Before the obligation to purchase CBAM certificates became effective on 1 January 2026, importers were subject to reporting requirements only. The transitional period, which run from 1 October 2023 until 31 December 2025, focused exclusively on emissions reporting.

During this phase, importers bringing CBAM-covered goods into the EU had to report the total embedded greenhouse gas emissions associated with those products. The scope currently includes, among others:

• cement,
• iron and steel,
• aluminium,
• fertilisers,
• electricity.

CBAM reports must generally be submitted quarterly, no later than the end of the month following the relevant reporting quarter.

For many businesses in Slovakia - including importers and indirect customs representatives - CBAM introduces entirely new regulatory responsibilities. Although customs authorities provide guidance during the transitional phase, the responsibility for accurate and timely reporting remains with the reporting entity.

Failure to comply may result in administrative procedures, correction requests and, eventually, financial penalties once the full CBAM system is in place.

We offer end-to-end CBAM advisory services to support companies affected by the new EU requirements. Our assistance covers both the transitional reporting phase and preparation for the full implementation of CBAM, including the future obligation to purchase certificates.

Our services are designed to reduce administrative burden, mitigate compliance risks and ensure alignment with EU and Slovak regulatory expectations.

We support clients throughout the registration process, handle formalities, liaise with competent authorities, and prepare the required documentation. Our experts also represent clients in contact with environmental and customs authorities, ensuring a smooth and compliant process.

How Crowe supports CBAM reporting – scope of services

Identification of CBAM-covered goods

We analyze product portfolios and customs classifications to determine whether imported goods fall within the CBAM scope, based on Combined Nomenclature (CN) codes.

CBAM obligation analysis for importers

We prepare clear and practical guidance covering:

• emission reporting requirements for CBAM goods,
• reporting workflows and timelines,
• data requirements from non-EU suppliers,
• internal processes required during the transitional phase,
• CBAM record-keeping structure and documentation standards,
• reporting methods and report content,
• administrative procedures, including correction requests,
• potential sanctions and future obligations under the definitive CBAM system.

CBAM obligations for non-EU suppliers

We assist exporters and manufacturers outside the EU by preparing dedicated analyses covering:

• emission reporting duties for steel and aluminium products,
• monitored emission data and methodologies,
• production processes subject to emission monitoring,
• practical guidance based on Implementing Regulation (EU) 2023/1773,
• emission calculation databases (e.g. Excel or Access formats) aligned with the European Commission’s CBAM communication templates.

CBAM hotline

We provide ongoing access to CBAM experts through a dedicated CBAM hotline, offering practical, day-to-day support within an agreed monthly scope.

CBAM record-keeping

We support the preparation and maintenance of CBAM records in line with Implementing Regulation (EU) 2023/1773, based on data received from importers and suppliers.

Quarterly CBAM reporting

After submission of the initial reports, we handle ongoing quarterly CBAM reporting via the CBAM IT systems, ensuring consistency and compliance.

Administrative proceedings and corrections

We assist in proceedings initiated by competent authorities, including correction and clarification procedures related to submitted CBAM reports.