Buying and repurchasing CBAM certificates: the draft on the central platform is here

The Commission sets out the rules for certificate trading

On 9 July 2026, the European Commission published a draft delegated regulation setting out how authorised CBAM declarants will buy and repurchase CBAM certificates from 1 February 2027. The draft gives concrete shape to Article 20 of the CBAM Regulation and describes the technical and financial foundation of certificate trading. Those affected can submit feedback via the Commission's portal until 6 August 2026.

Two separate systems for the registry and the platform

The purchase runs through two separate systems. The familiar CBAM registry manages the issuance, holding, surrender and cancellation of certificates. A new common central platform handles only the financial transaction, meaning the payment and settlement of purchases and repurchases. The Commission establishes this platform through a joint procurement procedure with the Member States, whose agreement entered into force on 16 December 2025. The declarant initiates the purchase in the registry, the platform executes the payment, and only after confirmed payment are the certificates created in the registry. Buying certificates is therefore a two-stage process across two connected systems.

Five cents per certificate

The fee for operating the platform is fixed in the draft. It is set at EUR 0.05 per certificate sold, irrespective of the certificate price and the selling Member State, and is multiplied by the number of certificates purchased. It is charged only on purchase, not on repurchase, in order to avoid double charges. During the first procurement contract, which runs for no more than five years, the Union budget initially bears the platform costs, and the fees collected flow monthly to the Commission. Measured against the certificate price, which tracks the weekly ETS average, this amount is small. It is nonetheless a new cost item that grows in line with import volume.

The purchase cannot be corrected after the fact

The declarant enters a purchase request in the registry, for a round number between one and 99,999 certificates. Payment is made exclusively in euro and is settled the same day in cleared funds. Once entered, a purchase request can no longer be amended. It can only be withdrawn as long as payment has not yet been made on the platform. The certificates appear in the account only after payment is confirmed. CBAM declarants should check the quantity and the details carefully before submitting, since no later correction is foreseen.

Repurchase only once a year, on three fixed dates

For the repurchase of excess certificates, the draft is considerably more restrictive. A CBAM declarant may submit only one repurchase request per year, and once entered it is irrevocable and can no longer be amended. A precondition is that the certificates for the previous year were surrendered on time by 30 September. The volume eligible for repurchase remains capped at the limit set out in Article 23(2) of the CBAM Regulation. Requests are approved on three fixed dates, on 1 April, 1 July and 1 November, each within 42 calendar days. Repurchase takes place at the same price as the purchase and likewise in euro, which rules out exchange-rate effects. Managing excess certificates thus becomes a once-a-year planning decision, and an over-purchase can no longer be unwound flexibly during the year. Accurate calculation is therefore essential here.

Buying becomes a financial and forecasting task

For affected companies, the draft shifts certificate buying from a pure compliance step towards a task for financial planning and demand forecasting. Because payment is made in euro on the same day and certificates appear in the account only afterwards, CBAM declarants must designate a euro bank account and keep the necessary liquidity available. Since repurchase is possible only once a year and only up to a limit, buying too generously ties up capital that can no longer be released during the year, and approval can take up to 42 calendar days. A reliable forecast of certificate needs thus becomes the central lever for avoiding both over- and under-coverage. In practice this means mapping the two-stage process across the registry and the platform internally, setting clear approval steps for the irrevocable purchase requests, and clarifying responsibilities between procurement, compliance and finance early on.

The consultation runs until 6 August

The draft is a delegated act and is open for public feedback until 6 August 2026. During this period, companies and associations can submit written comments via the Commission's portal. The Commission may then adjust the text before it is formally adopted, after which Parliament and Council have a period to object. For declarants this is the opportunity to flag practical weaknesses in the purchase and repurchase mechanics, such as the lack of in-year flexibility on repurchase, while the text is still open.

Outlook

The feedback period ends on 6 August 2026, with comments submitted via the Commission's portal until then. Before sales start on 1 February 2027, the central platform must also be in place through the joint procurement procedure. We will continue to monitor these developments for you.

Support

If you would like to understand how the new rules on buying and repurchasing CBAM certificates affect your CBAM strategy, for example the liquidity planning for same-day purchase or the forecasting of your certificate needs from February 2027, please get in touch at helge@kolum.earth.