# What does an Indian plant have to do and by when for its 2027 UK CBAM data?

Canonical: https://senseible.earth/answers/uk-cbam-plant-calendar-2027-to-may-2028

HM Revenue and Customs (HMRC) gives plants a calendar in its Carbon Border Adjustment Mechanism (CBAM) technical guide. Monitoring starts on 1 January 2027, a verifier is recommended from October 2027, the report goes to the verifier from January 2028, and the plant sends the verification report to the importer before 31 May 2028.

## HMRC's table, row by row

1. 1 January 2027 onwards: the plant sets up a monitoring plan and supplementary procedures, monitors the fuels and materials it uses, talks to the makers of any precursor goods about the data it needs from them, and reviews collected data regularly.
2. From October 2027 onwards: HMRC's table labels this a recommendation, that the plant liaise with and appoint a verifier.
3. From January 2028: the plant collates its data, produces the CBAM emissions report and sends it to the verifier.
4. January 2028 onwards, the verifier: reviews the report, arranges and completes a site visit, produces the verification report or summary, has an independent review completed, and issues the report to the plant.
5. Before 31 May 2028: the plant sends the verification report or summary to the importer.
6. By 31 May 2028: the importer submits its CBAM data to HMRC for the 2027 compliance year.

## What the table assumes about 2027

Goods imported before 1 January 2028 can use a verified figure from the 2026 or 2027 monitoring period, or from the year the goods were made. The guide says the plant must give the importer its first verification report for 2027 imports before 31 May 2028.

The table says it shows the current process with one reporting deadline and that quarterly reporting opportunities will follow. Section C3.7.1 says importers of goods from 1 January 2028 file quarterly tax returns, and the plant then provides its most recent verification report.

## What we read into it

The table gives no number of weeks for a verification. Our reading: the table recommends appointing from October 2027 but the verifier's work starts when the report arrives in January 2028. Appointing in October gives about eight months from appointment to 31 May 2028 to agree scope and fix gaps; waiting until February leaves about four.

## Example: counting the months

- Appoint in October 2027: October, November, December, January, February, March, April, May = 8 months to 31 May 2028
- Appoint in February 2028: February, March, April, May = 4 months, and the importer needs the report before 31 May, so fewer in practice
- Difference: 8 minus 4 = 4 months more between appointment and 31 May 2028

The months are counted by us from HMRC's dates; HMRC gives no time needed for a verification. They measure appointment to 31 May 2028, not verification time.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. That gives the monthly fuel and electricity history a monitoring plan starts from. It does not write the plan or the emissions report for you. A verifier accredited for UK CBAM must still verify the figure.

- [Which year's figure the buyer uses](https://senseible.earth/answers/uk-cbam-which-year-emissions-figure)
- [What a UK CBAM monitoring plan holds](https://senseible.earth/answers/uk-cbam-monitoring-plan-contents)
- [Who sends the verification report](https://senseible.earth/answers/uk-cbam-verification-report-who-sends-it)
- [UK CBAM for Indian exporters](https://senseible.earth/uk-cbam)

Sources: [HMRC, Carbon Border Adjustment Mechanism (CBAM): technical guide for monitoring, reporting and verification](https://assets.publishing.service.gov.uk/media/6ad219fe0f7b53973e02680f/CBAM_technical_guidance.pdf), [HMRC, Carbon border adjustment mechanism (CBAM): Policy summary](https://www.gov.uk/government/publications/carbon-border-adjustment-mechanism-cbam-policy-summary/carbon-border-adjustment-mechanism-cbam-policy-summary)

Last reviewed 2026-11-06. HMRC is taking feedback on this technical guide until 13 November 2026 and may update it before 1 January 2027. Re-check Table 6-1 then.