Across many organizations, CBAM is still approached with a familiar compliance reflex: waiting. Waiting for final rules, for formal publications, for full certainty towards 2026. For a long time, that approach was understandable. It is becoming increasingly difficult to justify.

Over recent weeks, a substantial part of the operational CBAM framework has become available. Not all of it in final form - some elements stem from draft implementing acts, annexes, consultation documents and information that has effectively “leaked” through policy processes. Taken together, however, this information is consistent, detailed and directionally clear.

What is already clear today

In practical terms, the following has now emerged:

Default values per CN code for CBAM goods, specified per country or under “other countries”.
Fixed mark-ups on default values, increasing from 2026 onwards (10%, 20% and 30%), clearly signaling that defaults are intended as an unpleasant fallback and will become structurally more expensive.
CBAM benchmarks (as well its standard values) derived from EU ETS benchmarks, including differentiation by product type and, where relevant, by production route (for example in steel and aluminum).
A defined calculation methodology for the free allocation adjustment, covering both simple and complex goods, including the treatment of precursors.
Clear conditions for using actual values: permitted only when data is traceable and verified. Where this is not the case, a mandatory fallback to default values and standard benchmarks applies.
Explicit assumptions on production periods and precursors, with goods presumed to be produced in the year of import unless proven otherwise.

Waiting is the real risk

While some of these elements are still subject to formal adoption, the structure, logic and financial mechanics of CBAM are now clear. The likelihood of fundamental changes to these principles is low. Waiting for full legal certainty increasingly means losing valuable preparation time. At the same time, practice shows that obtaining verified actual values towards 2026 is complex. Emissions data sits deep in global supply chains, suppliers are often unprepared, and verification capacity is limited. Starting late significantly increases the risk of having no viable alternative to default values.

Financial impact of CBAM

This is already becoming visible in the market. On a weekly basis, we see companies being surprised by the financial impact of CBAM, particularly in light of the recently released benchmark and default data. What was assumed to be manageable often turns out to be material once calculations are performed.

This is precisely where early action matters. Preparation does not mean locking in final answers today, but it does mean making risks transparent, quantifying potential cost exposure and understanding data and system requirements. A combination of CBAM expertise, robust calculation software and a clear risk approach is essential.

We support companies in making these questions tangible - including impact assessments, scenario calculations and the translation of emerging CBAM data into concrete financial insights. Even where information is not yet final, there is already more than enough clarity to act.