Authorisation as CBAM declarant – important updates!

In the Implementing Regulation (EU) 2025/486 dated 17 March 2025, the European Commission has specified the conditions and procedures related to authorisation as CBAM declarant. Only authorised CBAM declarants may import CBAM goods from 1 January 2026! Importing CBAM goods without corresponding authorisation may result in sanctions after 1 January 2026.

Please find the main points regarding authorisation as CBAM declarant in the following paragraphs:

Procedure for application

• • The application to become an authorised CBAM declarant is performed via the Authorisation Management Module (AMM) in electronic format.
  • Applicants have to submit the application and obtain the authorisation as CBAM declarant prior to the first importation of goods subject to CBAM.
  • Special regulations apply for importers of electricity: They qualify automatically as authorised CBAM declarants, if certain requirements are met.

Requirements for authorisation

• • Applicants must be established in the Member State in which they submit the application.
  • The applicant holds an EORI number.
  • Applicants must not be involved in serious or repeated infringements of customs legislation, taxation rules or market abuse rules in the three years preceding the application.
  • Applicants must not commit any serious economic criminal offences during the five years preceding the application.
  • The applicant demonstrates sufficient financial and operational capacity:
    • no bankruptcy proceedings
    • no material arrears regarding payments of customs duties, taxes or charges which are collected on or in connection with the import of goods and financial regulatory obligations
    • demonstration of sufficient financial standing
    • appropriate administrative organisation and appropriate internal control mechanisms
    • provision of a guarantee based on the value of the CBAM certificates, if necessary

Procedure

• • The competent authority shall assess the application within 120 calendar days (in case of applications prior to 15 June 2025: 180 days).
  • The competent authority may request additional information and extend the deadline by up to 30 calendar days.
  • Prior to refusing the application, the applicant is provided with the possibility to submit observations.

Revocation and reassessment

• • The authorisation may be revoked if the requirements are not met anymore or if serious infringements are determined.
  • Also after revocation, declarants must comply with all their obligations for goods imported prior to the revocation.

Penalties

If goods subject to CBAM are imported without an authorisation as CBAM declarant, penalties of EUR 300 to EUR 500 per not surrendered CBAM certificate may be imposed.

Application in Austria

In Austria, every importer or indirect customs representative may submit an application for authorisation as CBAM declarant via the Authorisation Management Module (AMM) as of beginning of April 2025. The following requirements must be met to access the AMM:

• • EORI number
  • Access to the Business Service Portal (USP)