On December 10, 2025, the European Commission published Implementing Regulation C(2025) 8580, which introduces significant changes to the operation of the CBAM Register. This is not a cosmetic update—it is a fundamental overhaul of the system's architecture, changing the way CBAM responsibilities are managed.
For importers, these changes mean both new opportunities and new challenges. Let's take a look at the most important changes.
Delegating CBAM services – a new opportunity for entrepreneurs
One of the most anticipated changes is the introduction of delegated access to the CBAM Register. Until now, the authorized CBAM declarant was the only person authorized to operate in the system – even if the company used external support, ultimately every action had to be performed by the declarant themselves.
The new regulations change this situation. Pursuant to the amended Article 3 of Regulation 2024/3210, the CBAM Register will contain data on "persons delegated to act in the name and on behalf of" authorized declarants.
In practice, an authorized declarant can now formally authorize another entity—for example, a consulting firm—to perform activities in the CBAM Register. The delegated person gains access through the UUM&DS mechanism and can perform tasks such as submitting declarations, managing certificates, and communicating with competent authorities.
This solution is particularly important for small and medium-sized businesses without internal resources to manage CBAM. It's worth emphasizing that delegation does not relieve the authorized declarant of responsibility for the accuracy of the declaration – it only applies to technical access to the system.
Customs authorities enter the CBAM Register
The second fundamental change concerns the role of customs authorities. The new Article 11(5) explicitly states: "Customs authorities shall use and have access to the CBAM Register for the purpose of validating authorizations and providing additional customs data."
This seemingly technical provision has far-reaching consequences. Until now, the CBAM Register and customs systems operated as separate entities. From now on, customs authorities become full users of the Register, with the ability to directly verify authorization status and enter customs data.
Combined with the Customs Communication Regulation, which mandates weekly reporting of imported goods to the CBAM, a coherent control system is being created. For importers, this means one thing: the era of "two separate worlds"—customs and CBAM—is finally coming to an end.
Automatic monitoring of the de minimis threshold
Regulation 2025/2083 introduced a single mass-based threshold for CBAM, below which CBAM obligations do not apply. The new regulation specifies a mechanism for monitoring it.
Under the new Article 5(3), when the competent authority determines that the de minimis threshold has been exceeded, customs authorities are automatically notified by the CRMS2 system via the CBAM Register. Monitoring is automatic, without manual verification – the system tracks import volumes and immediately initiates procedures when the threshold is exceeded.
For companies teetering on the edge of the threshold, this is important information: there is no way to "slip through" the system.
Verifiers and independent persons in the Register
Another change concerns the registration of verifiers and so-called independent individuals in the CBAM Register. Previously, verifiers operated outside the system – their accreditation was managed by national accreditation bodies, but they were not formally registered in the central Register.
Under the amended Article 10, verifiers and independent persons gain access to the Register via the CBAM Operators Portal. They must submit an application for registration to the competent authority of a Member State within two months of receiving accreditation, but no earlier than December 1, 2026.
The application must include the accreditation name and number, the scope of accreditation relevant to CBAM, the country of establishment, validity dates, and information on any administrative measures. Once registered, verifiers can use the Registry to verify information and exchange data with operators and declarants.
Full interoperability with customs systems
The Regulation updates the provisions on the interoperability of the CBAM Register with customs systems, replacing references to the repealed Regulation 2023/1070 with references to the new Regulation 2025/512.
The CBAM register will be fully integrated with key systems: UUM&DS (user management and digital signatures), EORI (economic operator verification), SURV3 (customs supervision) and CRMS2 (customs risk management).
This integration enables automated, real-time data flow. CBAM authorization can be verified directly during customs clearance, and customs clearance data is transferred to the CBAM Register without delay.
Data exchange between the Commission and national authorities
The new regulations specify the mechanism for data exchange between the European Commission and national competent authorities. Pursuant to the new Article 12(2a) and (2b), the Commission Portal will include a separate section dedicated to the tasks specified in Articles 15 and 27 of Regulation 2023/956 – reviewing CBAM declarations and monitoring circumvention of the regulations.
The Commission will record and make available to national authorities the information necessary to carry out their tasks, creating a two-way data flow ensuring consistency of control activities across the EU.
What do these changes mean for your business?
Regulation C(2025) 8580 transforms the CBAM Register from a simple database into a central hub connecting all participants in the system: authorised declarants, their representatives, installation operators, verifiers, customs authorities and the European Commission.
For importers of goods covered by CBAM, the following conclusions can be drawn from this. First, the ability to delegate CBAM management opens the door to professional outsourcing of this function, which can be particularly attractive for companies without dedicated internal resources. Second, integration with customs systems enforces absolute data consistency – discrepancies between customs declarations and CBAM declarations will be automatically detected. Third, automatic monitoring of the de minimis threshold means that companies exceeding this threshold cannot avoid the system. Fourth, centralized registration of verifiers increases the transparency of the verification process and facilitates the selection of the right partner.
The changes are coming into effect gradually – some regulations will apply from January 1, 2026, while registration of independent individuals will begin on December 1, 2026. This gives companies time to adapt their processes and structures to the new reality.
Legal basis: Commission Implementing Regulation (EU) C(2025) 8580 of 10 December 2025 amending and correcting Implementing Regulation (EU) 2024/3210 as regards the CBAM Register, issued on the basis of Article 14(6) of Regulation (EU) 2023/956.
