the Registry from around January 2027.
About a year, from Registry access opening in September 2026 to the declaration deadline on September 30, 2027.
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