What happens if a UK importer does not keep records for the UK Carbon Border Adjustment Mechanism (CBAM)?

HM Revenue and Customs (HMRC) says an importer may be charged a fixed penalty of £500 for not keeping CBAM records, and separate penalties may apply if it does not provide information or documents when asked. Records are kept in written or electronic form for 6 years.

What HMRC says

• Records are kept in written (including electronic) form for 6 years from the latest of the date they were created or the end of the accounting period they relate to.
• "You may be charged a fixed penalty of £500 if you do not keep records for Carbon Border Adjustment Mechanism (CBAM)."
• "Separate penalties may apply if you do not provide information or documents when asked to by HMRC."
• Records start with goods imported from 1 January 2027.

Two wordings of the 6 years

The policy summary says records are held "for 6 years after the end of the accounting period the goods are attributed to". The keeping-records guidance, updated on 3 November 2026, says 6 years from the latest of the date a record was created and the end of the accounting period it relates to. Our reading, not HMRC's: the two give the same end date for a record made before the period closes, and differ for a record made after it. The guidance wording is the more detailed of the two.

The record that comes from your plant

If an importer reports actual emissions, HMRC says it must keep the verification report, or verification summary, relevant to the emissions intensity on its return for 6 years. Our reading: your buyer will want a copy it can still open in 2033 or later, so keep your own copy for as long.

Same period, two records

• Goods imported on 15 March 2027 fall in the first accounting period, which ends on 31 December 2027.
• Import declaration, created 15 March 2027: the later date is 31 December 2027, so keep until 31 December 2033.
• Verification summary, created 20 February 2028: the later date is 20 February 2028, so keep until 20 February 2034 under the guidance wording.
• Under the summary wording alone, both would end on 31 December 2033.

Example dates.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated records, which feed a plant's emissions figure. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them. It does not hold import declarations or customs records, and it does not decide how long your buyer keeps them.

• Records your UK buyer will ask for
• UK CBAM return calendar
• Verification summary or report
• CBAM report from your records

Sources: HM Revenue and Customs, Keeping records for Carbon Border Adjustment Mechanism (CBAM) (updated 3 November 2026), 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.