Yevhen Altukhov, Head of the Operational Environmental Management Group at Metinvest Group, spoke about the challenges associated with adapting large-scale industry to the new CBAM requirements during the webinar “CBAM 2026: New EU Requirements and Practical Aspects”, hosted by KPMG Ukraine.
KPMG is a global network of firms providing audit, tax and advisory services. During the webinar organised by KPMG Ukraine, experts provided a detailed overview of the pathway for business adaptation to the implementation of the Carbon Border Adjustment Mechanism (CBAM): from legal considerations to the operational accounting of emissions.
The discussion was joined by Yurii Katser, Partner and Head of Legal Services at KPMG Ukraine; Oleksandr Baskov, Manager for Sustainability and ESG at KPMG Ukraine; and Yevhen Altukhov, Head of the Operational Environmental Management Group at Metinvest Group.
For Ukrainian exporters of steel, aluminium, cement, fertilisers and electricity, 2026 will mark the transition from the “transitional” phase to the permanent, financial phase of CBAM, which entails the mandatory purchase of certificates.
The implementation of CBAM represents an important turning point for imports of metallurgical products into the EU. Already this year, European importers of products falling within the scope of CBAM are required to pay an additional percentage of the product’s value.
CBAM is changing the rules of the game for Ukrainian exports – from new contractual requirements to more stringent control of emissions data. As the mechanism remains relatively new and dynamic, Ukrainian exporters and European importers are facing a range of uncertainties.
In particular, according to Yevhen Altukhov, one of the key dilemmas of CBAM lies in the existence of two principal approaches to reporting and, consequently, to the associated financial obligations: either on the basis of actual data or on the basis of default values.
Default values are simpler from an administrative perspective: the conduct of accounting processes, data archiving and verification, as well as reporting and auditing. However, this approach may result in a significant increase in financial liabilities, as a modern enterprise may have emissions levels lower than the EU‑established “average” benchmarks.
At the same time, producers that opt for reporting based on actual data may also face certain challenges. These include the calculation of individual benchmarks, the interpretation of certain methodological provisions of EU Regulations, the development of monitoring methodology documentation, compliance with data verification requirements, cooperation with verifiers, and related aspects.
"While actual emissions data require the establishment of an end‑to‑end monitoring system and the involvement of raw material suppliers, this approach enables the optimisation of CBAM certificate costs and strengthens risk control. Under the new conditions, carbon accounting is becoming an integral component of strategic business management,” added Yevhen Altukhov.
