Skip to main content
    QHSEtech
    Updated 27 September 2026
    EU importer guide · definitive regime

    CBAM Software 2026: An Importer's Buying Guide

    Choose software around a traceable import record: which goods entered the EU, who is responsible, which installation produced them and which emissions evidence supports the declaration. A supplier portal or carbon dashboard solves only part of that process.

    Jump to the 2 products

    Editorial responsibility: Dimitris Mitsios (Founder of The QHSE Standard; product marketing at Tekmon) · Tekmon pays for sponsored placements on this site (disclosure) · How pages are made · LinkedIn · Content date: 27 September 2026

    The rules your 2026 workflow needs to reflect

    Scope goods and the importer

    The definitive regime began on 1 January 2026. It covers selected goods in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen; use the applicable Annex I codes, not a blanket industry label. Commission: definitive regime

    The enacted mass exemption is 50 tonnes of cumulative net mass per importer per calendar year across the relevant goods. Electricity and hydrogen are excluded. Monitor totals across shipments; if exceeded, the year's covered imports enter scope, not just the excess. Enacted Regulation (EU) 2025/2083

    Keep imports and payment dates distinct

    The first declaration and corresponding certificate surrender for 2026 imports are due by 30 September 2027. Establish the authorised declarant and current authorisation requirements before relying on a filing workflow. Commission: implementation notices

    Certificate purchases begin in February 2027. Prices for 2026 imports use quarterly EU ETS auction averages; from 2027 the pricing basis is weekly. A planning estimate is not a certificate purchase. Commission: certificate prices and sales

    From 2027 the declarant must also hold, at the end of each quarter, certificates equal to at least 50% of the embedded emissions of the goods imported since the start of that calendar year (Article 22(2) as amended), so the software needs a running year-to-date estimate, not only the annual figure. DEHSt (German CBAM authority): certificates and quarterly holding · Regulation (EU) 2023/956, consolidated as amended

    This is a buying-oriented summary of enacted rules checked on 27 September 2026. The Commission lists legislative proposals separately from applicable regulations. Treat future scope extensions as change scenarios until adopted and applicable. Commission: legislation and current guidance

    Build the importer evidence chain

    1

    Reconcile customs records

    Import representative declaration lines, CN codes, origin, net mass and importer identity. Correct duplicates and reconcile totals with the broker or customs source.

    2

    Resolve supplier and installation identity

    Connect each good to the producing installation and reporting period. Route incomplete or inconsistent supplier responses to a named reviewer.

    3

    Record the calculation route

    Preserve the method version, inputs, precursor treatment and applicable factor/default dataset. Identify what is actual, default or still missing.

    4

    Prepare review and verification

    Provide the appropriate evidence to the reviewer and accredited verifier where required. Keep changes and unresolved findings visible.

    5

    Confirm the declarant handoff

    Demonstrate the annual declaration workflow, who submits, and where acceptance and certificate records are retained. Distinguish a file export from completed submission.

    Actual emissions and defaults are different evidence paths

    For goods other than electricity, the amended regulation permits actual emissions or prescribed default values. Actual emissions require verification by an accredited verifier; electricity has separate conditions. Enacted Regulation (EU) 2025/2083

    Ask which current method and dataset the software uses. The Commission guidance index includes corrected definitive-period default values, so a transitional spreadsheet is not a current calculation specification. Commission: legislation and current guidance

    Software evidence to use in a shortlist

    A product is listed only if its record documents a CBAM capability with a source. It is not a ranking, a complete market list or certification that a deployment meets the definitive regime; products without a researched profile are not listed. The count printed under this heading is the whole catalogue answer: no other researched record mentions CBAM, so absence here means no CBAM capability was found in the records, not that a product lacks one. A framework library or supplier request form does not establish a CBAM calculation engine, registry integration or declarant service: demonstrate each against the workflow above.

    Tekmon pays for a sponsored placement (above); its place in this list follows the same rule as every entry. How lists are ordered

    Same rule for every product: tagged “Carbon Accounting”, “Emissions Reporting”, “ESG Reporting”, “ESG Frameworks Reporting”, “Supplier Data”, “Supplier Sustainability” or “Supplier Due Diligence”, with a sourced CBAM capability in its record, or one the vendor stated to us, labelled as vendor-stated. 2 qualify.

    • Tekmon

      Documented: Pre-built ESG framework libraries. Source: tekmon.com

    • osapiens HUB

      osapiens HUB for CBAM: the current product page describes import screening, supplier-data collection, embedded-emissions calculations, certificate exposure and EU-compatible XML exports; Supplier Portal documentation shows operator and installation fields plus partial responses. Confirm the definitive-regime configuration and human review. An XML export is not evidence of direct CBAM Registry submission or legal compliance. Source: osapiens.com

    Demo a corrected import and an incomplete supplier response

    Load the same customs file twice and show duplicate detection, correction history and importer totals.
    Approach and cross the applicable threshold; test how the year's records and responsible owner are flagged.
    Provide an incomplete installation response. Show what remains missing, who follows up and which calculation path is allowed.
    Change a source value after review. Trace the affected records, recalculation and new approval evidence.
    Show the latest method and default dataset version, then export the inputs, calculations and evidence for independent review.
    Identify the person who submits and demonstrate the actual filing method and retained acknowledgement; do not stop at a generated report.

    Separate software cost from certificate exposure

    Request a proposal covering importer entities, users, goods, installations, supplier onboarding and support.
    Scope customs/ERP mappings and responsibility for interface errors; API availability does not prove a working connector.
    Price calculation support, verification coordination and any declarant service separately, with named responsibilities.
    Keep certificate expenditure outside the software quote. Preserve the price period and adjustment assumptions behind any forecast.
    Measure reconciliation effort, unresolved supplier responses and evidence retrieval during a pilot before estimating savings.

    Compare demonstrated results

    Record requirements, evidence and unresolved questions in the existing scorecard. Adapt the questions to your goods and declarant process; start untested.

    Open the demo scorecard

    Sources and review scope

    9 sources

    Primary EU sources and official product documentation reviewed through 27 September 2026; the latest targeted product recheck covered the osapiens CBAM workflow and Supplier Portal documentation. This review did not test a vendor deployment or establish a complete customs classification or legal assessment for a particular importer.

    Related evaluation guides

    ESG platform comparisonCSRD software comparisonCarbon accounting softwareSoftware integrations

    More related guides

    Frequently Asked Questions

    What should CBAM software help an importer do?
    Reconcile covered imports, track importer-level scope, collect installation evidence, preserve the calculation basis and prepare the declarant's work. Test the actual submission handoff and acceptance evidence; software does not replace the authorised declarant or accredited verifier.
    Does the old EUR 150 per-consignment test still describe the exemption?
    No. The enacted simplification uses an annual importer-level mass threshold for the relevant goods. Electricity and hydrogen are excluded from that mass exemption. Use the scope section and current legal text rather than a transitional-era checklist.
    Are 2026 imports still covered if certificate sales begin later?
    Yes. The definitive regime covers 2026 imports even though certificate sales begin in February 2027. The first annual declaration and corresponding surrender are due by 30 September 2027 for the preceding year.
    Who is the authorised CBAM declarant?
    The importer established in a Member State once authorised by its competent authority, or an indirect customs representative holding the status and acting for the importer; the representative route is required where the importer is not established in the EU. Above the 50-tonne threshold only an authorised declarant may import CBAM goods, although importers that applied by 31 March 2026 could keep importing pending a decision. The declarant surrenders the certificates and may delegate submission of the declaration but remains responsible (Articles 4, 5 and 17 of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083).
    Are actual supplier emissions compulsory in every case?
    No. For goods other than electricity the amended regulation provides actual-emissions and default-value routes. Actual emissions require accredited verification. Electricity has specific rules. Ask the software to record the selected route, applicable method and supporting evidence.
    Does general carbon accounting establish CBAM capability?
    No. A corporate footprint does not demonstrate CN-code scoping, installation data, CBAM calculation methods or the declarant's filing process. Request a current definitive-regime demonstration using representative imports.
    How much does CBAM software cost?
    Obtain a scoped quote. Separate subscription, supplier onboarding, interfaces, implementation and verification services from certificate expenditure. This guide does not establish universal vendor pricing, avoided-cost figures or ROI percentages.