Start of CBAM Inspections by the DEHSt: What Companies Need to Know Now

With the start of CBAM’s transitional phase, it was only a matter of time before authorities would step up enforcement. That moment has now arrived. In Germany, the German Emissions Trading Authority (DEHSt) has begun actively enforcing reporting obligations. Some companies have already received official notices. This marks a shift: the CBAM Regulation is no longer just a theoretical framework-it is now being applied. For affected companies, this should be a clear wake-up call to review their internal processes and ensure they are meeting the requirements.

Correction Procedure Initiated

The focus at the moment is the so-called correction procedure. It is a mechanism defined in the CBAM Regulation to allow companies to rectify missed or incomplete quarterly reports. The DEHSt is using this tool for the first time, requesting that companies submit reports for past quarters that they have failed to file. These requests come with firm-and in our view, quite short-deadlines. If these are not met, the authority may initiate formal sanction procedures. It is now clear that violations will not go without consequences.

Possible Consequences for Non-Compliance

There is a risk of substantial fines. These can reach up to €50 for each tonne of CO₂ emissions that is not reported or reported incorrectly. If several reports are missing or incomplete, this can quickly add up to significant amounts. Another major risk lies in the company’s ability to remain a registered CBAM declarant. Without this status, it will not be possible to import CBAM-covered goods into the EU starting in 2026. The regulation explicitly requires consistent and accurate reporting as a prerequisite for approval. Violations may therefore have a direct impact on a company’s ability to continue trade.

Action Required Now

For companies that have not yet submitted CBAM reports, now is the time to act. The DEHSt's requests are not just warnings-they also present an opportunity to catch up and avoid more serious consequences. Companies that have already submitted reports should also take this moment to internally review them. Incomplete or incorrect submissions may also be sanctioned. The quality and traceability of the reported emissions data, as well as the consistent application of reporting rules, are key.

Long-Term Implications for Corporate Strategy

This is not just about current reporting obligations. The oversight that has now begun will only become more comprehensive. By 2026, companies will face additional duties: third-party verification of emissions data, certificate management, and financial settlement of CO₂ costs. Those already struggling with reporting today are likely to face greater challenges down the road. CBAM compliance should be fully integrated into internal control systems-ideally through digital solutions and well-structured processes.

Conclusion

The DEHSt’s formal notices represent a turning point in the implementation of CBAM. The time for waiting is over. Companies that have ignored their obligations should act now. Those that have reported should double-check the accuracy and consistency of their data. Expectations around transparency and accountability will continue to rise in the coming months. Companies that take action early can avoid sanctions and build the foundation for a robust and efficient CBAM strategy.

Support with Implementation

If you need support in preparing or correcting your CBAM reports or in reviewing your internal processes for CBAM readiness, feel free to contact us directly at helge@kolum.earth. We’ll help you set up your reporting safely and efficiently.