A Strategic Framework for Implementing the European Union’s Carbon Border Adjustment Mechanism (CBAM): Development of a Maturity Model for Organizational Readiness

The introduction of the Carbon Border Adjustment Mechanism (CBAM) poses a major challenge for importing companies, as it requires continuous, verifiable reporting of product specific emissions data across international supply chains in a defined regulatory format. CBAM thus shifts the focus to a permanent, quality assured emissions monitoring and reporting regime, which in turn necessitates technological, organisational and strategic adjustments. Against this background, this Master thesis examines which organisational and technical capabilities are required to implement CBAM in a robust and auditable manner from 2026 onwards, and how these capabilities can be systematically assessed and developed using a maturity-based approach.
To address this objective, a CBAM-specific maturity model (CBAM Maturity Assessment Tool, CMAT) was developed. The thesis follows a literature-based model design, drawing on established maturity logic to translate CBAM requirements into assessable capability dimensions, criteria and development paths. In addition, the underlying assumptions were empirically validated through guideline-based expert interviews. The practical applicability of the model was further demonstrated through a case study in which CMAT was applied to an anonymised industrial company with CBAM relevant iron and steel imports.
The findings indicate that CBAM compliance in practice is less constrained by regulatory awareness or the mere technical connection of systems, but primarily by weaknesses in accountability and steering structures, insufficient methodological competence to validate externally provided emissions data, and gaps in data quality and traceability. CMAT operationalises this capability profile across ten dimensions and combines a 0–5 scoring approach with gate logic for mandatory minimum requirements (“must-haves”) as well as a risk multiplier reflecting the strength of the control environment.
Overall, the thesis contributes to the operationalisation of CBAM requirements by providing an auditable and scalable assessment and steering instrument. CMAT supports organisations in structured self-assessment and enables the prioritisation of improvement measures along defined capability development paths.