As the transitional phase of the CBAM ends on 31 December 2025, affected businesses must begin preparing for the full implementation phase starting in 2026. From that point forward, CBAM obligations will extend beyond reporting and will include actual financial liabilities. The first and most critical step in preparation is obtaining the authorised CBAM declarant status, which has been available for application in Hungary since 1 September via the National Climate Protection Authority’s official website.

What are the key changes?

De minimis exemption introduced

Under the new rules, importers bringing less than 50 tonnes per year of CBAM-covered goods into the EU will be exempt from CBAM obligations.

This uniform weight-based threshold applies across the iron, steel, cement, aluminium, and fertiliser sectors. However, imports of electricity and hydrogen remain excluded from this exemption. This rule will relieve approximately 90% of importers, predominantly small and medium-sized enterprises, while maintaining coverage of 99% of emissions from the targeted goods.

If an importer exceeds the annual threshold, all goods imported during the year become subject to full CBAM obligations, including:

• Obtaining authorised CBAM declarant status: applications submitted by 31 March 2026 will be eligible for transitional relief, allowing continued imports until the permit is granted. Applications in Hungary opened on 1 September and can also be submitted electronically via the ePaper platform. The European Commission will review the appropriateness of the threshold annually, and national customs authorities can suspend further imports if the threshold is breached without proper authorisation.

• Annual CBAM declaration and certificate surrender: declarants must submit their annual CBAM report and surrender certificates by 30 September each year, covering the previous year’s emissions. The first deadline is 30 September 2027, with CBAM certificate trading also starting in 2027.

The main challenge for importers remains the acquisition of embedded emissions data from non-EU manufacturers. In Hungary, these difficulties may be reported to the National Climate Protection Authority as part of the excuse mechanism (derogation).

Simplified administrative CBAM obligations

In addition to the de minimis threshold, the Omnibus I package introduces several streamlining measures, including streamlining the authorisation process, clarifying emissions calculation rules and reducing certificate purchase requirements.

Under current CBAM rules, importers must purchase CBAM certificates for at least 80% of embedded emissions in each quarter. The amendment reduces this obligation to 50%, thereby easing initial financial and administrative burdens for businesses.

Status and next steps

The Omnibus I regulation introducing the de minimis threshold has not yet entered into force. Following approval by the European Parliament, it now awaits formal adoption by the Council.

In Hungary, entities expecting to exceed the 50-tonne threshold, or those importing electricity or hydrogen, can now apply for authorised CBAM declarant status. During the transitional period, quarterly data reporting requirements remain in force.

These reforms offer significant relief for smaller market players, while also simplifying compliance for larger importers. However, the upcoming full implementation phase of CBAM will bring increased regulatory pressure in line with the EU’s climate targets. Timely preparation is essential. For expert support with CBAM compliance, reach out to the tax advisers at WTS Klient Hungary.

This article provides general information and does not constitute advice.

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What is the CBAM?

In May 2023, the European Union adopted Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, often referred to as the carbon tax or the CBAM Regulation. Commission Implementing Regulation 2023/1773 was published in August 2023 in connection with the CBAM Regulation, and the related rules entered into force on 1 October 2023.

In accordance with the regulation, from 1 January 2026 economic operators will have to pay a so-called carbon tax on imports of certain products to the EU, and submit quarterly data via an electronic interface set up by the EU.

Which products does the CBAM reporting obligation cover?

The products concerned are listed by customs tariff code in Annex I of the CBAM Regulation, and are typically products whose manufacture involves significant carbon dioxide emissions. These products are: cement, electricity, fertilisers, iron and steel, aluminium and hydrogen. The regulation will therefore mainly affect entities in the energy, automotive and machinery sectors, as well as fertiliser, chemical, iron, steel and aluminium companies.

Although the related payment obligation will only be a factor in two years’ time, businesses importing the above products already have an obligation to fulfil during the current transitional period, i.e. between 1 October 2023 and 1 January 2026: the CBAM reporting obligation. The first deadline for the fourth quarter of 2023 is 31 January 2024. The CBAM reporting obligation includes, among other things, the quantity of the given products placed on the market in the given quarter, information on the origin of the products and the associated carbon dioxide emission data – all of this must be included in the report.

Last week of January: get ready!

Only economic operators who have pre-registered with the competent Hungarian authority, i.e. the National Climate Protection Authority may access the EU platform. However, it is not yet possible to register on the Climate Protection Authority’s website, this will only be permitted in the last week of January, once the national legislation empowering the National Climate Protection Authority to act as a national authority in CBAM matters enters into force on 22 January.

Importantly, failure to fulfil the CBAM reporting obligation or not doing so properly could bring penalties for the economic operators concerned, ranging from EUR 10 to 50 per tonne of unreported emissions.

The European Union’s economic measures to support climate protection are increasingly affecting the businesses of most economic operators, so we believe it is important that all entities are kept informed about the new obligations.  This is why tax advisers of WTS Klient Hungary are always available with up-to-date news and information.

A CBAM reporting obligation by 31 January! bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.