Senseible

What happens to UK Carbon Border Adjustment Mechanism (CBAM) duties if the importer dies, is incapacitated or becomes insolvent?

Another person can carry on a registered importer's business for CBAM if it dies or is incapacitated, and must tell HM Revenue and Customs (HMRC) within 21 days. For insolvency, HMRC treats the insolvency office holder as the registered person; earlier liability stays with the registered person.

Death or incapacity

Insolvency

What it means for a supplier

Our reading, not HMRC's: your verified figure and verification summary stay relevant to the return of whoever is treated as the registered person, so keep sending them to the named contact. HMRC's summary does not say what happens to supplier contracts.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated records, which feed a plant's emissions figure. It does not give legal or insolvency advice.

Sources: HM Revenue and Customs, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026)

Last reviewed 2026-11-05. HM Revenue and Customs says the details in its policy summary may be subject to change. Re-check the policy summary and the keeping-records page before relying on a date or condition.