Companion file

The CBAM Compliance Handbook

Authorised Declarant Status, Embedded Emissions, Certificates and Supplier Data

Julian R. Sterling

One Excel workbook. 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. This file supplies the number, sizes the buffer the chapter recommends and never sizes, and finds a term the surrender formula counts twice. It is free. Nothing is gated behind a sign-up, and no email address is asked for.

• Appendix F · Chapters 10, 11 and 13

  The Northbeck cash profile

  “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, €65.47 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. Twenty-eight checks.

  The_CBAM_Cash_Profile.xlsx · XLSX · 16 KB

What to try first

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.

Conventions used throughout

Amber fill	an input — you may edit these
Grey fill	a formula — do not overtype these
ADDED	an input the book does not state — four treasury parameters, and nothing else
Checks sheet	twenty-eight controls — seven exist only to reproduce the book before extending it

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 file

The workbook opens in Microsoft Excel, LibreOffice Calc, Google Sheets and Numbers. It uses 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.

Also by Julian R. Sterling

The other books with companion files. The full list of titles is on the author page.

• Breaking Into European Defence ProcurementThe money and the instruments, the 35 per cent content test, and proposal economics.
• 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 Limited Partnership AgreementWhat the clawback actually collateralises, and why every dollar won on the tax clause lands in the uncollateralised column.
• How to Read a Private Funds Financial StatementsThe Harbourgate reporting pack, five worked cases, and rebuilding your own account.
• 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.
• Insurance Capital for Asset ManagersWhy the same fund costs two insurers different amounts, and what opacity costs a manager in euros.
• Logistics and Industrial Real EstateNet effective rent, the ageing asset, and the development letting decision.
• 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.
• Operational Due Diligence in Private EquityThe rating model built and then broken, and why refining a rubric weakens it.
• Personal Finance for BeginnersWhat a minimum payment really does, and what the snowball and the emergency fund actually cost.
• Private Equity Investor RelationsWhat a fund has returned, read six ways — and the eleven-point gap between them.
• 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.
• Real Estate Joint VenturesThe JV waterfall and promote, the complete venture, and failure to fund.
• Real Estate Transaction Due DiligenceWhat the diligence cost, which workstreams paid for themselves, and the investigation the book skips, priced.
• 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.
• Senior Living and Healthcare Real EstateThe resident engine of a seventy-bed home, the payor mix, and a rota costed at the employer's real hourly rate.
• Significant Risk TransferThe bank's ceiling and the investor's floor derived independently, and the narrow band of prices at which both can say yes.
• Stock Market Investing for BeginnersWhat compounding and fees actually cost, with figures — and a calculator for your own.
• Student Housing Real EstateRevenue per available bed against the rate card, the letting campaign week by week, and the cost base of a 520-bed scheme.
• The AIFMD II HandbookThe reverse stress test computed, and the facility term that moves it more than any asset.
• The Asset-Based Finance HandbookThe borrowing base off a live loan tape, the Meridian transaction, and trigger design.
• The Co-Investment PractitionerWhat dilution really costs, what a pay-to-play clause is worth, and how much to hold back.
• The Continuation Fund HandbookThe Thalia transaction, the bid funnel, and the fees behind the roll decision.
• The Data Center Development HandbookThe underwrite computed: the levered return the chapter never builds, and what a twelve-month slip costs.
• The Distressed Debt InvestorWhere the fulcrum security actually breaks, and what an 80-cent recovery is worth once composition and time are priced.
• The ESG Manager in Private EquityThe exit in equity and IRR, the line the book drops, and the half-turn nobody controls.
• The EU AML HandbookThe back book sized, and the month beyond which no headcount recovers a one-year window.
• The Evergreen Fund HandbookWhat the sleeve costs, and the headline IRR at which a closed-ended fund merely ties.
• The Family Office ProfessionalWhat an office costs, and the level of wealth at which building one starts to pay.
• 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 Infrastructure Investment AnalystDebt sculpted to a coverage floor, and one asset valued twice to the last decimal.
• 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 Private Equity Operating PartnerThe value creation bridge built in full, and who actually made the return.
• The Private Equity Secondaries InvestorThe seller’s floor beside the buyer’s ceiling — and the zone that usually is not there.
• The Private Fund Compliance OfficerThe grey zone as basis points, a broken deal four ways, and how many items you must test.
• The Private Markets Limited PartnerWhat a co-investment programme really saves, and the loss rate that erases it.
• The Private Markets Valuation SpecialistThe book describes its illustrations without numbers on purpose. These files close the chain, with every step visible.
• The Private Wealth FundraiserThree peaks, years apart, and the signature that tells a forecast miss apart.
• The Real Estate Asset ManagerBusiness plans, leasing, and what deferring the work on a building actually costs.
• The Real Estate Debt InvestorThe margin against the return on capital, the floor priced, and what prepayment protection buys.
• The Real Estate Development ManagerThe residual appraisal, the worked scheme, land diligence and the risk register.
• The Real Estate Secondaries InvestorAn eighteen per cent discount to net asset value that is really 9.18 once the reported value is unsmoothed.
• 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.

These files accompany The CBAM Compliance Handbook. The book is on Amazon.

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