National authorities in Denmark and Germany are signalling that importers may have until 31 March 2026 to apply for authorization as CBAM importers.
From 1 January 2026, CBAM formally applies. But if the Omnibus simplification package is adopted as expected this autumn, companies that submit their application before 31 March could continue importing while approval is pending.
This is not yet confirmed in EU law, but both the Erhvervsstyrelsen in Denmark and the DEHSt in Germany are preparing businesses for such a transition period.
However, neither the EU’s omnibus proposals nor provisions we’ve seen explicitly address extending the authorization application deadline to March 31, 2025 or allowing imports while waiting. That appears to be national-level guidance, reflecting local implementation during the legislative transition.
Why this matters
If this extension is confirmed in the final Omnibus text (expected September 2025), it buys importers three extra months to get their applications in order. Miss the 31 March 2026 deadline, and you risk immediate disruption: imports will stop at the border.
It also means that authorization becomes the single most important compliance step in early 2026. Benchmarks, default values, and the ETS price for 2026 are still pending, but none of that matters if your company isn’t even authorized to import.
- Deadline shift: A possible three-month extension eases the pressure but doesn’t remove the risk.
- Hard stop: Miss 31 March 2026 and you lose the right to import CBAM goods.
- Big picture: Benchmarks, default values, and ETS prices for 2026 are still pending, but authorization is the gatekeeper to market access.
Timeline to watch
A March 31, 2026 “safe harbor” appears to be de facto in Germany and Denmark but not (yet) an Omnibus headline. The EU simplification brings broad relief, yet authorization timing remains a national implementation detail, at least until explicit confirmation appears in the final Omnibus text expected around September.
- September 2025 – Final Omnibus text expected.
- 1 January 2026 – CBAM rules go live.
- 31 March 2026 – Expected last date to apply as Authorized Importer without disruption.
Do not underestimate the timeline. Authorities have up to 120 days to review your file. Starting now might already be too late.
Can your business survive being completely cut off from its suppliers? If you are not already deep in the authorization process, you are critically behind. For immediate help, you should review our core CBAM services.
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