Cabledger
A CBAM certificate portfolio manager that runs the new ITMO 10%-cap as an optimization problem and generates the EU Registry XML for your annual declaration.
An EU importer of steel, cement, aluminium, fertilizers, or hydrogen has to surrender CBAM certificates against the embedded emissions of everything it brings across the border. Until eleven days before this idea was generated, the math was a straight liability calculation. The May 13, 2026 draft rule changed that: internationally transferred mitigation outcomes (ITMOs) now count as carbon price paid, but only up to 10% of reported emissions, with eligibility that varies by host country. Suddenly the declarant has a genuine cost-minimization problem under a regulatory cap, and a spreadsheet is the wrong tool to solve it.
The compliance or trade lead at an EU importer of CBAM-covered goods (steel, cement, aluminium, fertilizers, hydrogen) — the person who owns the quarterly certificate purchase and personally answers for the annual declaration. The CBAM-obligated declarant population is regulation-defined and enumerable, which makes the buyer list concrete rather than guessed at.
The ITMO 10%-cap draft rule was published May 13, 2026, retroactive to January 1, 2026, with feedback closing June 10 — a confirmed signal with a sub-30-day first-mover window.
The 10%-cap portfolio problem did not exist eleven days before the run — the strongest possible 'just became buildable' answer.
Two confirmed signals but a single-run footprint and no cluster evidence (xref=2, inbound=0).
Two confirmed regulation and fragmentation signals plus a solver mechanism born directly of a days-old rule make this far more than a generic compliance dashboard. The 'why nobody did it' answer is the strongest possible kind: the 10%-cap portfolio problem did not exist eleven days before the run.
Single-run footprint with no cluster evidence kept convergence low, and the incumbent blindspot is shallow — there is no structural cost stopping an existing carbon-accounting vendor from bolting on an ITMO solver. The rule itself is still a draft implementing regulation, so the cap mechanics could shift after the June 10 feedback close.
Genesis doesn't invent in isolation — Cabledger shares architecture with, or powers, these ideas.
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