How many CBAM certificates must an authorised declarant hold at the end of each quarter?
At the end of each quarter, the declarant must hold certificates covering at least 50% of the embedded emissions in goods imported since 1 January of that year, after the free allocation adjustment. The 2025 simplification cut this from 80%. All certificates for the year are then surrendered with the annual declaration.
The rule in Article 22
Article 22(2) of the CBAM Regulation sets a quarterly holding test on the declarant's account in the CBAM Registry. Regulation (EU) 2025/2083 amended it, lowering the share from 80% to 50% of embedded emissions in goods imported since the start of the calendar year. The test is cumulative: each quarter looks back to 1 January, not just at that quarter's imports.
How it fits the annual cycle
- Certificates for 2026 imports go on sale from February 2027; the Commission publishes a quarterly price for 2026 imports.
- The annual declaration for 2026 imports, with surrender of all certificates due, is by 30 September 2027.
- Holding is a cash flow question: the quarterly rule makes you buy part of the year's need before the declaration.
- If you hold more than you need at surrender, the Commission repurchases excess certificates only within limits set in the Regulation.
How to budget for it
- Estimate the year's embedded emissions from expected tonnes and supplier data or default values.
- Deduct the free allocation adjustment for that year.
- Spread the net figure by your import schedule, quarter by quarter.
- At each quarter end, hold at least 50% of the cumulative net figure.
- Revisit the estimate when actual verified supplier data arrives; it can move the figure either way.
Worked example: 1,000 t net embedded emissions, imported evenly
- Imports: 250 t of embedded emissions per quarter, net of free allocation
- End Q1: cumulative 250 t, hold at least 125 certificates
- End Q2: cumulative 500 t, hold at least 250
- End Q3: cumulative 750 t, hold at least 375
- End Q4: cumulative 1,000 t, hold at least 500
- At €82.32, 500 certificates cost 500 x 82.32 = €41,160
€82.32 is the Q3 2026 certificate price, used for illustration; the price you pay depends on the rules for each year's imports.
What Senseible does here
Senseible's CBAM calculator estimates annual certificate cost from tonnes, production route and the free allocation phase-out, which gives the base for a quarterly budget. It does not hold, buy or surrender certificates, and it does not connect to the CBAM Registry.
Sources: Regulation (EU) 2025/2083, CBAM simplification, Regulation (EU) 2023/956, consolidated text (Article 22), European Commission, price of CBAM certificates
Last reviewed 2026-10-15. The 50% holding share comes from the 2025 amendment; confirm the consolidated Article 22 text and when the quarterly test first applies on EUR-Lex.