Companies importing goods covered by the Carbon Border Adjustment Mechanism (CBAM) in 2026 will be subject to four quarterly certificate prices rather than a single annual carbon price. The European Commission will assign a separate price to each quarter of import, creating four distinct carbon-cost vintages within the first year of the definitive regime. The approach affects margin analysis, supplier comparisons, financial provisioning and year-end reporting.
The published certificate prices are €75.36 per tonne of CO₂ for the first quarter, €75.28 for the second and €82.32 for the third quarter. The fourth-quarter price is scheduled for publication on 4 January 2027. For 2026 imports, certificate requirements are calculated from embedded emissions recorded for each quarter, with the corresponding quarterly price applied when certificates become available for purchase in 2027.
Quarterly pricing links certificate costs to import dates
The quarterly pricing structure means carbon costs can change even when physical volumes remain stable. Deliveries that fall into different pricing periods can lead to different certificate costs despite unchanged product specifications and emissions intensity. This makes the timing of import relevant for cost calculations tied to CBAM certificates.
A shift to a supplier with lower verified embedded emissions may offset part of an increase driven by the EU carbon market. Procurement and finance teams are expected to keep the import date and the related emissions information together rather than averaging exposure across the year. This is intended to preserve a link between physical deliveries and the quarterly pricing periods used for certificate cost.
CBAM exposure builds before the first annual deadline
Exposure from 2026 imports is accumulating even though the first annual CBAM declaration and certificate-surrender deadline is 30 September 2027. Management reporting is expected to provide a live connection between physical imports, estimated certificate requirements and anticipated cash outflows. Reliance solely on a year-end sustainability report is described as insufficient for this purpose.
The mechanism also separates timelines for imports, emissions verification and certificate pricing. Goods may enter the EU before verified actual emissions data are available, while the applicable certificate price follows the quarterly schedule. Companies therefore need a provisional emissions assumption and an update process once verified data become available.
Accruals and reconciliation support audit trails
Recognising exposure only after final verification could result in businesses identifying substantial historical costs after customer prices have already been agreed. A disciplined accrual process allows finance teams to recognise expected liabilities while clearly marking assumptions that remain provisional. This approach is aimed at aligning accounting recognition with CBAM compliance timelines.
A control file is described as needing quarter-by-quarter reconciliation from customs entries to covered quantities and specific embedded emissions. It should also include any applicable free-allocation adjustment, any eligible deduction for carbon prices paid abroad, and the relevant certificate price. The stated objective is a consistent audit trail for financial provisioning and the subsequent CBAM declaration.
Quarterly certificate prices affect contract settlement terms
The quarterly mechanism can change outcomes under commercial agreements that use fixed CBAM surcharges agreed at the start of the year. Unexpected gains or losses may arise if EU ETS prices move or if verified emissions differ from initial estimates used during contracting. This creates sensitivity between contract assumptions and later verification results.
More robust contracts can specify a calculation formula linked to official certificate prices and agreed emissions data, followed by an adjustment once verification is complete. Agreements are expected to distinguish provisional information from verified values and define which changes trigger a price true-up. The source example includes suppliers providing estimated emissions intensity before submitting accredited verification reports.
The same example also notes that official certificate prices may change between contract negotiation and settlement. Clearly defined adjustment mechanisms are described as reducing disputes while allowing finance teams to estimate costs without waiting for every compliance input to be final. This includes handling differences between initial estimates and later verified figures alongside quarterly certificate pricing.
Implications for exporters preparing offers in Serbia and Western Balkans
Exporters in Serbia and other parts of the Western Balkans can apply similar approaches when preparing offers for EU customers. Instead of quoting a generic CBAM premium, they can show how verified emissions intensity affects estimated certificate quantities while identifying the official EU certificate price as an external market variable. This separates supplier performance factors from carbon market inputs in offer calculations.
The approach is also described as supporting more consistent supplier comparisons when products arrive in different quarters or use different emissions assumptions. Finance teams are expected to maintain separate quarterly cost records for 2026 rather than relying on a single annual proxy before final calculation requirements are met. Contracts covering late-year deliveries should specify how the relevant import quarter is determined and how subsequent emissions corrections or other adjustments are handled.
Linking customs, procurement and finance records
A practical implementation test is whether a company can explain its calculation to both an auditor and a commercial manager using the same underlying records. CBAM documentation should connect purchasing, production, customs and finance rather than operate as a separate compliance file. Routine operational data, controlled assumptions and documented fallback methods are intended to allow updates when suppliers, transport routes, prices or legal requirements change.
The minimum decision file should link customs volumes, the emissions basis, certificate prices, expected cash timing and contractual cost pass-through, while identifying who approves each assumption. A fallback should also be documented where preferred emissions treatment cannot be substantiated. Although this alternative may be commercially less favourable, defining it early is described as reducing risk when claims are challenged by a verifier, customs authority or authorised declarant.
Consistent records are described as making later price adjustments, verification changes and management reporting easier to defend as CBAM’s financial effects grow. With four quarterly certificate prices, the quarter of import becomes an important variable in carbon-cost and invoice economics during 2026.