Case Study

Carbon Border Adjustment Mechanism

How SOVERN transformed Regulation (EU) 2023/956 into executable digital workflows

Overview

Transforming CBAM into Executable Workflows

The Carbon Border Adjustment Mechanism (CBAM) is a cornerstone of the EU's climate policy, designed to prevent carbon leakage by requiring importers to purchase certificates corresponding to the carbon price that would have been paid had the goods been produced under the EU's carbon pricing rules.

Implementing CBAM presents significant challenges for both regulatory authorities and businesses due to its complex requirements for emissions calculation, certificate management, and customs integration. SOVERN was tasked with transforming this complex regulation into executable digital workflows that would streamline compliance while ensuring accuracy and transparency.

Project Highlights

99.9%

Calculation accuracy

85%

Reduction in processing time

100%

Regulatory traceability

The Challenge

Complex Requirements, Multiple Stakeholders

Implementing CBAM presented several significant challenges that needed to be addressed

Complex Emissions Calculation

CBAM requires importers to calculate embedded emissions for imported goods using methodologies specified in Annex III of the regulation, with different approaches for different product categories and special provisions for certain countries.

Key Challenges

  • Multiple calculation methodologies depending on product type and data availability
  • Complex rules for default values and verification adjustments
  • Need for auditability and traceability of all calculation steps

Certificate Management

CBAM requires a complex system for issuing, trading, and surrendering certificates, with specific rules for pricing, validity periods, and reconciliation with actual emissions.

Key Challenges

  • Dynamic pricing based on EU ETS weekly average closing prices
  • Complex rules for certificate re-sale, validity, and cancellation
  • Need for secure, tamper-proof certificate records with full audit trails

Customs Integration

CBAM requires integration with customs systems to verify that importers have sufficient certificates for their imports, with specific procedures for declaration and verification.

Key Challenges

  • Integration with diverse customs systems across EU member states
  • Real-time verification of certificate availability during import
  • Handling of special cases like temporary storage and transit

Reporting & Compliance

CBAM requires detailed quarterly and annual reporting, with specific requirements for data collection, verification, and submission to regulatory authorities.

Key Challenges

  • Complex data collection requirements from diverse sources
  • Need for verification by accredited verifiers with specific expertise
  • Handling of appeals, corrections, and enforcement actions
The Solution

SOVERN's Regulation-as-Code Approach

How we applied our methodology to transform CBAM into executable workflows

1

Legal Analysis & Decomposition

Our legal experts analyzed the CBAM regulation to identify all requirements, obligations, and compliance pathways, breaking down the complex legal text into structured components.

Key Outputs

  • Comprehensive requirement catalog with 247 distinct regulatory requirements
  • Detailed dependency graph showing relationships between requirements
  • Legal interpretation documentation validated by regulatory experts
2

Structural Mapping & Formalization

We mapped CBAM requirements to data structures and logical relationships, creating a formal representation of the regulation that preserves its intent while making it machine-readable.

Key Outputs

  • Comprehensive data schema covering all CBAM-related entities and relationships
  • Formal rule specification for emissions calculation, certificate management, and reporting
  • Process flow diagrams for all CBAM-related workflows and interactions
3

Implementation & Deployment

We implemented the formal representation as executable code and deployed it as digital workflows, with full traceability back to the source regulation and comprehensive testing.

Key Outputs

  • Executable code modules for all CBAM-related functions with 100% test coverage
  • Digital workflows for emissions calculation, certificate management, and reporting
  • Integration interfaces for customs systems, verification providers, and reporting platforms

Key Technical Components

Emissions Calculator

Implements all CBAM calculation methodologies with support for default values and verification adjustments

Certificate Manager

Handles certificate issuance, trading, and surrender with secure, tamper-proof records

Customs Connector

Integrates with customs systems for real-time verification of certificate availability

The Results

Transformative Impact on CBAM Compliance

How our solution transformed the CBAM compliance landscape

For Importers

Key Benefits

  • 85% reduction in time required for CBAM compliance activities
  • Automated emissions calculation with 99.9% accuracy compared to manual methods
  • Streamlined certificate management with real-time visibility into certificate status
  • Automated reporting with built-in validation to ensure compliance with regulatory requirements

"SOVERN's CBAM solution has transformed our compliance process from a complex, resource-intensive burden to a streamlined, automated workflow. We've reduced our compliance costs by over 60% while improving accuracy and reducing risk."

— Compliance Director, Major EU Steel Importer

For Regulatory Authorities

Key Benefits

  • Standardized implementation of CBAM across all member states
  • Real-time visibility into CBAM compliance status and certificate usage
  • Comprehensive audit trails for all CBAM-related activities
  • Data-driven insights into carbon leakage prevention effectiveness

"SOVERN's approach to implementing CBAM has significantly enhanced our ability to monitor and enforce compliance. The transparency and traceability built into the system have been invaluable for ensuring the integrity of the CBAM mechanism."

— Senior Official, EU Regulatory Authority

Implementation Metrics

247

Regulatory requirements implemented

32

Distinct calculation methods

18

Integration points

100%

Test coverage

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