Abstract
<jats:sec> <jats:title>Context</jats:title> <jats:p>The EU Carbon Border Adjustment Mechanism entered its final financial phase on 1 January 2026. Industry consensus reads the phase as an import carbon tax to be managed by procuring reporting software, yet that reading misstates what the phase requires of importers in 2026.</jats:p> </jats:sec> <jats:sec> <jats:title>Findings</jats:title> <jats:p>Four themes that dominate vendor marketing are not supported by closer reading of regulatory texts. There is no CBAM certificate market in 2026; sales open on 1 February 2027. The carbon-price-paid deduction sits in Article 9, and Article 31 is the separate free-allocation adjustment. Hydrogen and electricity have no de minimis relief. Emissions-verification tooling is not high-risk AI under the AI Act as drafted. The determination of 2027 costs is the spread between verified emissions data and marked-up default values, with access to verified data rationed by operational verifier capacity.</jats:p> </jats:sec> <jats:sec> <jats:title>Implications</jats:title> <jats:p>For 2026, compliance hinges on two priorities: accurate exposure modelling and early alignment with verifiers before the first surrender on 30 September 2027. Platform procurement is secondary. To survive the framework, companies need a dynamic exposure model that updates in real time.</jats:p> </jats:sec> <jats:sec> <jats:title>Confidence</jats:title> <jats:p>CONFIRMED on the legal architecture, the statutory dates and the published Q1 reference price. REPORTED on cost magnitudes and trade-flow estimates. INFERRED on the deeper structural reads, flagged as they arise.</jats:p> </jats:sec>