Draft CBAM certificate platform: per-certificate fee, euro-only payment
You will buy CBAM certificates through a system that nobody has used yet. A draft Commission delegated regulation, Ares(2026)6860249, proposes how a common central platform would run those sales and the repurchases that follow them.
The draft covers the roles of the platform and the Registry, payments, fees, security, reporting and data protection. None of it is in force, and every parameter below is provisional.
Registry and platform would have different jobs
Under the draft, the CBAM RegistryCBAM RegistryEU IT system holding declarant accounts, declarations, verified emissions reports, certificate transactions and (from 2027) the published default carbon prices. would hold the compliance record, and the platform would handle the money. The Registry record covers requests, certificate creation, ownership, holdings, surrender, cancellation and the audit trail. The common central platformCommon Central PlatformCommission-managed platform through which Member States sell and repurchase certificates from 1 Feb 2027; reachable only by authorised declarants, only from the Registry; costs financed by declarant fees. would execute the banking and payment side of sales and repurchases.
The sequence matters if you design a process around it. A request would start in the Registry, and the platform would act only after secure data exchange and effective payment. Purchased certificates would become available after payment confirmation. Under the draft they would be non-transferable and assigned only to the purchasing declarant.
The proposal contains no supply cap and no Member-State allocation limit. Purchase timing, and the holding and surrender rules in the basic Regulation, remain separate matters.
The draft proposes a fixed sale fee per certificate
Article 15(1) of the draft proposes a fixed fee per CBAM certificate sold. It says that no other sale or repurchase fee or charge would apply.
The fee would finance the operation of the common central platform, and it would be collected through declarant payments. Article 13(3) of the same draft would require all sale and repurchase payments to be made exclusively in euro.
Treat this fee as a proposal, not a current tariff. You can use it as a clearly labelled scenario in a cash-flow model. Do not put it in a customer quote, an approved budget or a software configuration as a settled charge until you have verified adoption.
Repurchase would be one irrevocable request a year
The draft provides for one repurchase request per year. Once entered, the request would be irrevocable and could not be amended.
Competent-authority approval windows would be tied to 1 April, 1 July and 1 November, with a 42-calendar-day decision period for eligible requests. Any repurchase would remain subject to the limit in Regulation (EU) 2023/956, and it would use the original purchase price. The platform could refuse a payment where request data appeared inaccurate or security was compromised.
Design your workflow around that irreversibility. An annual request that nobody can amend leaves no room to correct an error, so it needs a formal pre-submission check with a named approver.
| What the draft proposes | Value in the draft |
|---|---|
| Sale fee | A fixed fee per certificate sold; no other sale or repurchase fee |
| Payment currency | Euro only |
| Repurchase requests | One a year, irrevocable once entered |
| Approval windows | 1 April, 1 July and 1 November; 42-calendar-day decision period |
| Data retention | Five years after the recording year |
| General application | From 1 February 2027 |
Draft Commission Delegated Regulation, Ares(2026)6860249. Not adopted.
Access, reconciliation and retention would be written into the design
The proposal calls for a secure, near-real-time interface between the Registry and the platform. It adds incident controls, transaction logs, daily reconciliation, operational reporting, a helpline and continuity arrangements.
Access would be split. Member-State authorities would see only declarants established in their territory, while the Commission would have system-wide access. Bank-account and transaction data would sit under a joint-controller model. Platform data would be retained for five years after the recording year.
The draft would generally apply from 1 February 2027. The procurement and contract provision would apply earlier, after entry into force. Do not treat either date as operative until you have checked an adopted act.
What it means for importers
Nothing changes in your costs today, because the fee and the procedures are still a draft. If the draft is adopted as written, you would pay for certificates exclusively in euro, plus a proposed fee per certificate sold. You would also get one irrevocable repurchase request a year.
What to do
Three teams can start work this quarter, and each one should keep the Registry record and the payment side apart.
- Declarants: map who will initiate requests, approve payments, reconcile certificates and review bank details.
- Finance teams: model euro liquidity, and add the draft fee as a clearly labelled scenario.
- System teams: separate the Registry compliance record from payment execution in your requirements, because the draft treats them as two different things.
Before implementation, compare the final act with this draft, article by article, once it appears in the Official Journal. Until then, document your assumptions and name one person to watch for adoption. Do not present the platform or the fee to anyone as live.
Stuck on this in your own import data? Write to us and we will look at it with you.
This article explains a draft regulation. It is not legal, tax or customs advice.
Informational only — not legal or tax advice. CBAM rules change; verify against the official source before acting.