Skip to content

ESRS and CSRD

Consultancy

UK SRSThe UK Sustainability Reporting Standards, ESOS, SECR and TCFD, read against the published text.HUBUK SRS GuideAn independent reference guide to UK SRS, ESG, TCFD, SECR, ESOS and the global standards.YOU ARE HEREGlobal Reporting StandardsSustainability reporting standards worldwide: ISSB, the EU CSRD after Omnibus I, California SB 253 and SB 261, and UK SRS.UK SRS StandardsUK SRS S1 and S2 at the provision: reliefs, comply or explain, and the FCA statements.ESOS QuestESOS Phase 4 in depth: qualification, the audit, sign-off, action plans and penalties, read against the Regulations.SRS EngineeringThe data build behind a UK SRS report: metrics, owners, controls and timing.SRS ReportWhat a UK SRS report contains, how it is assembled, and how to read one.UK SRS ReportAnalysis and commentary: CDP, the DESNZ emission factors, SECR and ESOS, with every figure cited.UK SRS NewsThe cluster's news publication, and what a UK SRS report contains.UK SRS DeliveryTemplates, costs, ESOS delivery guides and readiness assessment.UK SRS FinanceFinanced emissions, PCAF and IFRS S1/S2 for banks, insurers and asset managers.SECRStreamlined Energy and Carbon Reporting: deadlines, thresholds, eligibility and guidance.Carbon CreditsCarbon credit ratings, risk analysis, valuation and market structure.Environmental RegimesThe eight UK environmental reporting regimes, their thresholds, deadlines and regulators.UK SRS ServicesThe services arm: ESOS, SECR, net zero and sustainability consultancy.

Standards and reporting

UK CBAM

UK CBAM is an import tax on specified goods rather than a general sustainability reporting framework, so preparation starts with classification, importer responsibility and evidence.

What is UK CBAM?

UK CBAM taxes emissions embodied in specified imports and begins on 1 January 2027 Finance Act 2026 Part 5 HMRC preparation guidance.

Start with the importRequirements and evidence

Module 01 / 04

Goods

Check the imported product rather than only its industry label.

Read the detailed guidance and evidence

A company can need sustainability information for several purposes while the UK CBAM calculation follows its own goods and emissions rules.

The same supplier might provide a corporate carbon footprint and product information, but those records answer different questions.

Our sustainability reporting standards overview explains the wider reporting landscape without treating UK CBAM as another disclosure standard.

Which imported goods are covered?

The five sectors are aluminium, cement, fertiliser, hydrogen, and iron and steel, but inclusion depends on the listed commodity codes and exceptions Schedule 16.

Editorial classification prompts rather than a replacement tariff list Statutory goods schedule.
SectorFirst scope checkAvoid the shortcut
AluminiumMatch the imported good to Schedule 16Assuming every aluminium-containing item is covered
CementCheck the specific classificationTreating all construction materials as cement
FertiliserReview the code and any stated exceptionUsing a supplier category instead of the goods classification
HydrogenCheck the imported product classificationTreating all energy imports as covered
Iron and steelReview the relevant code and exceptionsIgnoring excluded scrap classifications
Read the detailed guidance and evidence

Glass and ceramics were not included in the final five-sector scope, despite appearing in earlier policy discussion Final policy scope.

Keep the classification decision and its supporting documents so it can be reviewed when products or codes change.

How should an importer check classification?

Use the statutory goods list and its exceptions to review each relevant commodity classification before applying the registration tests Schedule 16 paragraphs 1–2.

Identify the productRequirements and evidence

Module 01 / 04

Description

Retain a sufficiently detailed product description.

Read the detailed guidance and evidence

A purchase-order label such as metal components is not detailed enough to establish the legal classification by itself.

Ask the customs or product specialist to explain borderline classifications rather than filling an evidence register with guesses.

Use ESG data collection controls for ownership and provenance while retaining UK CBAM’s own definitions.

How does the £50,000 threshold work?

Registration is triggered at £50,000 or more under either the backward-looking or forward-looking statutory test Schedule 17 paragraph 2.

Registration turns on the value of CBAM goods, not the EU scheme’s mass threshold Statutory tests and adjustments.
TestWhen it is assessedWhat is compared
Backward-lookingFirst day of a monthAggregate value of relevant imports during the preceding 12 months
Forward-lookingWhen expected imports meet the testAggregate value expected before the end of a 30-day period
Exact boundaryAt £50,000The statutory wording includes equality
Special casesWhen applying the testsCheck disregarded goods and special-procedure valuation rules
Read the detailed guidance and evidence

Monitor both tests instead of checking only an annual purchasing total.

The legislation provides specific treatment for UK-origin and returned goods and certain goods under customs procedures, so an exemption decision needs its own evidence Paragraph 2(3).

Check the valuation section of HMRC’s policy summary before using an invoice amount in a threshold calculation Value of CBAM goods.

Who is responsible for UK CBAM?

The liable person is the importer under the policy’s customs-declaration rules, rather than automatically the overseas producer Liable person.

Assign the responsibilityRequirements and evidence

Module 01 / 04

Importer identity

Identify whose name or behalf the declaration uses.

Read the detailed guidance and evidence

Do not assume that a supplier’s promise to send a carbon number transfers the importer’s liability.

HMRC says a tax agent cannot register on behalf of the liable person and does not take on the liability Tax agents.

A carbon consultancy brief should distinguish help collecting evidence from tax advice or an undertaking to perform the importer’s legal obligations.

When are registration, returns and payment due?

The first-cycle rules separate the 2027 tax period from the 2028 registration and filing dates Regulation 2.

The transitory regulations modify the ordinary rules rather than creating one permanent annual deadline Regulations 2–3 Registration opening.
MilestoneDate or periodImporter preparation point
Tax begins1 January 2027Start retaining relevant import evidence
First accounting period1 January–31 December 2027Reconcile the full first-year population
Registration service opens1 January 2028Do not mistake the later service opening for a later tax start
Registration for those triggering in 2027By 31 January 2028Use the transitory deadline
First return and paymentBy 31 May 2028Both relate to the period ending 31 December 2027
Following transitory quartersCheck the specific statutory datesDo not reuse the first-year deadline permanently
Read the detailed guidance and evidence

For the quarter ending 31 March 2028, the transitory return and payment deadline is 31 July 2028 Regulation 2.

For the quarter ending 30 June 2028, it is 29 September 2028 Regulation 2.

Which emissions information should suppliers provide?

Actual-data reporting needs the relevant verified emissions intensity and verification evidence rather than an unsupported corporate emissions total Using actual emissions data Emissions and verification rules.

Ask for the right evidenceRequirements and evidence

Module 01 / 04

Good

Identify the CBAM product the intensity describes.

Read the detailed guidance and evidence

The system-boundaries document identifies relevant direct emissions, production processes and precursor goods for UK CBAM Regulation 2 System-boundaries reference.

An independently reviewed corporate inventory does not automatically supply the product-level evidence required for this tax.

Use the sustainability assurance guide to understand why a verification report’s scope and criteria need to match the information being used.

Which year’s verified data can be used?

For the import-date method, the permitted monitoring year changes after 2027, and a separate production-date option also exists Regulation 9.

Read the monitoring-period rule with the actual-data requirements Regulation 9 HMRC emissions-intensity guidance.
Import or methodMonitoring-period ruleEvidence control
2027 import-date methodMost recent verified year from 2027 or 2026Do not automatically choose the previous year
From 2028, import-date methodMost recent verified year from the two calendar years before importRetain the chosen report and why it is the most recent available
Production-date methodCalendar year in which the good was producedConnect the good to its production period
Relevant precursor goodsReview the specific monitoring-period provisionsDo not assume every input shares the same evidence
Read the detailed guidance and evidence

The monitoring period is not simply the date a supplier emailed its spreadsheet.

Record whether the file represents a verification report, a verification summary or an unverified estimate before deciding how it can be used.

How should the calculation inputs be organised?

HMRC’s policy summary describes liability as the CBAM charge less Carbon Price Relief, with the charge based on embodied emissions and the relevant CBAM rate Calculating liability.

Keep inputs separateRequirements and evidence

Module 01 / 04

Quantity

Retain the imported weight and product reference.

Read the detailed guidance and evidence

Do not use a generic corporate conversion factor as if it were a UK CBAM default or sector rate.

Open the current rate guidance and the appropriate default-value source before building a calculation file Rate guidance Default-value source.

The evidence register should allow a reviewer to replace one input without losing the provenance of the others.

Which official documents should the reviewer open?

Read the governing rules alongside the current HMRC method guidance and retain the version used rather than relying on an old consultation.

Method-navigation checklist Goods Threshold Dates Emissions Rates Defaults Relief scheme information.
Reader questionPrimary sourceWorking record
Is the good included?Schedule 16Classification decision
Has registration been triggered?Schedule 17 paragraph 2Dated threshold review
Which first-cycle deadline applies?S.I. 2026/830Return calendar
Which emissions method applies?S.I. 2026/995 and reference documentMethod and boundary note
Which rates or defaults are relevant?Current HMRC rate and default guidanceExact source and version
Can relief be claimed?HMRC qualifying-scheme information and applicable relief rulesClaim evidence and review
Read the detailed guidance and evidence

The rate and default links serve different purposes and should not be merged into one undated carbon-price field.

Check the status of each notice on the HMRC landing page before presenting a draft or future instrument as currently effective law Notice status.

What needs checking before claiming relief?

Carbon Price Relief concerns a qualifying carbon price and supporting evidence rather than an automatic deduction for any overseas environmental payment Carbon Price Relief Qualifying scheme information.

Document the claimRequirements and evidence

Module 01 / 04

Scheme

Identify the relevant qualifying carbon-pricing scheme.

Read the detailed guidance and evidence

A supplier’s general statement that it pays carbon costs is not a complete relief evidence pack.

The UK and EU mechanisms should be assessed separately rather than assuming an EU filing satisfies the UK tax.

Use the government’s current scheme material and relevant relief rules for the actual claim instead of copying a list from an old article.

How might a small importer prepare?

This fictional example tests evidence organisation and the exact registration boundary without calculating a real tax liability.

Original fictional case; the £50,000 boundary illustrates the statutory test and is not an assessment of a real importer Paragraph 2(2).
Fictional stageWorking decisionEvidence retained
Product reviewSpecialist confirms the good is within Schedule 16Product and classification note
Threshold reviewExpected relevant imports total £50,000 within 30 daysDated forecast and valuation working
Responsibility reviewIdentify the importer and customs supportDeclaration and responsibility note
Supplier requestAsk for relevant intensity and verification evidenceRequest log and received reports
Calculation preparationLeave rate and intensity pending until reviewedVersioned input register
Return preparationReconcile imports to the accounting periodEvidence index and unresolved items
Read the detailed guidance and evidence

The forecast reaching exactly £50,000 meets the stated value boundary, assuming the goods and values satisfy the statutory test Paragraph 2(2)(b).

A blank intensity field means evidence is pending, not that the goods have zero emissions.

What makes the importer handover useful?

Keep the import population, threshold reviews, emissions references and open decisions together so the return preparer can trace each input.

Make it reviewableRequirements and evidence

Module 01 / 04

Population

Reconcile relevant goods against customs and purchasing records.

Read the detailed guidance and evidence

HMRC’s record guidance is the place to check the detailed records required for the importer’s circumstances Keeping records.

A sustainability data platform should be tested for exporting those references rather than only displaying an aggregated footprint.

Software or a checklist does not determine the tax treatment of a complex import or guarantee that a return is correct.

How do you run a UK CBAM preparation project?

Use this editorial nine-step workflow to organise importer preparation while specialist advice addresses individual tax questions.

  1. 101

    Map the imports

    Identify potentially relevant products and customs records.
  2. 202

    Review classification

    Check codes and statutory exceptions.
  3. 303

    Confirm responsibility

    Identify the importer and supporting advisers.
  4. 404

    Assess the threshold

    Record both statutory tests and the valuation working.
  5. 505

    Set the calendar

    Separate tax start, registration and return deadlines.
  6. 606

    Request supplier evidence

    Ask for product-specific intensity and verification records.
  7. 707

    Review calculation sources

    Check the current rate, default and relief materials.
  8. 808

    Reconcile and review

    Resolve coverage gaps and document open issues.
  9. 909

    Retain the handover

    Keep the return working, evidence index and decisions together.

Can you download an editable working resource?

This original preparation resource supports evidence and review and does not establish reporting conformity.

Download importer register (CSV)

Editorial working resource, not a prescribed or government-approved form.
StepReview
AdaptSet the actual reporting basis, boundary, period and selected requirements
Retain evidenceConnect source records and judgements to each answer
ReviewResolve open issues before making the final reporting claim

Frequently asked

Questions people ask

When does UK CBAM start?

It commences on 1 January 2027 for specified imported goods.

Does exactly £50,000 trigger registration?

Yes, both statutory tests use £50,000 or more rather than more than £50,000.

Is the threshold based on an EU-style tonnage test?

The UK statutory registration tests concern the aggregate value of CBAM goods, assessed over the stated periods.

Why does registration open after the tax starts?

The first-cycle arrangements place the service opening on 1 January 2028 and give those triggering in 2027 until 31 January 2028 to register.

When are the first return and payment due?

Both are due by 31 May 2028 for the accounting period ending 31 December 2027.

Can a corporate carbon footprint replace the required import evidence?

Actual-data reporting requires the relevant CBAM emissions intensity and verification evidence under its own rules rather than an unsupported corporate total.

Book a free consultation