Firm Guides · CBAM and DAC8

CBAM and DAC8: the new international obligations

The year 2026 brings to full operation two mechanisms which, although they operate on distinct planes — the first at the customs frontier, the second in tax transparency — share the same logic: to shift onto the operator established in the Union the burden of collecting, keeping and transmitting information about facts that occur elsewhere. CBAM entered its definitive phase on 1 January 2026; DAC8 has extended mandatory automatic exchange of information to crypto-assets, with obligations running from the same date and a first report in 2027. This guide sets out the framework in force as at 1 September 2026, distinguishing what is law from what is still a proposal.

Two preliminary warnings, because they govern the reading of everything that follows. The first: the CBAM default values have been corrected with retroactive effect from 1 January 2026, so that all computations carried out before 31 July 2026, the date on which the correction was published, must be redone. The second: on the domestic side, the testi unici of the Italian tax reform — the consolidated legislative acts, including the one that absorbs the DAC8 rules — apply from 1 January 2027, that is, just ahead of the first reporting deadline. Anyone consulting a legal database must therefore distinguish the text in force today from the text that will come into operation in a few months’ time.

Part one. CBAM in the definitive regime

The legislative framework

The mechanism is established by Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 (OJEU L 130 of 16 May 2023). The transitional phase, which began on 1 October 2023, closed on 31 December 2025: the last obligation was the quarterly report for the fourth quarter of 2025, due by 31 January 2026. From 1 January 2026 the definitive regime applies, based on prior authorisation, an annual declaration and the surrender of certificates.

The base text was substantially amended by Regulation (EU) 2025/2083 of 8 October 2025 (OJEU L series, 2025/2083, of 17 October 2025), in force from 20 October 2025, the CBAM component of the simplification package: it changes the exemption criterion, the deadlines for the declaration, the start of the sale of certificates, the minimum percentage to be held in the account and the penalty regime. The implementing framework, as at the date of this guide, is as follows.

Act	Date of the act	OJEU publication	Subject matter
Implementing Reg. (EU) 2025/2547	10 December 2025	22 December 2025	Methods for calculating embedded emissions
Implementing Reg. (EU) 2025/2548	10 December 2025	22 December 2025	Calculation and publication of the price of certificates
Implementing Reg. (EU) 2025/2620	16 December 2025	22 December 2025	Adjustment for free allocation
Implementing Reg. (EU) 2025/2621	16 December 2025	31 December 2025	Determination of default values
Implementing Reg. (EU) 2026/1740	20 July 2026	31 July 2026	Correction of Annexes I and IV to Reg. 2025/2621
Implementing Dec. (EU) 2026/1862	23 July 2026	24 July 2026	Cross-sectoral correction factor 2026-2030
Implementing Reg. (EU) 2024/3210	18 December 2024	30 December 2024	CBAM registry

Two of these acts are recent and must be flagged at once. Implementing Regulation (EU) 2026/1740 replaces Annexes I and IV of Regulation 2025/2621 in their entirety and applies from 1 January 2026: it corrects missing or inaccurate production-route indicators, erroneous values for Taiwan (headings 7218 to 7223) and for the residual table (heading 7226 20 00), values omitted for certain countries, incorrect CN codes for Tunisia and, above all, it deletes the columns that set out the default values already inclusive of the mark-up, the calculation of which is now performed in the CBAM registry starting from the total-emissions column. Implementing Decision (EU) 2026/1862 determines the uniform cross-sectoral correction factor for the 2026-2030 allocation period: without it the adjustment for free allocation could not be calculated.

At national level, ADM — the Italian Customs and Monopolies Agency — addressed the start of the definitive phase in circular no. 36/2025 of 24 December 2025, Customs Directorate; the Agency then published, on 13 August 2026, a notice to economic operators on Regulation (EU) 2026/1740.

The goods covered

CBAM applies to the goods listed in Annex I originating in a third country, when they are released for free circulation in the customs territory of the Union or when processed products obtained from such goods under inward processing within the meaning of Article 256 of the Union Customs Code are imported. Origin is determined under the non-preferential rules of origin in Article 59 of Regulation (EU) No 952/2013 (Article 2(5)): proof of preferential origin is of no relevance whatsoever for CBAM purposes. Outside its scope are goods originating in the countries and territories listed in Annex III, point 1 (Iceland, Liechtenstein, Norway, Switzerland; Büsingen, Heligoland, Livigno, Ceuta, Melilla), goods intended for military activities (Article 2(3)) and, under the new Article 2(3a), electricity generated on the continental shelf or in the exclusive economic zone of a Member State or of a country or territory listed in Annex III, points 1 and 2, and hydrogen originating on the continental shelf or in the exclusive economic zone of a Member State or of a country or territory listed in Annex III, point 1. Point 2 of Annex III is still empty: the exclusion therefore does not cover just any continental shelf.

Sector (Annex I)	Main CN codes	Gases	Indirect emissions	De minimis exemption
Cement	ex 2507 00 80 (other kaolinic clays, excluding those not calcined); 2523 10 00; 2523 21 00; 2523 29 00; 2523 30 00; 2523 90 00	Carbon dioxide	Yes	Applicable
Fertilisers	2808 00 00; 2814; 2834 21 00; 3102; 3105 excluding 3105 60 00	Carbon dioxide; also nitrous oxide, save for ammonia (2814)	Yes	Applicable
Iron and steel	Chapter 72 with partial exclusions (ferro-alloys and scrap); 2601 12 00; 7301; 7302; 7303 00; 7304; 7305; 7306; 7307; 7308; 7309 00; 7310; 7311 00; 7318; 7326	Carbon dioxide	No	Applicable
Aluminium	7601; 7603; 7604; 7605; 7606; 7607; 7608; 7609 00 00; 7610; 7611 00 00; 7612; 7613 00 00; 7614; 7616	Carbon dioxide and perfluorocarbons	No	Applicable
Chemicals: hydrogen	2804 10 00	Carbon dioxide	No	Not applicable
Electricity	2716 00 00	Carbon dioxide	No	Not applicable

Two clarifications on the steel line, both a source of errors. The first concerns ferro-alloys, whose exclusion is not total: Annex I excludes ferro-silicon (7202 2), ferro-silico-manganese (7202 30 00), ferro-silico-chromium (7202 50 00), ferro-molybdenum (7202 70 00), ferro-tungsten (7202 80 00), ferro-titanium (7202 91 00), ferro-vanadium (7202 92 00), ferro-niobium (7202 93 00) and the other headings 7202 99, as well as scrap under heading 7204; ferro-manganese (7202 11 and 7202 19), ferro-chromium (7202 41 and 7202 49) and ferro-nickel (7202 60 00) remain, by contrast, within the CBAM scope. The second: the descriptions do not coincide across language versions — code 2523 29 00 is described in the Italian text as «Altri cementi idraulici», exactly like 2523 90 00, whereas the English text describes it as Other Portland cement. In a declaration and in a contract one cites the CN code, never the description.

The indirect-emissions column deserves attention. Article 7(1) provides that for the goods listed in Annex II only direct emissions are to be calculated and taken into account; Annex II covers iron and steel, aluminium, hydrogen and — by virtue of Regulation (EU) 2025/2083 — electricity as well. Indirect emissions therefore matter today only for cement and fertilisers.

Who is liable

The distinction between the roles is where operational errors cluster.

Importer (Article 3(15), as replaced): the person lodging the customs declaration for release for free circulation, or a bill of discharge within the meaning of Article 175(5) of Delegated Regulation (EU) 2015/2446, in that person’s own name and on that person’s own behalf; where the declaration is lodged by an indirect customs representative within the meaning of Article 18 of the Union Customs Code, the importer is the person on whose behalf it is lodged.
Authorised CBAM declarant (Article 3(17)): the person authorised by the competent authority pursuant to Article 17. Article 4 requires that goods be imported only by an authorised declarant.
Indirect customs representative: the Regulation does not define this figure and refers to Article 18 of the Union Customs Code. The new Article 5(1a) provides that such a representative must obtain the status of authorised CBAM declarant before importing and that, where appointed by the importer and where he agrees to act in that capacity, he must assume it irrespective of whether or not the represented importer is exempt under the de minimis threshold; paragraph 2a subjects him to the obligations applicable to the importer for goods imported on the latter’s behalf.

Where the importer is not established in a Member State, the status must be obtained by the indirect customs representative (Article 5(2)), here too irrespective of the de minimis exemption. Paragraph 1b adds a forward-looking rule: where Article 2a applies, the importer is to lodge the application for authorisation in cases where it expects to exceed the threshold, and not once it has already exceeded it. Paragraph 7a, lastly, allows the authorised declarant to delegate the lodging of the CBAM declaration to a third party, while remaining liable for the obligations.

On the allocation of risk, recital 8 of Regulation (EU) 2025/2083 is explicit: in the event of non-compliance the penalties fall on the indirect customs representative acting as authorised CBAM declarant; he is not subject to them only where, acting on behalf of an importer established in a Member State, he has not agreed to act in that capacity. For Italian customs brokers the consequence is clear-cut: indirect representation in respect of Annex I goods entails the direct assumption of declaration, financial and penalty obligations, and must be factored into the fee and regulated by contract accordingly.

The de minimis exemption: the single 50-tonne threshold

Regulation (EU) 2025/2083 abolished the exclusion for consignments of intrinsic value not exceeding EUR 150 and replaced it with the new Article 2a: importers, including those holding the status of authorised CBAM declarants, are exempt where the net mass of the goods imported in a calendar year does not cumulatively exceed the single threshold in Annex VII, point 1, set at 50 tonnes of net mass. The threshold applies to the total net mass of goods under all CN codes, aggregated per importer and per calendar year, and the exemption must be declared in the relevant customs declaration. Paragraph 4 excludes electricity and hydrogen from the exemption.

Paragraph 2 contains the rule to be explained to the purchasing department: once the threshold has been exceeded during the year, the importer is subject to all obligations for all the emissions embedded in all the goods imported in that calendar year, including the first fifty tonnes. It is not an allowance, but an entry threshold.

Example 1 — checking the threshold. A company imports three consignments of Annex I goods in 2026: 18 tonnes of screws and bolts (CN 7318), 22 tonnes of aluminium profiles (CN 7604), 12 tonnes of welded steel tubes (CN 7306). The sum of the net masses is 18 + 22 + 12 = 52 tonnes, above 50. Aggregation takes place across different CN codes and sectors: one does not reason by consignment or by sector. Once the threshold has been exceeded, the obligations extend to the emissions embedded in all 52 tonnes, including those of the first consignment already cleared under the exemption.

The threshold is not immutable. Article 2a(3) requires the Commission to assess by 30 April of each calendar year, on the data for the preceding twelve months, whether the exemption covers no more than 1 per cent of the emissions embedded in the goods and processed products imported; where the resulting threshold value differs by more than 15 tonnes from the applicable threshold, a delegated act is to amend it with effect from 1 January of the following year. As at the date of this guide no delegated act appears to have been published: the threshold remains 50 tonnes for 2027 as well. This is, however, negative proof, derived from a search of the acts published; before relying on it for a decision, a specific check at the date on which one operates is advisable.

Authorisation and the 2026 transitional arrangement

The application is lodged through the CBAM registry (Article 5(3)). The national competent authority within the meaning of Article 11 is located, for Italy, at the Ministry of the Environment and Energy Security, as confirmed by ADM circular no. 36/2025, which refers to the guidance published on the EU ETS – Italia portal. The Customs Agency does not issue the authorisation: it verifies in the declaration that the status is held and prevents importation where it is absent. The criteria in Article 17(2) are the absence of serious or repeated infringements of customs and tax legislation and of the rules on market abuse, financial and operational capacity, establishment in the Member State of the application and the EORI number; among the information required in the application, Article 5 now also provides for the number of the authorised economic operator certificate. A guarantee is required where the applicant was not established throughout the two preceding financial years, commensurate with the aggregate value of the certificates that it would have to surrender in relation to estimated imports and taking account of the adjustment under Article 31; the authority releases it immediately after 30 September of the second year of surrender of certificates.

For the first year, Article 17(7a) provides that a person who lodged an application by 31 March 2026 may temporarily continue to import pending the decision of the competent authority. In the event of refusal, the authority determines, within one month of the decision, the emissions of the goods imported between 1 January 2026 and the decision itself, using default values, and those emissions are used to calculate the penalties under Article 26(2a).

Operational warning, the most urgent in this whole text. ADM circular no. 36/2025 introduced document code Y238 to certify that the application was lodged by 31 March 2026, and states in a footnote that the code, unless subsequently indicated otherwise, is usable until 27 September 2026; in the body of the circular the derogation allows importation pending the decision of the competent authority «and in any event no later than 27 September 2026». Anyone who by 28 September 2026 has not yet obtained the status of authorised CBAM declarant loses, unless the Agency indicates otherwise, the entitlement to continue importing Annex I goods. This is a deadline of national administrative practice, not a deadline laid down by the Regulation, and it must be monitored through ADM notices.

The document codes introduced by the circular are the following.

Code	Meaning
Y128	CBAM account number, which may be indicated only by a person holding the status of authorised CBAM declarant; it allows immediate verification of the status through CERTEX and precedes the authorisation number in the record layout, in accordance with the format CBAM-XX-YYYY-AAANNNNNNNNNNN
Y134	Goods originating in Büsingen, Heligoland or Livigno (Article 2(4))
Y135	Derogation by virtue of Article 2(3) (military activities)
Y136	Derogation by virtue of Article 2(3a) (electricity and hydrogen)
Y137	Derogation by virtue of Article 2a (de minimis exemption)
Y237	Goods originating in the Union
Y238	Application for the status lodged by 31 March 2026 (usable until 27 September 2026)

Y238 and Y128 therefore address two opposite situations and are not interchangeable: Y128 certifies that the status exists and conveys the account number; Y238 certifies that the status does not yet exist but that the application was lodged in good time. A person who obtains the authorisation during 2026 moves from one to the other. Code Y134 does not mention Ceuta and Melilla, although they are covered by Annex III, point 1, because in TARIC the CBAM measure is laid down erga omnes with the exclusion of the geographical areas of Ceuta (XC) and Melilla (XL), as well as of Switzerland, Iceland, Liechtenstein and Norway: for those origins the measure is not triggered and no document code is needed, whereas Büsingen, Heligoland and Livigno, which are not autonomous geographical areas in the database, can be excluded only by means of Y134. The seven codes set out here have been verified against the ADM circular and, in their Italian wording, in the TARIC database; since TARIC is the source that establishes the measure and measures have their own period of validity, a specific check of the code in TARIC at the date of the declaration is nonetheless advisable before completing it.

Calculating embedded emissions

Emissions are calculated in accordance with Annex IV. For goods other than electricity, the new Article 7(2) offers two alternative routes, no longer making the second conditional on the impossibility of the first: actual emissions in accordance with Annex IV, points 2 and 3, verified by an accredited verifier pursuant to Article 8, or the default values in Annex IV, point 4.1, determined by Implementing Regulation (EU) 2025/2621 as corrected by Regulation (EU) 2026/1740, by country of origin, CN code and production route.

A mark-up is applied to the total-emissions column and, contrary to a widespread belief, it does not concern the steel sector alone: for cement, iron and steel, aluminium and hydrogen it is 10 per cent for 2026, 20 per cent for 2027 and 30 per cent from 2028; for fertilisers it is 1 per cent from 2026. Following the July 2026 correction the mark-up no longer appears in the table: it is applied in the CBAM registry to the total-emissions figure. For the sole purposes of the quarterly minimum under Article 22(2)(a), by contrast, the default values are used without the mark-up.

Where default values are used no third-party verification is required, but the reduction for the carbon price paid abroad is allowed only on the basis of annual default prices. Records, including the verifier’s report, are to be kept until the end of the fourth year following the year in which the declaration was or should have been lodged (Article 7(6)).

The adjustment for free allocation

The number of certificates does not correspond to gross emissions. Article 31 requires it to be adjusted to reflect the EU ETS allowances still allocated free of charge to Union installations producing the same goods.

This is where the most costly error in the field lies. Article 10a(1a) of Directive 2003/87/EC introduces «a factor reducing the free allocation of allowances» and calls it the CBAM factor: the literal wording invites one to read it as the percentage of free allocation removed. The opposite is true. The CBAM factor is the percentage of free allocation that remains, and it is equal to 100 per cent from the entry into force of the CBAM Regulation until the end of 2025 — a period in which no reduction occurred — and then, without prejudice to the application of Article 36(2)(b) of Regulation (EU) 2023/956, to 97.5 per cent in 2026, 95 in 2027, 90 in 2028, 77.5 in 2029, 51.5 in 2030, 39 in 2031, 26.5 in 2032 and 14 in 2033; from 2034 no CBAM factor applies. Technical confirmation lies in Implementing Regulation (EU) 2025/2620, which uses it as a multiplier and not as a deduction: the specific embedded free allocation, where default values are used, is equal to the CBAM factor for the year multiplied by the cross-sectoral correction factor and by the CBAM benchmark for the goods (point 5, column B, of the Annex). Anyone reading the «2.5 per cent» found in popular commentary as if it were the CBAM factor for 2026 inverts the calculation: that 2.5 per cent is the share of the burden that accrues, not the factor.

The cross-sectoral correction factor had not been determined when the first commentaries appeared. It has been now: Implementing Decision (EU) 2026/1862 of 23 July 2026 sets it at 100 per cent for each year of the allocation period from 2026 to 2030, thanks to the allowances left unused in the 2021-2025 period and to the additional quantity of 3 per cent. In the 2026-2030 calculations the factor is therefore 1 and does not reduce the adjustment — but it must be cited, because without it the formula does not close.

Example 2 — number and cost of certificates (2026 imports). Import, in the first quarter of 2026, of 120 tonnes of flat-rolled products of non-alloy steel, hot-rolled, not in coils, of a thickness exceeding 15 mm (CN 7208 51 20), of Indian non-preferential origin, with emissions determined using default values.

2026 default value, India, heading 7208, total emissions: 4.280 t CO2 equivalent per tonne, production route (C), carbon steel from blast furnace and basic oxygen converter (Annex I to Implementing Reg. (EU) 2025/2621, as replaced by Implementing Reg. (EU) 2026/1740).
2026 mark-up for the steel sector, 10 per cent: 4.280 × 1.10 = 4.708 t CO2 equivalent per tonne.
Embedded emissions: 4.708 × 120 = 564.96 t CO2 equivalent.
CBAM benchmark for route (C) under heading 7208 51 20: 1.370 t CO2 equivalent per tonne (Implementing Reg. (EU) 2025/2620, Annex, point 5, column B).
Specific embedded free allocation: 2026 CBAM factor (0.975) × cross-sectoral correction factor (1.00) × benchmark (1.370) = 1.33575 t per tonne.
Adjustment: 1.33575 × 120 = 160.29 tonnes.
Corresponding certificates: 564.96 − 160.29 = 404.67; the CBAM registry operates in whole units, so in practice 405 certificates.
Price for the first quarter of 2026, published by the Commission on 7 April 2026: EUR 75.36 per tonne. Burden: 405 × 75.36 = EUR 30,520.80 (EUR 30,495.93 without rounding to whole units).

In this case the adjustment cuts the obligation by roughly 28 per cent, but that reduction shrinks every year as the CBAM factor decreases. The burden, although payable only in 2027, accrues on 2026 imports.

Example 3 — the quarterly minimum in 2027. The same company imports another 120 tonnes of the same goods in the first quarter of 2027 and must calculate how many certificates to hold in its account at the end of the quarter. Under Article 22(2)(a), default values are used without the mark-up, taking account of the adjustment under Article 31.

Embedded emissions without mark-up: 4.280 × 120 = 513.60 t CO2 equivalent.
Adjustment with the 2027 CBAM factor (0.95): 1.370 × 0.95 × 1.00 × 120 = 156.18 tonnes.
Net base: 513.60 − 156.18 = 357.42.
Minimum to be held, 50 per cent: 357.42 × 0.50 = 178.71, that is 179 certificates in the account at 31 March 2027.

The comparison between the two examples shows the twofold dynamic: the base grows with the mark-up and the adjustment contracts with the CBAM factor. It is this, and not the price of the certificate, that is the variable weighing on financial planning.

Certificates: sale, price, quarterly minimum, repurchase

Sales begin on 1 February 2027: from that date each Member State sells to authorised CBAM declarants established in its territory through the common central platform (Article 20(1)). The costs of establishing, operating and managing the platform are financed by fees charged to authorised declarants, provided for by Article 20(5a) and not by paragraph 1; for the duration of the first procurement contract those costs are initially borne by the Union budget, with the revenue from fees qualified as internal assigned revenue.

As to the price, Article 21(1) provides as a rule for the weekly average of the closing prices of EU ETS allowances on the auction platform; for 2026 alone the derogation in paragraph 1a applies, requiring the quarterly average of the quarter of importation. The calculation methodology and the arrangements for publication are laid down by Implementing Regulation (EU) 2025/2548. The prices published by the Commission as at 1 September 2026 are the following.

Quarter of application	Date of publication	Price (euro per tonne)
First quarter 2026	7 April 2026	75.36
Second quarter 2026	6 July 2026	75.28
Third quarter 2026	5 October 2026 (expected)	not yet published

The minimum number of certificates in the account is no longer 80 per cent: Article 22(2) provides that from 2027 the declarant must ensure, at the end of each quarter, at least 50 per cent of the emissions embedded in all goods imported since the beginning of the calendar year, determined using default values without the mark-up or, subject to certain conditions as to identity of CN code and country of origin, using the number of certificates surrendered for the previous year, and taking account of the adjustment under Article 31. Paragraph 2a specifies that the obligation must be complied with by the end of the quarter following that in which the single mass-based threshold was exceeded. Where the Commission finds a discrepancy, it informs the competent authority, which under Article 22(3), second subparagraph, notifies the declarant of the need to restore a sufficient number of certificates within one month of the notification.

As regards repurchase, an important limitation has fallen away. The request is to be made by 31 October of each year in which certificates were surrendered (Article 23(1)); the number that may be repurchased is limited to the total number of certificates the declarant was required to purchase under Article 22(2) in the calendar year of purchase. But the second subparagraph of paragraph 2 adds a rule that should not be passed over in silence: a person who purchased certificates expecting to exceed the single threshold and then did not exceed it obtains the repurchase of all those certificates, upon request. Paragraph 2a provides that certificates purchased in 2027 for 2026 emissions may be repurchased only in 2027. As to cancellation, on 1 November of each year the Commission cancels without compensation the certificates purchased in the year before the preceding calendar year and remaining in the account (Article 24(1)); by way of derogation, on 1 November 2027 the certificates purchased for 2026 emissions are cancelled (paragraph 2). Cancellation is suspended in respect of the contested part where the number of certificates to be surrendered is the subject of pending proceedings.

The reduction for the carbon price paid in the third country

Article 9, replaced in its entirety, does not confer a «credit»: it allows the authorised declarant to claim in the declaration a reduction in the number of certificates to be surrendered to take account of the carbon price effectively paid in the third country on the declared embedded emissions, net of any rebate or compensation available there. This route presupposes that emissions are determined on the basis of actual emissions. The burden of proof is severe: the documentation must be certified by a person independent of the declarant and of the authorities of the third country, with name and contact details, together with proof of actual payment, and is to be kept until the end of the fourth following year.

Paragraph 4 introduces the route of annual default carbon prices, which is mandatory where emissions are determined using default values. Here a point must be made that summaries pass over: the second subparagraph is optional and deferred — «from 2027 and for third countries in which carbon pricing rules are in force, the Commission may determine and make available» such prices. A person declaring on default values must therefore reckon with the possibility that, if no default price is available for the third country concerned, the reduction is not due. The implementing act under Article 9(5), governing conversion into a reduction of certificates, the exchange rate into euro, the evidence and the qualifications of the certifier, does not appear to have been published in the Official Journal of the European Union as at 1 September 2026: only a draft put out to consultation in May 2026 is on record. This too is negative proof and must be re-checked at the date on which one operates.

Penalties and circumvention

Article 26 does not state amounts in euro: it cross-refers. The penalty under paragraph 1, for an authorised declarant who fails to surrender the certificates by 30 September, is identical to the excess emissions penalty under Article 16(3) of Directive 2003/87/EC — EUR 100 per tonne of carbon dioxide equivalent — increased in accordance with paragraph 4 of the same article, which provides for it to be adjusted to the European index of consumer prices from 2013, and applicable in the year of importation of the goods; it applies for each certificate not surrendered. The relevant amount is therefore the indexed value, not the nominal EUR 100: the indexed amount applicable to 2026 must be determined case by case (to be confirmed: no official Union publication of the indexed amount is on record). The new paragraph 1a allows the penalty to be reduced where the error stems from inaccurate information supplied by a third party, and the third party is identified by the provision as the verifier or the independent person certifying the documentation on the carbon price: the operator appears only in recital 31, not in the text of the article.

A person who brings in goods without being an authorised declarant pays three to five times that penalty (paragraph 2). The new paragraph 2a extends the measure to importers other than authorised declarants who exceed the single mass-based threshold, counting all the embedded emissions of the year; payment dispenses with the declaration and the surrender. The penalty may be reduced where the excess does not exceed 10 per cent of the threshold, or in the cases covered by the transitional arrangement in Article 17(7a), but not below the level set in paragraph 1. For an authorised declarant, by contrast, payment does not dispense with the surrender of the missing certificates (paragraph 3). The new paragraph 4a lays down the method of calculation: for the purposes of paragraphs 1 and 2 the competent authority determines the number of certificates that should have been surrendered on the basis of the net mass imported, using default values in accordance with Annex IV and taking account of the adjustment under Article 31.

On the anti-circumvention front, Article 27(2)(b) now qualifies as a circumvention practice the artificial splitting of imports, including through non-genuine arrangements, in order to avoid exceeding the threshold. The new Article 25a is, however, the operationally weightiest point and must be read in full: the Commission periodically exchanges with the competent authorities, through the CBAM registry, a list of importers exceeding 90 per cent of the threshold; a competent authority which concludes that the threshold has been exceeded adopts a reasoned decision, notified also to the indirect customs representatives appointed, and an appeal against that decision has no suspensory effect; for the purposes of the check, no account is taken of practices or arrangements whose main purpose is to fall below the threshold and which are not genuine, that is, not put in place for valid commercial reasons. The consequence is serious and must be stated to the client: in such a case the importer is deemed to have been involved in a serious infringement of the Regulation for the purposes of Article 17(2)(a) and Article 26(2a). This is not merely a matter of penalties: it undermines the requirement for obtaining and retaining the authorisation.

Accounting and tax treatment of the burden

The point is systematically overlooked and deserves a clear rule. At the close of financial year 2026 CBAM certificates cannot even be purchased, because sales begin on 1 February 2027. There is therefore no payable to a supplier to be recognised, nor an asset to be recorded: there is an obligation, certain in its existence and capable of estimation in its amount, which will manifest itself financially in the following year. The correct classification is the provision for charges governed by OIC 31, the Italian accounting standard, recognised under item B.3 «altri» (other) of the provisions for risks and charges in the liabilities side of the balance sheet, with a matching entry among the production costs of the relevant class.

For tax purposes, Article 109(1) of the testo unico on income taxes applies: negative components contribute to income in the year to which they relate, but those whose existence is not yet certain or whose amount is not objectively determinable in the year to which they relate contribute in the year in which those conditions are met. For the 2026 CBAM burden, certainty of existence is present; objective determinability of the amount depends on the data available at the closing date, and the 2026 framework makes it arguable: default values are tabulated, the CBAM factor is set by the Directive, the cross-sectoral correction factor is determined by Decision (EU) 2026/1862 and quarterly prices are published by the Commission for quarters already ended. A person determining emissions from actual data not yet verified is in a weaker position and must document the basis of the estimate.

The penalties under Article 26 are not deductible: they lack the requirement of inherence to the business activity laid down by Article 109(5) of the testo unico, in line with the settled approach to penalties of a punitive nature. This is an interpretative position, not an express provision: it must be adopted knowingly and not presented as a statutory given.

There remains the question of import VAT. Article 69, first paragraph, of Presidential Decree no. 633 of 26 October 1972 computes the tax on the value of the imported goods determined in accordance with customs provisions, increased by the amount of the customs duties payable, VAT excluded, and by the forwarding costs up to the place of destination within the territory of the Union. The CBAM burden is not a customs duty, is not collected by customs and is not even chargeable at the time of importation: it accrues to the national competent authority and is discharged by surrendering certificates in the following year. It should therefore not form part of the taxable base under Article 69 (to be confirmed: no practice of the Customs Agency or of the Revenue Agency on the point appears to have been published).

A final warning as to what is in force, which applies to all the domestic references in this section: the testo unico of the legislative provisions on value added tax, approved by Legislative Decree no. 10 of 19 January 2026, and the one on income taxes, approved by Legislative Decree no. 117 of 19 June 2026, have already been published but apply from 1 January 2027 (Article 171 and the corresponding commencement provision respectively). Until that date Presidential Decree no. 633 of 1972 and Presidential Decree no. 917 of 1986 apply; thereafter, the same rules will have to be traced to the corresponding articles of the new consolidated acts.

The calendar

Date	Obligation	Person concerned
1 January 2026	Start of the definitive regime; requirement to hold the status of authorised CBAM declarant	Importer or indirect customs representative
31 January 2026	Last quarterly report of the transitional period (fourth quarter 2025)	Transitional-period declarant
31 March 2026	Application allowing importation to continue temporarily (Article 17(7a))	Importer or indirect customs representative
30 April of each year	Commission assessment of the single mass-based threshold	Commission
27 September 2026	Last day on which document code Y238 may be used, unless ADM indicates otherwise	Persons who lodged an application and are still awaiting a decision
1 February 2027	Start of sales of certificates on the common central platform	Authorised CBAM declarant
From 2027, end of each quarter	At least 50 per cent of the embedded emissions of the current year held in the account	Authorised CBAM declarant
30 September 2027	First CBAM declaration (year 2026) and surrender of certificates	Authorised CBAM declarant
31 October 2027	Request for repurchase of surplus certificates	Authorised CBAM declarant
1 November 2027	Cancellation without compensation of certificates purchased for 2026 emissions	Commission

What is moving

On 17 December 2025 the Commission presented the proposal for a regulation COM(2025) 989 final, procedure 2025/0419(COD), which would extend CBAM to steel- and aluminium-intensive downstream products — machinery, metal components, equipment, vehicles and parts, metal furniture — from 1 January 2028, strengthening anti-circumvention measures. The Council adopted its general approach on 12 June 2026 and interinstitutional negotiations are under way; Parliament has not yet defined its position. It is a proposal: none of this is in force today. Anyone importing such products nonetheless has an interest in taking stock of its CN codes now, not least because the breadth of the list is itself under negotiation.

What to do

Check by 27 September 2026 the position of anyone still importing under code Y238: if the authorisation has not arrived, open a channel at once with the national competent authority and with ADM, because from 28 September the entitlement to import lapses.
Extract from 2026 customs data the releases for free circulation of Annex I goods, by CN code and net mass, and monitor the cumulative figure against the 50 tonnes on a monthly basis: monitoring is for the importer, not the representative, but the indirect representative acting as declarant is answerable for it.
Redo the computations on default values carried out before 31 July 2026: Regulation (EU) 2026/1740 applies retroactively from 1 January 2026 and has corrected values, CN codes and route indicators.
Check that the status of authorised declarant is held by the person appearing in the declaration and that document code Y128 carries the CBAM account number in the format indicated by ADM circular no. 36/2025, after checking the code in TARIC.
Ask non-EU suppliers for actual emissions data per installation, weighing the alternative of default values: the choice governs accredited verification and, above all, the arrangements for the reduction for the foreign carbon price.
Before counting on that reduction, check whether an annual default price exists for the third country concerned: failing that, and in the absence of the implementing act under Article 9(5), the reduction is not available.
Build a CBAM file for each calendar year and keep it until the end of the fourth year following the declaration.
Estimate the cost of the 2026 certificates, recognise it in a provision for charges under item B.3 and document the basis of the estimate for the purposes of Article 109 of the testo unico on income taxes; plan the outlay between 1 February and 30 September 2027, taking account of the quarterly minimum from 2027.
Review indirect customs representation contracts: a person who agrees to act as authorised CBAM declarant assumes financial and penalty obligations of his own, and must set out funding, guarantees and rights of recourse in writing.

Part two. DAC8 and automatic exchange on crypto-assets

The Directive and its Italian transposition

Council Directive (EU) 2023/2226 of 17 October 2023 amended Directive 2011/16/EU, extending mandatory automatic exchange to the information reported by reporting crypto-asset service providers. Transposition took place by Legislative Decree no. 194 of 10 December 2025 (Official Gazette no. 296 of 22 December 2025), in force from 6 January 2026 and applicable, under Article 20, from 1 January 2026. The decree comprises twenty articles in four chapters: general provisions (Article 1), amendments to the existing rules (Articles 2-5), automatic exchange on crypto-assets (Articles 6-18), financial neutrality and commencement (Articles 19 and 20).

The implementing provisions are contained in the measure of 22 June 2026, prot. no. 186865/2026, of the Director of the Revenue Agency (Agenzia delle entrate). At Union level, Implementing Regulation (EU) 2015/2378, as amended in November 2025, is relevant for forms and formats.

The 1 January 2027 switch

This is where the greatest caution must be exercised, because the rules change their legislative home just before the first deadline. Legislative Decree no. 141 of 5 August 2026 — not to be confused with Legislative Decree no. 141 of 26 September 2024, which is the customs decree — approves, as an annex, the testo unico of the legislative provisions on compliance obligations and assessment (Official Gazette no. 181 of 6 August 2026, ordinary supplement no. 28; the decree entered into force on 7 August 2026, the day after publication, by express provision of its Article 9). Article 368 of the consolidated act provides that its provisions apply from 1 January 2027. Article 367(1)(uuuu) repeals «Articles 6 to 13, 14(1) and (2), 15 to 18» of Legislative Decree no. 194 of 2025: the repeal is therefore partial, because Article 14(3) remains in force, and it takes effect from the same date of 1 January 2027.

The repealed content is transposed into Section VIII of the consolidated act, which is devoted to the rules on the automatic exchange of information on crypto-assets implementing Directive (EU) 2023/2226 and consists of Articles 229 to 241. The correspondence is as follows.

Leg. Decree 194/2025 (until 31 December 2026)	Testo unico annexed to Leg. Decree 141/2026 (from 1 January 2027)	Subject matter
Article 6	Article 229	Definitions
Article 7	Article 230	Reporting providers
Articles 9-12	Articles 232-235	Due diligence for tax purposes
Article 13	Article 236	Reporting obligations
Article 14(1) and (2)	Article 237	Operational block and record-keeping
Article 15	Article 238	Single registration of the operator
Article 18	Article 241	Implementing rules
Article 14(3) (not repealed)	Article 35-bis of the testo unico on administrative and criminal tax penalties	Penalty

The last row is the most delicate. Article 8(1)(q) of Legislative Decree no. 141 of 2026 inserts into the testo unico on administrative and criminal tax penalties, approved by Legislative Decree no. 173 of 5 November 2024, an Article 35-bis dealing with infringements of the due diligence or reporting obligations of crypto-asset service providers, which expressly refers in its sub-heading to Article 14(3) of Legislative Decree no. 194 of 2025 and provides that the penalty under Article 35 applies also to infringements of the obligations under Articles 232 to 236 of the compliance consolidated act. The practical consequence: the two obligations that matter fall after the switch — the self-certifications of pre-existing users by 1 January 2027 and the first report by 30 June 2027 — and must therefore be referred to the articles of the consolidated act, no longer to those of the transposing decree. Anyone who on 30 June 2027 still cites Article 13 of Legislative Decree no. 194 of 2025 will be citing a repealed provision. The two penalty provisions are not alternatives but linked: Article 14(3) of Legislative Decree no. 194 of 2025, not repealed, remains the basis for infringements of Articles 9 to 13 of the same decree, that is, for those accrued until 31 December 2026; from 1 January 2027 those obligations live in Articles 232 to 236 of the compliance consolidated act and the penalty is extended to them by Article 35-bis of the penalties consolidated act. For infringements after the switch the provision to be cited is therefore Article 35-bis.

Who is subject to the obligations

The definitions are not in Article 1, but in Article 6. The reporting crypto-asset service provider (Article 6(1)(i)) is the provider authorised under Regulation (EU) 2023/1114 (MiCAR) or the crypto-asset operator (letter h: a person providing crypto-asset services without being an authorised provider) who provides services consisting in exchange transactions for or on behalf of a reportable user.

Article 7 identifies the connection with Italy: under paragraph 1(a), authorisation under Article 63 of Regulation (EU) 2023/1114 or entitlement to provide services in the territory of the State following notification under Article 60 of the same Regulation; under letter (b), on a subsidiary basis, tax residence, incorporation or organisation under national provisions with legal personality or a reporting obligation, management within the State, or the habitual place of business within the State. Paragraph 2 adds Italian branches for transactions carried out there. Paragraphs 3 to 8 — not up to 9 — lay down the cascade of exclusions where the obligations are already discharged in another reportable jurisdiction. The exclusion in paragraph 7, for persons subject to obligations elsewhere on substantially similar criteria, presupposes that the provider has notified the Revenue Agency that those obligations are discharged there: it is not an automatic exemption.

Reportable crypto-assets are all those other than central bank digital currencies, electronic money and those in respect of which the provider has adequately determined that they cannot be used for payment or investment purposes. Pre-existing users are those who established the relationship by 31 December 2025. The reportable transactions also include the reportable retail payment transaction (Article 6(1)(o)), that is, the transfer of reportable crypto-assets as consideration for goods or services for a value exceeding an amount in euro corresponding to 50,000 United States dollars.

Due diligence for tax purposes

Articles 8 to 12 govern due diligence procedures for tax purposes, distinct from anti-money-laundering procedures. The provider obtains from the user a self-certification enabling its tax residence or residences to be determined and confirms its reasonableness on the basis of the information it holds. The relevant moment is that at which the relationship is established; for pre-existing users, both individuals and entities, the self-certification must be obtained by 1 January 2027 (Articles 9(1) and 10(1)). Where circumstances change, a new valid self-certification or a reasonable explanation is required. Article 11 sets out the validity requirements.

Article 12 must be read precisely, because in popular accounts it is often flattened. The option of relying on due diligence procedures already carried out under the Decree of the Minister for the Economy and Finance of 28 December 2015 is reserved to a provider that is also a financial institution, and is limited to the procedures in Annex A, sections III and V, of that decree. Any provider may, by contrast, rely on a self-certification already obtained for other tax purposes, provided it meets the requirements of Article 11, and may rely on third parties to fulfil the obligations, while remaining liable for their proper fulfilment (paragraph 2).

Information, deadlines and first exchange

Article 13(1) provides that, from the reporting period beginning on 1 January 2026, the provider is to report to the Revenue Agency by 30 June of the following year the identifying data of the user and, for entities, of each controlling person with an indication of their roles; the identifying data of the provider, including its individual identification number and its international legal entity identifier; and, for each type of crypto-asset, aggregate gross amounts, units and number of transactions in respect of acquisitions and disposals against fiat currency, exchanges against other crypto-assets, retail payment transactions and inward and outward transfers, including those to distributed-ledger addresses not known to be associated with a virtual asset service provider or a financial institution (paragraph 1(c)(9)).

Two derogations should be flagged. Paragraph 2 allows a provider which notifies the Agency that it uses an identification service made available by a Member State or by the Union, and which obtains from it direct confirmation of identity and residence, to report, in place of the personal data, the name, the service identifier and the issuing Member State, in addition to the roles. Paragraphs 3 and 4 govern the currency in which gross amounts are expressed and the determination of fair market value, requiring methods applied consistently.

The measure of 22 June 2026 lays down the arrangements: transmission exclusively by electronic means through Entratel or Fisconline, with an XML file following the annexed record layout, including through the persons authorised to transmit under Article 3(2-bis) and (3) of Presidential Decree no. 322 of 22 July 1998 — the ordinary channel of the professional firm; first report by 30 June 2027 for the 2026 period; a receipt of acceptance or rejection, with an obligation to resubmit where rejected; exchange by 30 September of the following year, with the first exchange by 30 September 2027. The measure further clarifies that reports transmitted after the deadline are nonetheless acquired and forwarded: missing the deadline does not entail forfeiture, without prejudice to the penalty.

Single registration of operators is governed by Article 15: an operator which is a reporting provider registers with the Revenue Agency before the end of the period within which it must report the information; an operator which, under Article 7(3) to (8), discharges the obligations in another Member State or in a qualified non-EU jurisdiction is not required to register. Registration takes effect from the first subsequent report; paragraph 7 identifies the cases of removal from the register. At the end of the procedure an individual identification number is assigned and communicated to the secure central register set up by the Commission under Article 8ad of Directive 2011/16/EU. For non-residents, electronic credentials are to be requested through the dedicated procedure; the measure identifies the Centro operativo di Pescara, the Pescara operations centre, as the office competent for controls.

Two external safeguards complete the picture and are often omitted. Article 16 requires the Bank of Italy and CONSOB to communicate to the Revenue Agency, by 31 December of each year, the list of providers authorised under Article 63 of the MiCAR Regulation and of persons entitled following notification under Article 60: the Agency therefore has an independent cross-check of the range of persons subject to the obligations. Article 17(2)(b) requires the provider to give each data subject the information due under Regulation (EU) 2016/679 in good time to exercise their rights and in any event before the information is reported: it is an obligation with a fixed date, not a formality to be discharged afterwards. Article 18(2), lastly, provides that the list of qualified non-EU jurisdictions is to be published by 15 May of each year on the institutional websites of both the Finance Department of the Ministry for the Economy and Finance and the Revenue Agency.

Operational block, record-keeping and penalties

Article 14 contains three rules to be read together.

Operational block (paragraph 1): following the issue of two reminders after the first request, and provided that sixty days have elapsed since that first request was sent, the provider prevents a user who has not supplied the information from carrying out reportable transactions. It is a systemic measure, not a penalty, and must be translated into a function of the platform.
Record-keeping (paragraph 2): the data relating to the steps taken and the information used for due diligence and reporting are to be kept until 31 December of the tenth year following the year in which the information was or should have been reported.
Penalty (paragraph 3): infringement of the due diligence obligations (Articles 9 to 12) or of the reporting obligations (Article 13) attracts the administrative penalty laid down for infringement of the obligations of financial operators by Article 10(1-bis) of Legislative Decree no. 471 of 18 December 1997, or by Article 35(2) of Legislative Decree no. 173 of 2024 from the date indicated in Article 102(1) of that consolidated act.

As to the amount there is no doubt: Article 10(1) of Legislative Decree no. 471 of 1997, as in force, provides for an administrative penalty from EUR 1,500 to EUR 15,000, and paragraph 1-bis cross-refers to it. The date indicated in Article 102(1) of the penalties consolidated act is 1 January 2027: the original date of 1 January 2026 was deferred by Article 4(1) of Decree-Law no. 200 of 31 December 2025, converted with amendments by Law no. 26 of 27 February 2026.

On one point, however, frankness is required. The halving of the penalty for transmission carried out within the following fifteen days is not an established given for this situation. The clause appears in the last sentence of paragraph 1 of Article 10 of Legislative Decree no. 471 of 1997 and is tailored to the reply to a request by the administration under Article 32, first paragraph, point 7, of Presidential Decree no. 600 of 1973, where the period has a dies a quo fixed by the request itself. Whether it survives the double cross-reference — Article 14(3) of Legislative Decree no. 194 of 2025 to paragraph 1-bis, and from the latter to paragraph 1 — and from what starting point it would apply to a periodic mass obligation with a fixed deadline of 30 June, is stated by no provision and does not appear to have been clarified in administrative practice. It is an open question: it should not be taken into account in assessing the risk, and any voluntary correction of the breach — ravvedimento operoso — should be built on the general rules and not on a presumed reduction.

Failure to register is not separately penalised in pecuniary terms: the penalty under paragraph 3 targets due diligence and reporting, not registration, whose specified consequence is removal from the register in the cases set out in Article 15(7).

Electronic money and central bank digital currencies

The scope does not stop at crypto-assets. Electronic money is a crypto-asset that digitally represents a single fiat currency, is issued against funds received for payment transactions, embodies a claim on the issuer in the same currency, is accepted in payment by persons other than the issuer and is redeemable at any time at par value; products created solely to facilitate the transfer of funds on a customer’s instructions are excluded, unless the funds are held for more than sixty days. A central bank digital currency is any digital fiat currency issued by a central bank or other monetary authority.

Both are excluded from reportable crypto-assets, but they do not leave the system: they run on the financial-accounts track. To that effect the Decree of the Minister for the Economy and Finance of 30 December 2025 (Official Gazette no. 302 of 31 December 2025) amended the Ministerial Decree of 28 December 2015, extending the notion of depository institution to persons holding electronic money or central bank digital currencies on behalf of customers, with effect from 1 January 2026. The transitional arrangement is not a general postponement of the obligation: it consists in an exemption, for 2026 and 2027 and for accounts already existing at 31 December 2025 only, from reporting the roles of controlling persons.

The relationship with the OECD CARF framework

DAC8 is the Union transposition of the Crypto-Asset Reporting Framework developed by the OECD, approved on 10 October 2022 and published in June 2023 in the consolidated version together with the amendments to the Common Reporting Standard. The multilateral competent authority agreement was negotiated on that framework and signed by Italy on 20 November 2024. The two sets of rules coexist: DAC8 governs exchange within the Union, CARF exchange with qualified non-EU jurisdictions, with deadlines aligned to 30 September. The list of qualified non-EU jurisdictions is published annually by 15 May, on the websites of the Finance Department and of the Revenue Agency, under Article 18(2) of the decree.

The other amendments to administrative cooperation

Chapter II makes changes to Legislative Decree no. 29 of 4 March 2014 and to the related rules. Three provisions are of direct interest to businesses and professionals.

Advance cross-border rulings concerning individuals (Article 2): exchange is extended to rulings concerning exclusively individuals, where issued, amended or renewed after 1 January 2026 and where the amount of the transaction or series of transactions exceeds EUR 1,500,000, if stated in the ruling; rulings on the taxation at source of employment income, directors’ fees and pensions of non-residents remain excluded.
Foreign tax identification numbers (new Article 5-bis of Legislative Decree no. 29 of 2014): to be stated in applications for advance cross-border rulings and in country-by-country reporting from 1 January 2028; to be collected and stated, where possible, by withholding agents in the annual return and in the Certificazione Unica, the single certification of income paid, from the tax period beginning on 1 January 2030.
Controlling persons (Article 5, amending Law no. 95 of 18 June 2015): information on their roles to be obtained from 1 January 2026, with a deadline of 31 December 2027 for accounts already existing at 31 December 2025.

Chapter II also touches on DAC6 (Article 3, with the obligation for an exempt intermediary to inform the client without delay) and DAC7 (Article 4). The commencement dates do not coincide with that of the crypto-asset obligations and must be checked one by one against the text in force.

What to do

Check whether the company falls among the reporting providers under Article 7, distinguishing the MiCAR position under Articles 63 and 60 from that of operators with a qualifying connection to Italy, and document the outcome.
Where the obligations are discharged elsewhere under paragraphs 3 to 8, prepare and send to the Revenue Agency the notification required by paragraph 7: without it the exclusion does not operate.
Complete the single registration and obtain the individual identification number, requesting electronic credentials in good time where the person is not resident.
Adapt the procedure for establishing the relationship to the collection of the tax self-certification and to the reasonableness check, and plan the recovery of self-certifications from pre-existing customers by 1 January 2027.
Set up the information notice to data subjects so that it is given before any report, and keep proof of it.
Provide in the platform for blocking transactions for a user who does not respond after two reminders and sixty days.
Test the extraction of 2026 data in the XML record layout well before 30 June 2027, agreeing the transmission channel in writing, including through the person authorised under Article 3(2-bis) and (3) of Presidential Decree no. 322 of 1998.
Update internal forms and legislative references to the numbering of the consolidated act from 1 January 2027, remembering that the penalty remains anchored to Article 14(3) of Legislative Decree no. 194 of 2025 for infringements accrued until 31 December 2026, while for later ones Article 35-bis of the penalties consolidated act must be cited.
Keep self-certifications, evidence of checks and electronic receipts until 31 December of the tenth year following the year of reporting.

Conclusion

The common thread of the two mechanisms is that the obligation falls on whoever is inside the Union, while the data lie outside it. Under CBAM the importer — or the indirect representative who takes on that capacity — is answerable for emissions produced in an installation it does not control; under DAC8 the provider is answerable for the tax residence declared by a user who may be anywhere. In both cases the defence is not documentary after the event, but organisational beforehand: contractual clauses requiring the supplier or the user to provide the data, internal traceability, record-keeping for the whole period prescribed.

That said, the dates and values set out here have differing degrees of stability, and some have already changed once. The CBAM default values have been corrected with retroactive effect from 1 January 2026, and nothing rules out further corrections; the 50-tonne threshold is subject to annual review by the Commission; the implementing act under Article 9(5) does not appear to have been published and that finding is negative proof; the deadline of 27 September 2026 for code Y238 is expressly left to «subsequent different indications» of the Customs Agency; the proposal to extend the mechanism to downstream products is in full negotiation. On the DAC8 side, the whole body of rules changes numbering and location on 1 January 2027, with a partial repeal that leaves a single paragraph alive, and legal databases display by default even versions that are not yet applicable. Every assessment must therefore be checked against the text in force at the date on which one operates, and against the code or value in force at that moment, not the one read some months earlier.

The information contained in this guide is of a general informative nature, does not constitute professional advice and cannot replace the examination of the individual case. No operational decision should be taken on the basis of this document alone.