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Over the past few weeks, I’ve explored several of the operational capabilities that organisations need to become UK CBAM ready, including Product & Import Visibility, Supplier & Emissions Data, Financial Readiness, and Reporting & Audit Readiness.
Each capability addresses a different part of the challenge. Together, they form The Six Capabilities of CBAM Readiness™, a practical framework to help organisations prepare for UK CBAM in a structured and manageable way.
This time, I’d like to step back from the operational detail and look at the bigger picture.
How does UK CBAM fit into the organisation?
It’s a question that comes up regularly in conversations with leadership teams.
Encouragingly, very few are looking to create something completely new.
Instead, they’re looking for a practical way to incorporate UK CBAM into the way the organisation already operates.
I think that’s exactly the right approach.

Start with the organisation you already have

One of the most positive aspects of the conversations I’ve been having is that leadership teams already recognise they have many of the capabilities they need. The challenge isn’t creating new departments or redefining existing roles. It’s understanding how those capabilities come together to support UK CBAM in a coordinated and proportionate way.
Procurement already works closely with suppliers.
Finance already plans for future costs and commercial impacts.
Customs and trade teams understand imports.
Compliance teams manage regulatory obligations.
Operational teams know their products and supply chains better than anyone.
UK CBAM doesn’t replace those responsibilities.
It simply creates another opportunity for those teams to work together towards a common objective.

Leadership creates clarity

Every organisation will approach this differently, and that’s exactly as it should be. Leadership & Governance isn’t about introducing unnecessary bureaucracy or creating another committee. It’s about giving people clarity so they understand where responsibility sits, how decisions are made and how information moves across the organisation.
Clear ownership.
Clear responsibilities.
Clear communication.
When those foundations are in place, teams can continue doing what they do best, while leadership has confidence that UK CBAM is being managed in a consistent and coordinated way.
For me, that’s what good governance looks like.

Make UK CBAM part of business as usual

Most organisations already manage financial reporting, customs compliance, procurement, operational risk and a wide range of other regulatory responsibilities. UK CBAM should become another of those well-managed business activities rather than a separate initiative competing for attention.
The objective isn’t to make UK CBAM the centre of the organisation.
It’s to make it part of how the organisation already operates.
That is where Leadership & Governance provides real value. It creates the structure that allows every other capability within the framework to work together effectively, giving leadership confidence that responsibilities are understood, progress can be monitored and decisions are based on consistent information.

Where next?

Leadership & Governance is the first capability within The Six Capabilities of CBAM Readiness™ because it establishes the foundation on which the remaining capabilities are built. Once ownership is clear, it becomes much easier to develop Product & Import Visibility, engage suppliers, forecast financial exposure and prepare for reporting.
Every organisation will be at a different stage of its UK CBAM journey.
Some will already have many of these capabilities in place. Others may be just starting to consider how UK CBAM fits within their organisation.
Understanding where you are today is the best place to begin.
If you’d like to understand how your own organisation compares across all six capabilities, the free UK CBAM Readiness Assessment provides a practical place to start. Developed around The Six Capabilities of CBAM Readiness™, it has been designed to help leadership teams assess their current position, identify opportunities for development and begin planning the next steps towards UK CBAM readiness.
About James Napier
James Napier is the founder of Notch, an author and sustainability expert specialising in carbon regulation and operational readiness. He is the creator of The Six Capabilities of CBAM Readiness™, a practical framework designed to help organisations build the leadership, data, financial, reporting and workflow capabilities needed to manage CBAM with confidence.
Through his work with importers, manufacturers and professional advisers, James focuses on helping organisations move from regulatory awareness to operational readiness, creating the visibility needed for confident reporting, stronger financial planning and better commercial decisions.

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