How to Submit a CBAM Application: Information and Documents Required
Following our recent blog post outlining the key aspects of becoming an authorised CBAM declarant, this week we're focusing on the CBAM authorisation submission process and the documentation applicants must prepare.
The first step in this process is applying to become an Authorised CBAM Declarant (CBAM application). As a reminder, without this authorisation, businesses exceeding the de minimis mass threshold of 50 tonnes will not be permitted to import CBAM goods into the EU from 2026 onwards.
The CBAM application must be submitted electronically via the CBAM Registry in the Member State of establishment. Specifically, applications must be submitted through the Authorisation Management Module (AMM), a new section of the CBAM Registry launched by the European Commission on 31 March 2025. The AMM facilitates the entire process — from the initial authorisation request, through consultations between competent authorities and the Commission, to the final decision to grant or refuse the CBAM authorisation.
While some Member States, such as the Netherlands and Spain, already allow submissions, others have yet to open the application process.
Activity Details
When submitting a new application, applicants are required to provide details about their main economic activity, along with information on the imported CBAM goods. This includes the type and description of the goods, an estimate of the quantity imported during the calendar year in which the application is submitted, the value of those goods, and the same information projected for the following calendar year.
Applicants must also specify the Member State(s) in which they acted as an importer or declarant in customs declarations for CBAM goods during both the previous calendar year and the year of the application.
In addition, applicants must upload certification from the relevant tax authority and complete a declaration of honour. This declaration confirms that, during the five years preceding the application year, the applicant has not been involved in any serious or repeated infringements of customs legislation, taxation rules, or market abuse regulations, and has no record of serious criminal offences related to their economic activity.
Financial and Operational Information
The final stage of the application process requires providing certain financial and operational details, such as:
- The legal status and size of the entity under which the applicant intends to act as an authorised CBAM declarant,
- The number of staff dedicated to CBAM reporting,
- The internal controls in place to prevent, detect, and correct errors in CBAM declarations and certificate management, and to prevent and detect illegal or irregular transactions.
Applicants must also indicate whether their organisation has been established for more or less than two years, as this determines whether a financial guarantee is required.
Additionally, applicants must provide financial figures for the three most recently closed financial years, including net profit/loss, turnover, current assets, and current liabilities.
Final Submission
Before submitting the application, applicants have the option to save it as a draft and resume completion at a later stage.
Once all required information has been provided, the application can be formally submitted to the national competent authority (NCA), which will then carry out the necessary steps to either grant or refuse the CBAM authorisation.
Need help submitting your CBAM application?
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