CBAM communication template: what the Excel file holds, and what changes in 2026

The template is an Excel workbook developed on behalf of the European Commission by its consultants, Umweltbundesamt GmbH Austria. Its stated purpose is to facilitate communication between operators of installations in third countries and the declarants who report their goods. It was written for the transitional period under Implementing Regulation (EU) 2023/1773, when importers filed quarterly reports and paid nothing.

The operator enters installation-level data once; the template's own formulas attribute emissions to production processes, compute specific embedded emissions per good and fill the summary sheets that the importer needs. The Commission published sector examples alongside it for cement, aluminium, fertilisers, hydrogen and steel. The version in circulation at the end of the transitional period is 2.1.1, dated 13 December 2024; the version number is on the first sheet.

The operator of the installation: the company that runs the plant where the goods are made. Only the operator has the meter readings, fuel invoices, production logs and process data the workbook asks for. The importer receives the result; it cannot produce it.

A trader or a sales company does not fill it in either. Where goods pass through intermediaries, the Commission's guidance expects the request to be forwarded to the operator of the installation that produced them.

From 1 January 2026 the legal basis is Implementing Regulation (EU) 2025/2547 on the methods for calculating embedded emissions. Three things follow:

• A mandatory report. Where embedded emissions are based on actual data, the operator prepares an annual operator’s emissions report and a summary of it, using the template set out in points 1.1 and 1.2 of Annex IV to IR (EU) 2025/2547. Article 10 makes the template mandatory. For electricity on actual values a declarant-specific addendum is added.
• Verification. Actual values can be used only if verified by an accredited verifier under Article 8 of Regulation (EU) 2023/956, with a positive verification report. National authorities have warned declarants that simply completing the transitional communication template is not enough in the definitive period.
• A calendar year. The reporting period is the calendar year of production, and the report is compiled after the year closes.

The Commission's definitive-period guidance documents of 14 August 2026 state that the series is accompanied by an electronic template for operators to communicate information to declarants and the CBAM Registry, and that the Commission's Excel template also generates the summary report automatically.

Many EU importers send their own CBAM supplier questionnaire or data collection template before, or instead of, the Commission file. Formats vary. The substance does not, because it comes from the same law: installation identity, goods by CN code, production routes, attributed emissions, precursors, electricity and its emission factor, and the reporting period.

Answer them from one dataset. If the installation-level record is complete, every questionnaire is an export of it; if it is not, each one becomes a separate estimate that a verifier will later have to reconcile. The document that settles the matter for the declaration is the verified operator’s emissions report.

• Company totals instead of installation data. Emissions are monitored per installation and attributed per production process. Two plants at one address are still two installations.
• Production processes drawn wrongly. The transitional template asked for separate processes where separate routes made the same goods category. Under IR (EU) 2025/2547 a process covers goods with the same functional unit and, where relevant, all production routes used in the installation. Carry the 2026 structure forward, not last year’s.
• An electricity factor with no source. The workbook asks for the emission factor of consumed electricity and the method by which it was determined. An EU-average factor entered without a source is exactly the kind of figure a verifier will question.
• Precursors without origin. Every purchased precursor needs its country, its mass and whether its embedded emissions are measured or default. A precursor of unknown origin falls back to the Commission’s default for unknown origin, which is set high.
• Annual guesses instead of records. Monthly meter readings and invoices are what a verifier samples. Figures typed in once a year rarely survive the visit.
• Treating the file as final. Until a verifier has issued a positive report, the numbers are the operator’s draft, however carefully the workbook was filled.

The first operator’s emissions reports cover calendar year 2026. A monitoring plan, monthly records and a verifier booked early are the difference between a report in the first months of 2027 and a declarant forced onto defaults. The Commission's guidance advises contracting a verifier early in the reporting period, because much of the verification work, starting with the monitoring plan, can be done during the year.

The steps below follow the order the regulation implies.