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The UK Government has released a significant update to the developing Carbon Border Adjustment Mechanism (CBAM). On 9 April 2026, HMRC published a new set of draft secondary legislation that sets out how embedded emissions must be monitored and verified for goods imported into the United Kingdom from 2027.

This is the most detailed material published so far on the UK CBAM monitoring framework. It provides enough clarity for importers and overseas suppliers to begin preparing their systems and data collection processes.

Source: HMRC Draft Regulations (Emissions and Verification), 9 April 2026

Key Points from the New Draft Legislation

Alignment with the EU CBAM Approach

The UK has chosen to follow the structure and principles used in the EU CBAM for emissions monitoring and verification. This includes:

• Installation level monitoring
• Activity data requirements
• Calculation methods for direct emissions
• Verification principles and data quality expectations

This alignment reduces complexity for businesses that already supply into the EU market.

Source: HMRC Draft Regulations (Emissions and Verification), 9 April 2026

Verifier Accreditation: A Key Difference from the EU

One of the most notable divergences from the EU system is the UK’s approach to verifier accreditation.

The UK will allow verification by organisations accredited by any national accreditation body that is a signatory to:

• The European co‑operation for Accreditation (EA)
• The International Accreditation Forum (IAF)
• The International Laboratory Accreditation Cooperation (ILAC)

This means verifiers do not need to be accredited in the UK. This is expected to ease capacity constraints that the EU is already experiencing.
Source: HMRC Draft Regulations (Emissions and Verification), 9 April 2026

How the UK CBAM Will Work

The draft legislation confirms the core mechanics of the UK CBAM, which will apply from 1 January 2027.

CBAM Liability Calculation

Your CBAM liability will be calculated as:

• Embedded emissions

multiplied by

• A quarterly CBAM rate set by HMRC and linked to the UK ETS price

minus

• Any Carbon Price Relief for carbon prices already paid in the country of production

Source: HMRC Policy Summary

Registration Requirement

Importers must register with HMRC if the annual value of their CBAM goods exceeds £50,000.

First Accounting Period

• Covers the full year 2027
• Return and payment due by 31 May 2028

Default Values and Actual Emissions

From January 2027, importers may choose between:

• Default emissions values published by HMRC
• Verified actual emissions from overseas suppliers

Default values and several remaining implementing rules are expected before the end of 2026.
Source: Fresh Produce Consortium summary of HMRC consultation, 9 April 2026

Supporting Materials Published by HMRC

HMRC has also released communication resources to help importers engage their supply chains. These materials are intended to support early preparation and ensure suppliers understand what will be required.
Communications resources

Consultation Timeline

The consultation on this new draft legislation is open until 21 May 2026. HMRC is inviting feedback from:

• Importers
• Overseas producers
• Verifiers and accreditation bodies
• Trade associations
• Technical specialists

Responses can be submitted by email as outlined in the consultation documents.

What Businesses Should Do Now

With the publication of these detailed drafts, businesses can begin preparing for UK CBAM implementation. Key actions include:

• Reviewing the monitoring and verification requirements
• Assessing whether suppliers can provide verified actual emissions
• Identifying which suppliers already use accredited verifiers
• Preparing internal systems for 2027 reporting
• Engaging supply chains early using HMRC’s communication materials