Methodological Guidelines № 3 on CBAM: Reporting, Verification, and Fulfilment of Financial Obligations
At the end of March 2026, Biomass-Carbon LLC publishes the third methodological guidelines regarding the Carbon Border Adjustment Mechanism — “CBAM Financial and Administrative Procedures for Verification, Reporting, and Fulfilment of Obligations”, covering the CBAM definitive period from January 1, 2026.
The document was prepared within the project “Technical Assistance for the Export of CBAM Goods from Ukraine to the EU“, implemented with the support of the Ministry of Foreign Affairs of the Kingdom of the Netherlands. The primary goal is to assist Ukrainian producers and exporters in preparing for the fulfilment of administrative and financial obligations during the CBAM definitive period.
The guidelines are intended for technical directors, production managers, environmental engineers, and export specialists of Ukrainian enterprises that supply or plan to supply CBAM-covered goods to the European Union. The document’s structure is designed to guide the reader through all stages of fulfilling the mechanism’s administrative and financial requirements.
Check out the methodological guidelines №3 (in Ukrainian)
About Methodological Guidelines № 3
The document covers five key thematic blocks:
- Portal for Operators of Installations in Third Countries (O3CI): detailed instructions on registration and operation within the O3CI system: creating an EU Login account, setting up two-factor authentication, delegating rights to employees, and uploading verified reports. For Ukrainian enterprises, a company identifier in the format UA + EDRPOU code is used.
- Use of Default Values for Embedded Emissions: explanation of the rules for applying default values according to Implementing Regulation (EU) 2025/2621, including the hierarchy of data sources for precursors, the mixed approach (combining actual and default values), and current mark-ups: 10% in 2026, 20% in 2027, and 30% from 2028.
- Specifics of Embedded Emissions Verification: a step-by-step guide on preparing for mandatory verification: requirements for accredited verifiers, the audit process from strategic analysis to the physical site visit, the content of the verification report, and the materiality threshold of 5%. In 2026, a physical site visit by the verifier is mandatory for all installations without exception.
- Determination of Free Allocations and Assessment of Financial Obligations: detailed methodology for calculating the Free Allocation Adjustment (FAA) and the Specific Embedded Free Allocation (SEFA) with practical examples for 7 typical goods of the iron and steel sector: sinter, pig iron, DRI, ferromanganese, ferrochromium, raw steel (EAF), and hot-rolled coil (HRC).
- Purchase and Surrender of CBAM Certificates: procedures for submitting the CBAM declaration, purchasing certificates through the central platform, the buy-back mechanism for surplus certificates, and rules for surrendering certificates upon revocation of declarant status. The first CBAM declaration for 2026 is to be submitted by September 30, 2027.
The document includes four practical annexes: current default values for Ukrainian goods (direct, indirect, and total emissions with mark-ups), default values for indirect emissions and electricity, and a table of CBAM benchmarks for calculating the free allocation adjustment.
Key Dates and Obligations in 2026-2027
To ensure successful adaptation to the CBAM definitive period, it is important to follow this chronology:
- 2026: collection and monitoring of data on embedded emissions; conducting the first mandatory physical site visit by the verifier; registration in the O3CI portal and uploading verified reports.
- By October-November 2026: concluding a contract with a verifier and planning the audit schedule for 2027.
- January 1, 2027: verifiers submit reports directly through the CBAM Registry.
- February 1, 2027: start of the sale of CBAM certificates by EU Member States through the Common Central Platform (CCP).
- September 30, 2027: deadline for submitting the first CBAM declaration for 2026 and the surrender of certificates by the authorised declarant in the EU.
A Series of Methodological Guidelines for Ukrainian Business
Methodological Guidelines № 3 is the final document in a series of three specialised editions developed by Biomass-Carbon LLC to support Ukrainian exporters. Below is a brief overview of the previous parts:
Methodological Guidelines № 1 «General Provisions and Regulatory Framework of the Carbon Border Adjustment Mechanism (CBAM)»: general provisions and the CBAM regulatory framework: from Basic Regulation (EU) 2023/956 and Amendments 2025/2083 to implementing acts regarding the Registry, authorisation of declarants, and principles of interaction between EU authorities and economic operators.
Check out the methodological guidelines №1 (in Ukrainian)
Methodological Guidelines № 2 «Technical Guidance on Monitoring and Calculation of Embedded Emissions for Operators of Installations»: technical guidance on monitoring and calculating embedded emissions for installation operators: production routes, system boundaries, methodology for direct and indirect emissions, and requirements for measurement systems.
Check out the methodological guidelines №2 (in Ukrainian)
The publication was prepared within the framework of the project “Technical Assistance for CBAM good exports from UA to EU“, which is implemented with the support of the Ministry of Foreign Affairs of the Kingdom of the Netherlands and the Netherlands Enterprise Agency. Funding is provided by the Private Sector Development Program of the Netherlands Enterprise Agency/The Netherlands Enterprise Agency.
