Climate Management 2026 – The Updates That Matter Now · Part 2 of 4

When Climate Data Costs Money: CBAM and the Rise of the ISSB

Voluntary standards are only half the story. With CBAM, the EU has created a regulatory tightening that now costs real money – and with the ISSB, a global reporting regime is growing at the same time, often flying under the radar.

Part 1 of this series covered the methodological foundations: the revision of the GHG Protocol and the new SBTi Corporate Net-Zero Standard V2.0. Today we shift perspective – from voluntary target-setting to binding regulation and the international reporting landscape.

CBAM: From Reporting Obligation to a Real Cost Center

Anyone focusing solely on voluntary standards in climate management can easily overlook the fact that the EU has long since gotten financially serious. Since January 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) has been in its definitive phase.

The Key Changes

• Binding de minimis threshold: Importers with less than 50 tonnes of CBAM-relevant goods per year are fully exempt from the obligations – replacing the previous value threshold of 150 euros per consignment.
• New country- and product-specific default values replace the previous global averages – and increase step by step: a ten percent markup in 2026, twenty percent in 2027, thirty percent from 2028.
• Mandatory third-party verification of reported emissions data instead of self-declaration.
• Annual instead of quarterly declaration, with the first reporting deadline on September 30, 2027 for imports from 2026.
• Expansion in sight: A Commission proposal envisages extending the scope from 2028 to downstream steel and aluminum products; chemicals and polymers are also under discussion.

Why This Matters Now

Even though the first certificate purchases will not be due until 2027 – emissions from 2026 already count. Anyone without verified supplier data now will have to fall back on the significantly more expensive default values. For non-European suppliers, CBAM thus often becomes their very first binding climate disclosure – with ripple effects on the entire Scope 3 reporting of their European customers.

ISSB: The Global Standard Keeps Growing – While Being Eased at the Same Time

While Europe debates the simplification of the ESRS, the international standard IFRS S2 of the ISSB (International Sustainability Standards Board) continues to gain momentum.

Global Adoption

Targeted Relief Measures in IFRS S2

At the same time, in December 2025 the ISSB adopted targeted relief measures for the greenhouse gas disclosure requirements in IFRS S2 – a direct response to practical implementation challenges that companies had reported when applying the standard. The amendments apply to reporting periods beginning on or after January 1, 2027.

Why This Matters Now

The ISSB is becoming the global point of reference that a growing number of national frameworks are aligning with – from China to the United Kingdom to Brazil. For companies with an international footprint, this is often more relevant than any single piece of EU regulation: those reporting under IFRS S2 today are automatically on the safe side in most target markets. At the same time, developments in the US – where the repeal of the SEC climate rule is imminent – show how fragmented the global regulatory landscape remains despite all the convergence.