The UK’s final emissions and verification rules allow qualifying 2026 production data to be used for carbon calculations covering goods imported under the UK Carbon Border Adjustment Mechanism in 2027.
The Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026, S.I. 2026/995, were made on 8 September, laid before Parliament on 9 September and will take effect on 1 January 2027.
Monitoring periods set conditions for first-year data
The regulations establish requirements for the monitoring period used when calculating actual emissions. For imports during the first CBAM year, the rules can allow the use of the most recent verified calendar-year data from either the import year or the preceding year, alongside a separate route connected to the year in which the goods were produced.
The provision does not give businesses unrestricted discretion to select whichever historical dataset results in the lowest emissions calculation. The relevant monitoring-period provisions and verification requirements must still be satisfied.
This timing flexibility is important because complete data for an entire production year may not be available when the first 2027 shipments enter the UK. Where the requirements are met, a verified preceding-year dataset can provide the necessary basis for early calculations without waiting for all 2027 production records to be completed and verified.
Evidence remains central to actual-emissions claims
HM Revenue & Customs record-keeping guidance requires importers to retain evidence supporting the emissions figures used, including relevant verification documentation.
Where the required actual-emissions information or supporting evidence cannot be provided, the rules provide for the use of default values instead.
The distinction means that having a carbon dataset is not by itself sufficient. Producers need records that meet the applicable UK requirements and can support the emissions calculation when reviewed.
Six-year retention period
Records generally must be retained for six years after the relevant accounting period. Data prepared for the first year of UK CBAM therefore needs to remain accessible well beyond the initial supplier information request and be capable of supporting a later examination of the calculation.
For producers, the immediate compliance priority is the quality and verifiability of 2026 production records. For importers, the corresponding task is to establish that supplier data meets the UK’s specific requirements rather than assuming that an existing carbon report automatically qualifies for CBAM purposes.
