This week in CBAM: the 31 March deadline for authorised CBAM declarant applications enters its final days with a visible surge in last-minute registrations across the market, the UK CBAM technical consultation closed on 24 March confirming parallel compliance pressure ahead of its January 2027 start, and the first official CBAM certificate price publication on 7 April is set to mark the next major milestone as the mechanism shifts from a regulatory exercise to a financial planning issue.
1. Final Week Before 31 March: Last-Minute Rush for Authorised CBAM Declarant Applications
The 31 March 2026 deadline for applying for authorised CBAM declarant status has now entered its final stretch. For importers bringing in more than 50 tonnes of CBAM-covered goods per year, failure to submit an application in time could mean they are no longer permitted to import covered goods from 1 April 2026 under the definitive regime.1
Across the market, there is a clear surge in last-minute applications as businesses move to meet the deadline. This is in line with what many advisors and customs stakeholders are reporting: companies that delayed action are now being forced into accelerated compliance.1
Under the Commission's transitional arrangement, companies that submit their application before 31 March may continue importing while their application is under review, provided the correct customs codes are used. However, if an application is ultimately rejected, businesses remain exposed to retroactive penalties and compliance consequences. With national authorities allowed up to 120 calendar days to process applications, filing at the last minute may avoid an immediate import stop — but it does not remove downstream risk.1
For many businesses, this is the final warning: March is still about customs access; April starts the shift toward financial exposure.
2. UK CBAM Consultation Closes, Confirming Parallel Compliance Pressure for 2027
The UK's technical consultation on the first set of draft secondary legislation for its own Carbon Border Adjustment Mechanism closed on 24 March 2026. Although the UK regime will only take effect on 1 January 2027, the direction of travel is increasingly clear: businesses with both EU and UK import exposure should now treat 2026 as a dual-preparation year.4, 5
The draft UK framework covers the core administrative mechanics of the future regime, including registration, filing and return obligations, record-keeping, weight calculation rules, reimbursement arrangements, and carbon price relief methodology.5
A second package of draft UK secondary legislation is still expected in Spring 2026, which means further detail is likely to follow soon. For multinational importers, the message is simple: EU CBAM may be the immediate priority, but UK CBAM is no longer a distant issue.6
3. First CBAM Certificate Price Publication on 7 April Will Mark the Next Big Milestone
The first official CBAM certificate price publication is scheduled for 7 April 2026. The European Commission will publish the first quarterly CBAM certificate price based on the average EU ETS auction price for Q1 2026. The figure will be published on the Commission's CBAM website and in the CBAM Registry.2
Although importers will not need to purchase certificates for 2026 imports until February 2027, the 7 April publication is highly relevant because it gives companies their first formal basis for budgeting future CBAM exposure, testing product-level margin impacts, discussing cost pass-through with customers, re-evaluating supplier structures, and building internal forecasting models.2
In practical terms, this is the moment when CBAM begins to move beyond registration and customs mechanics and starts to become a real financial planning issue. For many businesses, April will be the month in which CBAM stops being treated as a regulatory project and starts being treated as a commercial cost variable.
What to Watch in Early April
Although this week brought no major new legislative headlines, the start of April will be one of the most important operational checkpoints of the year so far. Key dates to watch:
- 31 March 2026 — final deadline to apply for authorised CBAM declarant status
- 1 April 2026 onwards — increased customs and import risk for companies that failed to apply in time
- 6 April 2026 — deadline for the Common Central Platform (CCP) tender, the infrastructure that will later support CBAM certificate sales and repurchases3
- 7 April 2026 — publication of the first official CBAM certificate price
In collaboration with
Hulsman & Partners
This article was produced in collaboration with Hulsman & Partners. Looking for expert guidance on CBAM compliance? Their team offers specialised consultancy to help your organisation navigate the Carbon Border Adjustment Mechanism.
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- European Commission, DG Taxation & Customs Union — CBAM implementation / news page
- European Commission, DG Taxation & Customs Union — First CBAM Certificate price to be published on 7 April 2026 (6 Mar 2026)
- European Commission, DG Taxation & Customs Union — Call for tender to establish the Common Central Platform (CCP) (2 Mar 2026)
- GOV.UK, HM Revenue & Customs — Carbon border adjustment mechanism (CBAM): Policy Summary
- GOV.UK, HM Revenue & Customs — Draft regulations: Carbon Border Adjustment Mechanism (CBAM)
- CMS Law-Now — The road to a UK CBAM: various new developments