JMS Blog

UK CBAM : Moving from Uncertainty to Readiness

Written by Mark Thornton | Aug 24, 2026, 8:47:40 AM

UK CBAM: Moving from Uncertainty to Readiness

Jonas Metals Software is working with carbon and cost management specialists Auditel as we prepare our customers and our software for the introduction of UK CBAM on 1 January 2027.

UK CBAM has been on the horizon for some time. But knowing that legislation is coming and knowing precisely what businesses – and the software supporting them – will need to do are two different things.

At Jonas Metals Software, we made a deliberate decision not to rush into development while important elements of the UK regime were still evolving.

Our customers don't need software built around assumptions that subsequently change. We wanted sufficient regulatory clarity before committing development resource and, importantly, access to specialist expertise to help us interpret the requirements correctly.

We have now reached that point.

Why timing matters

The detail behind UK CBAM has continued to emerge throughout 2026.

Important Government technical documentation was published as recently as July, followed by further HMRC guidance covering areas including goods in scope, registration, record keeping and carbon price relief. Further detail continues to emerge as the regime moves towards implementation.

This matters when developing business software.

A change in regulatory interpretation can affect the information a business needs to capture, when it needs to capture it, how long it must retain it and how its eventual CBAM liability is calculated and reported.

Our approach therefore isn't to regard CBAM as a specification that was fixed months ago. We need to understand each significant development, assess its implications and incorporate those changes into both our product development and our customer-readiness programme.

Bringing together CBAM and metals expertise

To support that work, Jonas Metals has partnered with Auditel, a UK cost, procurement and carbon management consultancy that works with organisations on carbon reduction, sustainability and the financial implications of changing regulatory requirements.

In July, CBAM specialists from Auditel joined members of the Jonas Metals Product and Consulting teams for a full-day workshop.

We deliberately approached the day from the perspective of a metals business rather than starting with a list of software features.

We followed material through the operational process: purchasing, import, goods inwards, stock, processing, traceability and despatch. We considered what information is available at each stage, what additional information CBAM may require and how that information needs to remain associated with the material.

That work is now informing our CBAM development programme for iMetal.

CBAM is about more than producing a report

One of the clearest conclusions from our work so far is that CBAM readiness isn't simply about producing a report at the end of an accounting period.

The quality of that report will depend on the information captured much earlier.

For metals businesses this can include commodity codes, country of origin, mills and installations, cast information, customs information, emissions data and supporting documentation.

Much of the foundation already exists within iMetal.

Commodity codes are already held against products. Mill and country-of-origin information can be recorded, while cast-level traceability allows information to follow stock through cutting and subsequent parent-child production processes.

Our development challenge is therefore not simply to add a CBAM report. It is to understand how the additional requirements fit naturally into the operational processes our customers already use.

What happens when material is processed?

The detailed work with Auditel is also helping us answer some very practical questions from customers.

One we have already been asked is what happens when imported material is subsequently processed.

If steel or aluminium is sawn, slit, drilled, bent or profiled – sometimes using significant amounts of energy – does the business need to measure that energy and add the resulting emissions to the CBAM value of the material?

Under the UK CBAM regime being introduced in January 2027, indirect emissions associated with electricity are currently outside scope. This means that in many of the everyday processing scenarios encountered by metals stockholders, simply using electricity to cut, drill, bend, slit or profile material does not mean that energy consumption must automatically be measured and added to its CBAM emissions value.

There are important distinctions where processing transforms a product and different rules may apply. It is precisely this type of question that demonstrates the value of combining Auditel's regulatory expertise with our understanding of metals operations and software.

It also demonstrates why we don't want to ask customers to collect information simply because we think it might be required.

We want to understand what is actually required, while recognising that those requirements may evolve.

Getting the data ready

There is another important lesson from our work so far.

Having CBAM functionality available in software will not automatically make a business CBAM-ready.

Our initial analysis across the customer base has identified considerable variation in how information such as commodity codes, mills, casts and country of origin is currently maintained.

For some businesses, much of the necessary foundation may already be there. Others will need to improve the information they capture and potentially adapt some operational processes.

That work needs to begin before 1 January.

Our programme will therefore combine software development with customer readiness – helping customers understand the information they currently hold, identify gaps and prepare their data and processes for the new regime.

From compliance to better decisions

There is also a wider commercial consideration.

CBAM will introduce a new cost and an additional area of uncertainty into an industry already managing fluctuating material prices, tariffs, quotas, supply constraints and margin pressure.

Businesses will need to understand not just what they eventually need to report, but their developing exposure and what that could mean for purchasing, costing, pricing and margin.

That fits closely with the wider direction of Jonas Metals Software: helping our customers use trusted operational information to make better, faster decisions in an uncertain world.

What happens next?

UK CBAM takes effect on 1 January 2027.

Between now and then, our work continues.

We will continue developing the required iMetal capabilities, work with customers on data readiness and, alongside Auditel, continue to assess new regulatory detail as it is published.

We deliberately waited until there was sufficient clarity to commit our development resource.

Now our focus is on making sure that our customers don't simply reach January with new software functionality, but with the data, processes and understanding they need to be ready for UK CBAM.

We'll be sharing more about the programme, and answering some of the practical questions we're already receiving from customers, over the coming weeks.