Authorised Declarant Status, Embedded Emissions, Certificates and Supplier Data
Julian R. Sterling
These are the companion files of The CBAM Compliance Handbook by Julian R. Sterling.The book on Amazon →
One Excel workbook, corrected where it was wrong. Chapter 10 builds a cash-flow model and stops
one step short of the year that matters: it warns that budgeting only the 2026 lump sum understates
2027 “substantially”, and leaves the word where the number should be. The workbook
supplies the number, sizes the buffer the chapter recommends and never sizes, finds a term the
surrender formula counts twice, and closes on 35 checks, every one green. Around it:
a blank version for your own imports, thirteen working documents to print, forty questions that mark
themselves, and three cases the book names and never takes to a number. All free. Nothing is gated
behind a sign-up, and no email address is asked for.
Six workbooks, the printable documents and the read-me. Each group below can also be
downloaded on its own. Last revised 24 September 2026.
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“Substantially” is a factor of exactly two. Certificates cannot be
bought before 1 February 2027; the 2026 obligation is surrendered by
30 September 2027; and through the same year the declarant is building holdings
against 2027 imports at each quarterly checkpoint. On one calendar that is €6,750 in March,
€8,100 in June, €6,075 plus €27,063 in September, €6,075 in
December — €54,063 against a lump sum of €27,063. A treasurer
who budgets only the lump sum has budgeted 50.1 per cent of the year. And the two is
structural, not coincidental: the factor doubles while the checkpoint is a half, so half the
2027 obligation is exactly the whole of the 2026 one.
The surrender formula counts one term twice. Step four of chapter 10 says
it applies the CBAM factor and the free-allocation adjustment. Its own table applies
the factor and nothing else — 14,400 × 2.5 per cent = 360, with no room
for a second multiplier, so the implied adjustment is exactly 1.00. The table
is right: chapter 11 sets the factor and the retained free allocation as complements, so
the factor already carries the adjustment. But chapter 11 also states the formula
as five separate terms including that adjustment. A reader who builds from the formula arrives
at a smaller obligation than the chapter’s own worked example —
and under-declaring is what Article 26(1) sanctions.
The cap the chapter warns about does not bind. Hold O(1+b), surrender O,
repurchase O×b, cap O. The cap binds only above a buffer of 100 per cent
of the obligation. At ten, twenty or fifty it does not bind at all. What binds is the
31 October deadline — a diary entry with an owner, not a financial constraint, and
it should not be priced like one.
Which makes the buffer close to free, and the decision independent of the penalty.
Thirty-six certificates cost €2,700 and, carried eight months at five per cent, cost
€90. The break-even probability of a shortfall does not depend on the
buffer size — carry and protection scale together, so the ratio is identical at five
per cent and at thirty. And expressing the penalty as a multiple of the certificate price puts
the break-even between 3.3 and 0.7 per cent across the whole
plausible range, so the decision never needs the indexed figure chapter 13 rightly refuses
to print.
And €3.40 a tonne becomes €65 by 2030. Same book of imports, same
intensity, same price — only the factor moves: €13.50 in 2028, €30.38 in 2029,
€65.48 in 2030, €135.00 in 2034. Nineteen times by 2030, which is
inside the horizon of every supply contract being signed now. The workbook also tests
chapter 11’s claim that four fifths of the increase falls after 2029: it is
79.5 per cent, exact to a tenth of a point, and the verdict cell
prints CONFIRMED. Thirty-five checks.
Revised: the 2030 cost a tonne is €65.48, not €65.47 (65.475 rounds up, as 30.375 did
for 2029); three inputs are ADDED, not four, because the forward price of 75 is the
chapter’s own; three checks that read only the first row of their range in Excel now test
every row; and seven checks are added.
Go to sheet 4 and read the last two rows. Then replace Northbeck’s four volume cells on
sheet 1 with your own quarterly imports and the intensity with your own supplier figure:
everything downstream is linear, so the whole calendar rescales in five keystrokes. Then go to
sheet 5 and change the penalty multiple — the break-even column closes the argument
about whether to hold a buffer without anyone having to establish the indexed penalty first.
What the arithmetic does not settle
It cannot confirm the regulation. The book is unusually careful about this and the workbook keeps
its caution: the checkpoint percentage, the checkpoint dates and the phase-out schedule are the
figures as consistently reported, and the book says plainly that a verbatim read of the
consolidated text returned a different percentage in one case. Confirm them against the
consolidated regulation before you rely on any of this operationally, and record the date of your
read. The workbook can only tell you what follows if the parameters are what they are
reported to be — which is why every one of them is an editable cell rather than a constant.
The same model, for your own imports
The workbook with its 23 inputs emptied. Enter your own quarters, intensity and prices; the checks sheet counts what is still missing and runs eleven tests that hold for any inputs.
Chapters 10, 11 and 13 · Appendix F
A blank cash profile
Four quarters of imports, the intensity, the quarterly prices and the forward price, the checkpoint, the three treasury inputs and the phase-in schedule. The file gives the certificates and the cost by quarter, the implied free-allocation adjustment that must read 1.00, the cost a tonne to 2034, the 2027 calendar and the years after it, and the break-even probability that decides the buffer. The buffer sizes and penalty multiples stay, because they are the axes of their tables, not data.
The book’s inputs are listed in a text file inside the archive. Type them back in and the file returns 360 certificates, 27,062.64, a 2027 requirement of 54,062.64 and a break-even of 2.56 per cent.
Thirteen pages to print and use. A4, with margins wide enough for US Letter.
Chapters 10, 11 and 13 · the whole book
Thirteen working documents
The scope screen, with the annual mass threshold. The authorised declarant file, condition by condition. The supplier data request, with what the contract must say. Supplier figure or default value, year by year. The obligation line by line, Northbeck’s beside a blank column. The surrender formula checked for the term counted twice. The phase-in budget to 2034. The 2027 treasury calendar and the multi-year cash plan. The buffer decision. The deadline and penalty register, with two names on every date. The parameter log for reading the regulation. And one page for the finance committee.
A workbook that marks itself. Answer in the yellow cells; the marking fills in as you go.
All parts of the book
Forty questions on the book
Eight on the Northbeck year, seven on the phase-in, seven on the 2027 load, six on the buffer and the penalty, six on the model rerun on other inputs, and six on the three cases below. Numbers are marked to a tolerance, multiple choice to the letter, and the score sheet counts your errors part by part: that is your revision list.
Nothing is hidden. The marking sheet holds every answer, every tolerance, and the reason for each answer.
New material, not a restatement. Three situations the chapters name and never take to a number. Each case is one workbook: the note is the first sheet, the model is the rest, and a checks sheet closes it. Type your own figures in and every finding recomputes.
Chapters 10, 11 and 13 · Case one
The term counted twice, carried to 2034
A workbook built from the five-term formula multiplies the factor by the retained free allocation. In 2026 it is 9 certificates short, 675 euros on 360, and the implied adjustment reads 0.975: inside any tolerance. The share short is the factor itself, so by 2030 it is 3,387.24 certificates and 330,256 euros of penalty at 1.3 times the price (ADDED), and in 2034 the workbook says nothing is owed. A budget that falls after 2030 on flat volumes is the signature. The check that catches it has no tolerance.
Chapters 10 and 11 · Case two
What the supplier’s data is worth
Chapter 10’s 1.8 against a default of 2.30 with its mark-up (ADDED). At 12,000 euros a year for verified data (ADDED), the data does not pay in 2026, by 1,050 euros: 2026 is the one year in which defaults are the cheaper answer. From 2027 it pays above 3,333 tonnes, and in 2030 it is worth 346,290 euros, 43.29 a tonne. Over nine years, 2,906,460.
Chapters 10 and 13 · Case three
The buffer, sized to the data
The chapter asks for a buffer “sized to the uncertainty in your own emissions data”. The rule: cover every outcome whose chance of being reached is above the 2.56 per cent break-even. With a 3 per cent chance that the supplier’s figure is rejected (ADDED), that is 146 certificates, 40.6 per cent, at an expected cost of 365 euros. The modest 10 per cent costs 780. At a 2 per cent chance the rule stops at 90.
a figure the book does not give: three treasury parameters in the workbook, and the case inputs, marked wherever they appear
Checks sheet
thirty-five controls, seven of which exist only to reproduce the book before extending it; in the blank set and the cases, each control states its own verdict and the file ends ALL OK
Northbeck Metals is the book’s own invented company and the volumes and intensity are its own.
The prices, dates, factors and rules are the published framework as the book reports them. This is
not legal or compliance advice, and the regulation should be confirmed against its consolidated
text.
Opening the files
The workbooks open in Microsoft Excel, LibreOffice Calc, Google Sheets and Numbers; the PDF
prints on A4 or US Letter. They use no macros and no add-ins, so nothing needs to be enabled or trusted. If your spreadsheet asks
to update links on opening, decline — there are none.
What changed, and when
24 Sep 2026
The workbook corrected, 35 checks. The 2030 cost a tonne is €65.48, not €65.47; three inputs are ADDED, not four, since the forward price of 75 is chapter 10’s own; three checks that read only the first row of a range in Excel now test every row, and seven are added. Added: a blank version, thirteen working documents, forty questions that mark themselves, and three cases. The workbook can now also be downloaded on its own.
Articles on this book
What a CBAM certificate buffer costs to holdCarry and protection are both linear in the buffer, so the break-even probability is identical at 5 per cent and at 30 — and 2027 costs exactly twice 2026.
Is it worth staying under the CBAM 50 tonne threshold?Crossing 50 tonnes by 5 brings all 55 into CBAM. In 2026 the certificates cost 210 euros; the fixed compliance cost, 15,000 illustrative, is what makes the cliff.
How do you calculate a CBAM surcharge per tonne?Certificates owed per tonne times the certificate price, plus compliance cost per tonne: 0.76425 x 75 + 2.00 = 59.32 euros a tonne of steel in 2026.
Closing the DealTwo defensible bridges 20.70 million apart, a peg worth 7.00 million, and the six choices that remove 6.60 of a 12.00 earn-out.
CMBS and CRE CLOsWhere the loss actually lands, from appraisal reduction to realised severity, and what the B-piece is really being paid for.
How to Read a Commercial LeaseThe three refinements chapter 19 names and never performs, and the renewal rate below which the mark-to-market is worth nothing.
How to Read a Credit AgreementWhere the default actually comes from, the cure that costs 5.5 times the other, and the capacity nobody adds up.
How to Read a Real Estate Loan AgreementThe cure ratio in closed form, the four-point window in which the cheap cure works, and the cure sized to the wrong threshold.
Office Real EstateA six per cent yield that returns 3.2 per cent once the re-letting cycle is paid for, and the headline-to-net-effective rent arithmetic.
Private Equity Real EstateBoth worked waterfalls to the dollar, the two capital stacks, and the arithmetic of the promote made changeable.
Private Markets PerformanceThirty-one of the thirty-three figures chapter 19 publishes reproduce exactly — and the two that do not are named rather than quietly adopted.
Raising a Real Estate FundThe chapter 17 funnel run on a calendar — when the first close actually lands, and why more travel does not help.
Real Estate FinanceFour people look at one building and reach four numbers; the lender is whole only above 105,109,489, twelve per cent below today’s value rather than forty.
Real Estate Financial ModelingProperty, development and fund models built line by line, and the modelling test worked end to end.
Real Estate Fund ManagementThe waterfall of 6.11, the build-to-core of 8.7 and the proceeds gap, reproduced as live formulas rather than asserted.
REIT Analysis and ValuationFFO of 532.0, AFFO of 381.0, net asset value and dividend safety — every figure a formula you can change.
Retail Real EstateThe occupancy cost of every unit in a centre, the sixteen per cent of the rent roll no tenant can sustain, and the right-size-convert-or-hold decision priced.
Sale and LeasebackA €179.5 million transaction end to end, with rent cover measured on the entity that actually signs the lease.
Self-Storage Real EstateThe cohort engine behind a 590-unit store, and the rate increase on existing customers priced against the move-outs it causes.
The Fund Finance ProfessionalChapter 8 builds the reported-to-eligible NAV bridge; chapter 9 computes every ratio without it. Two points at every state — and what a subscription line does to the IRR.
The Growth Equity InvestorWhat a pro rata cheque really costs, and the band where defending your ownership loses money.
The Private Credit InvestorThe two coverage ratios are not measured on the same thing: the erosion is 47.7 per cent, not the 28.7 the headline implies.
The Private Equity Fund Controller PlaybookThe book defines IRR, DPI, RVPI and TVPI, tells you to update them at the exit, and prints not one value. Computed: a 1.833× deal inside a fund at 0.892 TVPI.
The Venture Capital AssociateWhat defending a position costs, and how many companies a reserve pool actually defends.
Financial Risk ManagementA fund inside every limit that cannot meet a redemption — and the number that decides it is the one with no currency attached.
Business ValuationThree advisers land 26.8 per cent apart on one company, and the whole gap turns out to be 1.96 points of perpetual growth.
Quantitative FinanceThree models agree to a quarter of one per cent about a number that one unobservable input moves a hundred and three times as much.
Asset ManagementFour people quote four returns for one mandate, all correct and 2.7017 points apart — forty-eight times the manager’s net skill.
Alternative InvestmentsA manager reports 13.29 per cent and the endowment earns 6.26 — both correct, and only a third of the advertised advantage arrives.
Credit AnalysisFour defensible EBITDAs on one borrower give leverage from 3.19x to 6.47x — and the add-back argument is fifty times the covenant headroom.
Venture CapitalOne company out of twenty-eight returns 56.7 per cent of the fund, and half the capital goes in after the decision — at half the return.
Machine Learning for FinanceFive people quote the accuracy of one credit model, all five are right, and the number that decides how much money it makes is none of them.
Commercial Real Estate InvestingThe equity earned 8.6647 per cent and the investor received exactly 8.0000 — the preferred return, and nothing above it.
Mergers and AcquisitionsThe board paper says the deal creates 13,436,667 of value. The arithmetic says it destroys 17,530,855. Nobody is lying.
DerivativesThe treasury report says the hedge cost 1,233,698. That is the interest differential, not a cost.
Treasury ManagementFive cash balances for one company, all correct and 145,600,000 apart — and the revolver that is two-thirds of the liquidity leaves at a revenue fall of 8.4127 per cent.
Financial Planning and AnalysisRevenue 3.0190 per cent above budget and operating profit 16.3209 per cent below it, in the same quarter, with every figure correctly stated.
Energy TradingA position report that is 91.7031 per cent hedged and correctly computed, on a book that is short 2,542,000 MWh — and a margin call of 198,400,000 the next morning.
Construction Cost ControlA contract sum of 26,301,102 became a final account of 29,153,363 on the building that was drawn — and 85.8 per cent of what was lost was knowable on the day it was signed.
Pricing StrategyA list price of 148.00, a pocket price of 112.51, and the nine deductions in between — with what one point of price is actually worth.
Trade FinanceSix routes to payment on one 4,200,000 export order cost between 178,040 and 223,268, a spread worth 14.8 per cent of the margin, and a day of buyer credit costs 1,031.76.
Cost AccountingOne factory costed twice on the same 13,440,000 of overhead, and 4,053,091 moves between four product families.
Contract ManagementA bid 5.50 a unit cheaper, signed on paper worth 9.81 a unit more — and 94.68 per cent of it was knowable on the day of signature.
Capital MarketsFour defensible readings of one bond, the cost of an issue under each convention, and the placement discount computed at a constant discount.
Financial RegulationThree ratios pass and the fourth is in breach by 1,956.0 million: the output floor, the liquidity buffer after encumbrance, and the loan split.
Bank ManagementFour defensible readings of one balance sheet, the deposit beta measured two ways, and the liquidity that lasts 3.9 days.
The Real Estate WorkoutFour ways out of one broken loan, discounted to today, and the 58.7 cents at which a payoff beats enforcement.
Go beyond the companion files
The CBAM Compliance Handbook develops the complete framework behind these models, with the assumptions, trade-offs and worked examples tied together.
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