CBAM – reporting deadline for Q3 2025 and KOBiZE calls

The National Centre for Emissions Balancing and Management (KOBiZE) once again reminds of the key obligation to report CBAM (Carbon Border Adjustment Mechanism) for the third quarter of 2025. The deadline for submitting the report is the end of October 2025. Reporting covers embedded emissions related to CBAM goods (including cement, iron and steel, aluminium, fertilizers, electricity, hydrogen) imported into the customs territory of the European Union between July and September 2025.

KOBiZE is actively sending requests to submit reports to entities that have not yet fulfilled this obligation for the entire period from the entry into force of the CBAM regulations, i.e. from 1 October 2023. The CBAM report is submitted using the CBAM transitional register administered by the European Commission.

Business owners, if you have received a notice or are behind on your submission, there is only one answer: you must immediately submit the overdue reports with the required emissions values. As a rule, failure to submit overdue reports will result in penalties.

What to do if actual emissions data are missing?

One of the most common challenges the importers face is the inability to obtain actual embedded emissions data from non-EU CBAM producers. It is important to remember that the reporting entity is obligated to make every effort to obtain these actual figures from its suppliers.

If, despite these efforts, actual data is unavailable at the time of reporting, the National Centre (following the European Commission) will provide information on how to proceed. In the CBAM interim register, in the “Emissions” tab, in the section regarding direct embedded emissions, select the option “Actual data not available” from the list in the “Determination method” field. You can read the explanations from KOBiZE here.

In addition, KOBiZE published messages regarding the most frequently occurring errors during report validation along with their solutions (message of January 23, 2025).

Simplifications and changes to the CBAM mechanism. What will Regulation 2025/2083 change?

On October 17, 2025, Regulation (EU) 2025/2083 of the European Parliament and of the Council (Omnibus I) was published. It introduces simplifications and improvements to the final CBAM mechanism, but the key information for businesses is as follows: the changes do not apply to the CBAM transitional period.

The rules for submitting quarterly CBAM reports remain unchanged!

The new regulations came into force on October 20th of this year, but in most cases, they will only apply from January 1st, 2026, the CBAM target period. Among the most important changes that await us in the future, it's worth mentioning:

• New de minimis threshold. Exemption from CBAM obligations for importers whose imports of CBAM goods (excluding energy and hydrogen) do not exceed 50 tonnes of net weight of goods per year.
• Possibility to continue importing without the status of an authorized CBAM declarant, provided that an application for the status is submitted by 31 March 2026.
• Change of deadline for submitting CBAM declarations and transferring certificates for cancellation to 30 September each year (first time in 2027 for the year 2026).
• Reduction of the level of mandatory quarterly maintenance of certificates in the CBAM register from 80% to 50% of emissions (from 2027).

You can read more about the new regulations here: Three CBAM regulations in EU public consultations

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