Carbon Border Adjustment Mechanism – Policy, Landscape, and Market Report

Executive Summary, December 2025

 This report provides an analysis of the EU Carbon Border Adjustment Mechanism (CBAM), where the policy process stands, how the implementation will evolve, how the development of key technologies is foreseen, and the role for remote sensing in this policy domain.  

This report identifies key elements of the CBAM, which consists of Regulation (EU) 2023/956, establishing a carbon border adjustment mechanism; Implementing Regulation (EU) 2023/1773, CBAM for the transitional phase; Implementing Regulation (EU) 2024/3210, CBAM Registry, two measures for simplification of the CBAM under Omnibus I (Regulation (EU) 2025/2083, already adopted) and proposed Omnibus II, as well as Implementing Regulation (EU) 2025/486, conditions and procedures related to the status of authorised CBAM declarant. The report will dive into the initial CBAM establishment, the changes under the Omnibus simplification measures, and the timeline of how CBAM is set to progress in the coming years.  

The report also assesses key stakeholders involved in CBAM and interconnections with other carbon-related policies.  An analysis of the state-of-the-art is also provided which discusses EO applications.  The report also provides a gap analysis, covering regulatory, economic, and technical gaps, and a market sizing exercise to showcase developments.  Finally, the report provides a list of recommended actions/interventions that could further encourage the inclusion of EO-based MRV solutions under CBAM.   

If you wish to engage with the SEF team further about this topic, please contact us at esa-sef@evenflow.eu.