The EU Carbon Border Adjustment Mechanism (CBAM) entered its definitive period on 1 January 2026, creating reporting, evidence and financial obligations in respect of 2026 imports of electricity into the EU from third countries covered by CBAM. Sales of CBAM certificates covering 2026 imports begin in 2027, while the first annual CBAM declaration and surrender of certificates for 2026 imports are due by 30 September 2027 for the relevant authorised CBAM declarants.
This briefing article prepared by VIS explains why CBAM for electricity requires targeted preparation and a clear strategy for importers and traders, given the distinctive nature of electricity as an imported good. The article identifies the main CBAM issues that may be relevant to electricity-import arrangements, including declarant responsibilities, potential data and compliance gaps, cost exposure and implementation risks.
Drawing on our experience supporting the European Commission during 2024–2025 on the operationalisation of CBAM for electricity imports, the article explains how VIS can support clients through readiness and strategy reviews, actual-emissions claim support, and advisory work on applicable default values and potential alternative emission-factor scenarios. This support can help clients assess their exposure, evaluate risks and available options, and prepare a practical CBAM strategy and action plan.
The article can be accessed by clicking here