Quick answer
Article 26 of Regulation (EU) 2024/573 sets one main date: 31 March, every year, for the preceding calendar year. What you report is the data listed in Annex IX, filed through the reporting tool reached from the F-gas Portal.
A second date follows for larger volumes: 30 April, when an independent auditor has to confirm the report. And there is a trap in between — a quota holder who placed nothing on the market still files a nil-report.
The annual report says what you actually did last year. A quota declaration is a request for future quota, submitted in a separate window. Section 8 sets out the difference.
Who has to report
Article 26 does not have a single audience. Each paragraph adds a different group, with its own threshold.
| Who | Trigger |
|---|---|
| Producers, importers, exporters | Produced, imported or exported hydrofluorocarbons in any quantity, or more than one metric tonne or 100 tonnes of CO2 equivalent of other fluorinated greenhouse gases (Article 26(1)). |
| Undertakings receiving quota | Received quota transferred under Article 21(1) — they report as well (Article 26(1)). |
| Undertakings that destroyed gases | Destroyed hydrofluorocarbons, or quantities of other fluorinated greenhouse gases above the threshold (Article 26(2)). |
| Feedstock users and stock holders | Used gases as feedstock or held stock during the preceding calendar year (Article 26(3)). |
| Undertakings placing equipment on the market | Placed 10 tonnes of CO2 equivalent or more of HFCs, or 100 tonnes of CO2 equivalent or more of other F-gases, contained in products or equipment (Article 26(4)). |
| Recipients of exempted quantities | Received quantities of HFCs falling under Article 16(2), such as destruction, feedstock, direct export or military use (Article 26(5)). |
The 10-tonne threshold for equipment is much lower than the thresholds elsewhere. A company that imports modest volumes of pre-charged equipment can be caught by Article 26(4) while assuming reporting is only for bulk traders.
The two deadlines
| Date | What is due |
|---|---|
| 31 March | The annual report with the Annex IX data for the preceding calendar year, and the nil-report where it applies. |
| 30 April | Independent auditor verification where 1 000 tonnes of CO2 equivalent or more of HFCs were placed on the market (Article 26(8)), and the verification report for importers of pre-charged equipment above the same threshold (Article 26(7)). |
Both are annual and recurring. The first reports in the current format were due on 31 March 2025 for the 2024 calendar year.
The nil-report
This is the obligation most often missed. Under Article 26(1), a producer or importer that has been allocated quota, or to whom quota has been transferred under Article 21(1), but which placed no hydrofluorocarbons on the market during the preceding calendar year, still has to report — by submitting a nil-report.
In other words, holding quota creates a reporting duty by itself. A quiet year does not remove it; it changes what you file.
The Commission cannot distinguish "nothing to report" from "did not report". Silence looks like non-compliance, and the registration in the F-gas Portal has to be kept in good standing to remain valid.
What Annex IX actually asks for
Annex IX is titled "Data to be reported pursuant to Article 26" and it is more granular than a single tonnage figure. Depending on your role it asks, among other things, for:
- the total quantity of each substance in Annexes I, II and III produced, imported or exported, per substance rather than as a total;
- the main categories of application in which the substance is used;
- quantities placed on the market, broken down separately for feedstock uses, quantities destroyed, direct exports, production of metered dose inhalers, military equipment, and semiconductor etching or chamber cleaning;
- amounts imported but not released for free circulation and re-exported inside products or equipment;
- amounts of hydrofluorocarbons contained in pre-blended polyols;
- for destruction and feedstock entries, the identity of the undertaking that carried out the destruction or used the feedstock.
You cannot reconstruct this from invoices alone at the end of March. Quantities have to be tracked per substance and per destination category during the year, together with the counterparty for destruction, feedstock and direct export.
When an independent auditor is required
Article 26(8) applies to undertakings that report, under Article 26(1), the placing on the market of 1 000 tonnes of CO2 equivalent or more of hydrofluorocarbons during the preceding calendar year. They must ensure that the veracity of the report is confirmed, at a reasonable level of assurance, by an independent auditor, by 30 April.
The auditor is not free choice. They must be registered in the F-gas Portal and accredited — either under Directive 2003/87/EC, or accredited to verify financial statements under the law of the Member State concerned.
Article 26(7) sets a parallel duty for equipment: importers that placed pre-charged equipment as referred to in Article 19 containing at least 1 000 tonnes of CO2 equivalent of HFCs on the market, where those HFCs were not placed on the market before the equipment was charged, submit a verification report issued under Article 19(3), also by 30 April.
The auditor has to be registered in the portal before they can verify. Discovering in April that your chosen auditor is not registered leaves no time to fix it.
How the report is filed
Reporting runs through the F-gas Portal. Once your registration status is valid, the portal gives access to the reporting system — the Commission's material points users to the reporting button in the portal profile, which opens the Business Data Repository used for F-gas reporting.
The format itself is set by Commission Implementing Regulation (EU) 2024/2195, integrated into the portal's reporting tool, with the first submission in that format due on 31 March 2025 for 2024 data.
Practical order of work: confirm the registration is valid, confirm who inside the company is the account manager, assemble the Annex IX figures per substance, file by 31 March, and where the threshold is crossed, have the auditor complete verification by 30 April.
Annual report versus quota declaration
These two get confused because both go through the F-gas Portal and both involve quota.
| Annual report | Quota declaration | |
|---|---|---|
| Purpose | Says what you did last year | Asks for quota for future years |
| Timing | Every year, by 31 March | Only when the declaration window is open |
| Legal basis | Article 26 and Annex IX | Article 17 and the quota chapter |
| Next occasion | Next 31 March | By 1 April 2027, for the years 2028 to 2030 |
The Commission allocates quota annually to producers and importers, and from the allocation for 2026 onwards allocation is subject to a price of EUR 3 per tonne of CO2 equivalent. None of that replaces the annual report.
Common mistakes
- Skipping the nil-report. Holding quota and placing nothing on the market still requires a filing.
- Assuming reporting is only for bulk gas. Article 26(4) catches equipment from 10 tonnes of CO2 equivalent of HFCs.
- Reporting a single total. Annex IX asks per substance, and separately per destination category.
- Leaving the auditor to April. The auditor must already be registered in the F-gas Portal, and verification is due 30 April.
- Confusing the annual report with a quota declaration. Different articles, different windows, different purpose.
- Not recording counterparties. Destruction, feedstock and direct-export entries require identifying the undertaking involved.
- Forgetting re-exported goods. Amounts imported without release for free circulation and re-exported in products or equipment are reported separately.
- Letting the registration lapse. Reporting runs through the portal; an invalid registration blocks the route.
Checklist for the reporting season
- Registration valid in the F-gas PortalStatus valid and the account manager reachable at the registered email address.
- Your reporting trigger identifiedWhich paragraph of Article 26 applies to you, and at which threshold.
- Figures assembled per substancePer substance from Annexes I, II and III, not as a single total.
- Destination categories separatedFeedstock, destruction, direct export, MDI production, military, semiconductor use.
- Counterparties recordedThe undertaking that destroyed, used as feedstock or exported, where Annex IX asks for it.
- Equipment volumes checkedHFCs contained in products or equipment placed on the market, against the 10 t CO2e threshold.
- Nil-report consideredIf quota was held or transferred but nothing was placed on the market.
- Auditor engaged and registeredWhere 1 000 t CO2e or more was placed on the market, well before 30 April.
- Both dates in the calendar31 March for the report, 30 April for verification.
Frequently asked questions
What is the deadline?
31 March each year, for the preceding calendar year, under Article 26. Where verification by an independent auditor is required, that is due by 30 April.
I hold quota but placed nothing on the market. Do I report?
Yes. Article 26(1) requires a producer or importer that was allocated quota, or had quota transferred to it under Article 21(1), to submit a nil-report if it placed no hydrofluorocarbons on the market during the preceding calendar year.
I only import pre-charged equipment. Does reporting apply?
It can. Article 26(4) applies to undertakings that placed 10 tonnes of CO2 equivalent or more of HFCs, or 100 tonnes of CO2 equivalent or more of other fluorinated greenhouse gases, contained in products or equipment on the market.
When do I need an auditor?
Under Article 26(8), when you report the placing on the market of 1 000 tonnes of CO2 equivalent or more of hydrofluorocarbons. The auditor must be registered in the F-gas Portal and accredited under Directive 2003/87/EC or to verify financial statements under national law.
What exactly do I have to report?
The data listed in Annex IX, which is broken down per substance and separately by category — feedstock, destruction, direct export, metered dose inhalers, military equipment, semiconductor use, pre-blended polyols and more — including the identity of the counterparty where relevant.
Is the annual report the same as a quota declaration?
No. The annual report under Article 26 covers what happened last year. A quota declaration requests quota for future years and is only possible when the window is open; the next one runs by 1 April 2027 for 2028 to 2030.
Where is the report submitted?
Through the reporting system reached from the F-gas Portal. The format is set by Implementing Regulation (EU) 2024/2195 and integrated into the portal's reporting tool.
What if my registration is not valid at reporting time?
Reporting runs through the portal, so the practical answer is to restore the registration first. Registration has to be kept up to date to remain valid, and the Commission can refuse, suspend or cancel it under the implementing regulation.
Official sources
Article 26 and Annex IX were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
Reporting formats and portal screens change between years. The article references here were checked on the verification date shown at the top of the page. Confirm the current requirements in the portal before filing.
This is general information prepared by EgoLog from the regulation and official Commission material. It is not legal, accounting or audit advice.
Which paragraph of Article 26 applies to your undertaking, and whether a threshold is crossed, depends on your own figures. Where it is unclear, ask the European Commission or your national competent authority before the deadline rather than after it.