Introduction

The Carbon Border Adjustment Mechanism enters a definitive period in 2026. What began as a transitional reporting exercise now operates as an enforceable regulatory regime with financial consequences. As the first full CBAM year begins, EU authorities and national customs bodies have circulated new reminders, clarifications, and operational guidance aimed directly at importers. These communications remove much of the remaining ambiguity around expectations for emissions data, verification, documentation, and penalties.

For companies importing CBAM covered goods into the European Union, this shift marks a change in risk profile. CBAM compliance now functions as a customs and financial exposure that directly affects import operations and costs. This article explains what changed in 2026, why enforcement matters now, and how importers should adapt their compliance approach.

What Changed in CBAM Enforcement in 2026

The most important change in 2026 is the transition from a learning phase to active enforcement. During the transitional period, authorities emphasized familiarization, data collection, and system testing. In 2026, customs authorities are applying the rules as written.

Key changes include clearer expectations around verification, documentation, and accuracy. Importers are expected to submit complete and credible emissions data for covered goods, supported by evidence that can withstand inspection. Authorities have clarified that estimates and placeholders that were tolerated earlier are no longer sufficient when primary data is reasonably available.

Member state customs notices have reinforced that CBAM declarations are now treated as formal regulatory submissions. In practice, this means that misreporting, underreporting, or inconsistencies between customs data and CBAM reports can trigger penalties. The guidance circulated across France, Germany, and the Netherlands signals a common enforcement direction even if national procedures differ.

Area	Transitional Phase	2026 Enforcement Phase
Reporting	Quarterly CBAM reports required by regulation	Annual declaration and certificate surrender
Emissions data	Estimates and default values permitted	Methodology compliant data subject to authority verification
Documentation	Limited review	Inspection ready documentation
Penalties	Corrective feedback without financial penalties	Financial penalties applied

Why CBAM Enforcement Now Creates Real Financial Exposure

CBAM enforcement in 2026 introduces direct financial risk for importers. Penalties can apply not only for failure to report, but also for incorrect or incomplete reporting. This includes errors in embedded emissions calculations, missing supporting documentation, or discrepancies between customs declarations and CBAM submissions.

The financial exposure is amplified by the structure of CBAM itself. Embedded emissions determine the number of CBAM certificates required. Inaccurate data can therefore result in both penalties and higher compliance costs once certificates are purchased. For importers operating on thin margins, this risk is material.

CBAM enforcement also expands the scope of internal stakeholders affected. Compliance teams are no longer the sole owners of CBAM risk. Procurement decisions, supplier selection, contract terms, and data governance now influence regulatory outcomes. CBAM has become part of trade compliance and financial planning rather than a purely environmental reporting obligation.

Step	Description	Risk Impact
Supplier data	Emissions data collected	Incomplete or estimated data
CBAM report	Data submitted to authority	Misreporting risk
Verification	Authority review or inspection	Penalties triggered
Cost outcome	Certificates and fines	Higher total CBAM cost

What Importers Must Do Differently in 2026

To manage CBAM enforcement risk, importers must upgrade their approach across four areas.

First, emissions data verification must improve. Importers should understand when third party verification is required, what methodologies are acceptable, and how to document assumptions. Data requests to suppliers should be standardized and traceable.

Second, documentation readiness is essential. Importers should be able to demonstrate how embedded emissions were calculated, which data sources were used, and how data aligns with customs declarations. This documentation must be available during inspections, not recreated after the fact.

Third, internal controls should be strengthened. CBAM reporting should be integrated with customs, finance, and procurement systems. Clear ownership, review processes, and escalation paths reduce the risk of inconsistent submissions.

Fourth, supplier engagement must become more structured. Contracts may need to include data sharing obligations, audit rights, and consequences for non cooperation. Suppliers that cannot provide credible emissions data introduce compliance risk.

Area	Key Actions
Data	Collect primary emissions data where possible
Verification	Align with accepted methodologies
Documentation	Prepare inspection ready records
Systems	Integrate CBAM with customs processes
Suppliers	Formalize data obligations

Conclusion

CBAM in 2026 represents a clear shift from preparation to enforcement. Guidance issued by EU authorities and member state customs bodies confirms that expectations are now operational and penalties are real. Importers that continue to treat CBAM as a reporting exercise risk financial and regulatory consequences.

The companies best positioned for this phase are those that invest in data quality, verification, and internal coordination. CBAM enforcement rewards preparation and transparency while penalizing assumptions and delays. As enforcement matures, CBAM will increasingly resemble other core trade compliance obligations.

To continue the discussion, do not miss our upcoming webinar with our partner CBAMBOO. The session will cover why CBAM has become a priority for global manufacturers, how moving from estimates to primary and site level data reduces cost and risk, and how product carbon footprints and site data form the foundation of compliant reporting. We will also address how importers and exporters can coordinate to manage certificate costs, avoid overreliance on default values, and apply a practical compliance checklist that strengthens supply chain resilience as enforcement accelerates.

Why Work with ASUENE Inc.?

ASUENE is a key player in carbon accounting, offering a comprehensive platform that measures, reduces, and reports emissions. The company serves over 10,000 clients worldwide with an all-in-one solution that integrates GHG accounting, ESG supply chain management, a Carbon Credit exchange platform, and third-party verification.

ASUENE can support companies at every stage of CBAM reporting, from emissions data collection and supplier engagement to documentation readiness and ongoing compliance management.