Introduction:

The European Union is preparing for the definitive phase of the Carbon Border Adjustment Mechanism (CBAM), a landmark climate policy that will significantly reshape international trade compliance. Established under Regulation (EU) 2023/956, CBAM introduces a carbon pricing mechanism on specific imported goods to align them with the EU’s internal carbon market.

From 1 January 2026, accredited verification of embedded emissions will become a legal requirement for companies wishing to declare actual emissions data. This shift places accredited verifiers at the heart of CBAM compliance, financial exposure management, and cross-border carbon accountability.

Why does CBAM require Accredited Verifiers?

CBAM was introduced to:

  • Preventing carbon leakage
  • Protect EU industries subject to EU ETS carbon pricing
  • Ensure equal treatment of domestic and imported goods
  • Support global decarbonization

During the transitional phase (2023–2025), importers were required to report emissions data without purchasing CBAM certificates. However, from 2026 onward, the system becomes financially binding.

Under the definitive phase:

  • EU importers (Authorised CBAM Declarants) must purchase CBAM certificates.
  • The number of certificates depends on embedded emissions.
  • Only verified actual emissions data can be used in annual declarations.
  • Unverified data defaults to conservative emission factors published by the European Commission.

Accredited verifiers ensure emissions data is:

  • Accurate
  • Complete
  • Consistent
  • Traceable
  • Free from material misstatement

Without verification, importers face potentially higher carbon costs due to reliance on default values.

Legal framework governing CBAM verification

The CBAM verification framework is built on existing EU ETS practices and expanded through dedicated legislation.

  • The foundation is Regulation (EU) 2023/956, which establishes the CBAM system and reporting obligations.
  • Accreditation conditions and competence criteria are detailed in Commission Delegated Regulation (EU) 2025/2551
  • Verification methodologies closely align with EU ETS standards under Implementing Regulation (EU) 2018/2067.

Together, these regulations define:

  • Conditions for granting accreditation
  • Oversight and supervisory mechanisms
  • Withdrawal procedures
  • Mutual recognition across EU Member States
  • Technical competence requirements for auditors

This ensures CBAM verification maintains consistency with the EU’s established carbon compliance system.

Sectors covered under mandatory verification

From 2026, accredited verification applies to imports in the following high-emission sectors:

  • Cement
  • Iron and steel
  • Aluminium
  • Fertilisers
  • Hydrogen
  • Electricity

Verification may cover:

  • Direct embedded emissions
  • Indirect embedded emissions (where applicable)
  • Precursor materials in certain value chains

The scope may expand in future regulatory updates.

Who can become an Accredited Verifier?

Only qualified legal entities can act as accredited verifiers under CBAM. Individual consultants cannot independently perform accredited verification.

To qualify, an organization must:

  • Be a legal entity.
  • Demonstrate independence and impartiality.
  • Show technical expertise specific to the sector.
  • Meet competency standards outlined in the 2025 Delegated Regulation.
  • Obtain accreditation from a National Accreditation Body (NAB) within an EU Member State.
  • After receiving accreditation, the verifier must apply for access to the CBAM Registry through the competent authority of the Member State where the NAB is located. This application must be submitted within two months of receiving accreditation and cannot be made before September 30, 2026.
  • Once access to the CBAM Registry is granted, the verifier can submit verification reports.

Additional requirements include:

  • Existing EU ETS verifiers must extend their accreditation scope to cover CBAM activity groups.
  • New verification bodies must apply directly under the CBAM accreditation framework.
  • Verifiers may be based inside or outside the EU, provided accreditation is granted by an EU-recognised body.

The CBAM verification process in detail

CBAM verification follows a structured, risk-based approach designed to provide reasonable assurance of emissions data accuracy.

A. Monitoring Plan Review: Verifiers assess.
  • Monitoring methodologies
  • Identification of emission sources
  • System boundaries
  • Allocation methods
  • Materiality thresholds

This ensures that emissions are calculated in accordance with CBAM rules.

B. Risk Assessment: The verifier evaluates.
  • Internal control systems
  • Data management processes
  • Measurement reliability
  • Potential areas of misstatement
  • Sampling strategies

The risk analysis determines the depth and scope of verification activities.

C. Mandatory Site Visits

A key requirement in 2026 is the mandatory physical site visit for all installations during the first reporting period.

From 2027 onward:

  • Virtual visits may be permitted under defined conditions.
  • Physical visits must occur at least once every two years.

Site visits confirm operational reality, production data integrity, and monitoring system functionality.

D. Data Verification Activities: Verifiers conduct detailed checks, including.
  • Accuracy of emissions calculations
  • Review of emission factors
  • Verification of production and activity data
  • Cross-checking supporting documentation
  • Ensuring traceability and consistency
  • Identifying non-conformities
E. Reporting and Final Opinion: Conclude the verification.
  • A verification report is issued.
  • A clear opinion is provided (satisfactory or unsatisfactory).
  • Reports are submitted via standardized electronic templates in the CBAM Registry.

Technical competence and Auditor requirements

Under Commission Delegated Regulation (EU) 2025/2551, accredited verifiers must demonstrate advanced technical competencies.

Each CBAM auditor must possess:

  • Knowledge of greenhouse gas monitoring and verification principles
  • Familiarity with EU ETS-aligned methodologies
  • Understanding of sector-specific industrial processes
  • Expertise in embedded emissions calculations
  • Competence in risk assessment and data sampling
  • Ability to detect material misstatements
  • Capability to recommend corrective measures
1. Lead Auditor Responsibilities
  • Managing and coordinating the verification team
  • Supervising technical experts
  • Ensuring regulatory compliance
2. Independent Reviewer Role
  • Conducting a technical review of the verification process
  • Meeting the same competence standards as auditors
  • Demonstrating effective English communication
3. Technical Experts

Technical experts may support the team when specialised industrial knowledge is required. However:

  • They must demonstrate relevant expertise.
  • They cannot replace core auditor competence requirements.

Accreditation aligns with international standards such as EN ISO/IEC 17029 and reflects established EU ETS verification principles.

Consequences of Unsatisfactory Verification

If a verification opinion is unsatisfactory, the report must clearly outline:

  • Reasons for lack of reasonable assurance
  • Material misstatements
  • Uncorrected non-conformities
  • Scope limitations
  • Identified material issues
  • Recommended corrective actions

In such cases:

  • The importer must rely on default emission values under Regulation (EU) 2023/956.
  • There are no automatic penalties solely due to an unsatisfactory opinion.
  • Financial liability may increase due to conservative default values.

Companies can strengthen monitoring systems and address deficiencies in subsequent reporting cycles

Strategic Business Implications

1. For EU Importers
  • Begin verification planning well in advance of annual reporting deadlines.
  • Engage suppliers early to ensure verifiable data availability.
  • Assess the cost implications of default versus verified emissions.
  • Integrate carbon compliance into procurement strategies.
2. For Non-EU Producers
  • Invest in robust emissions monitoring infrastructure.
  • Engage accredited verifiers proactively.
  • Provide verified data to maintain competitiveness in the EU market.
  • Use carbon transparency as a commercial advantage.
3. For Verification Bodies
  • Expand accreditation scope to include CBAM activity groups.
  • Strengthen sector-specific industrial expertise.
  • Prepare for increased demand from 2026 onward.

Conclusion

As the definitive phase of CBAM begins in 2026, accredited verifiers will play a decisive role in ensuring the credibility, reliability, and financial integrity of emissions reporting.

Verification is no longer a procedural formality — it is a strategic compliance pillar under Regulation (EU) 2023/956

Organisations that prepare early, invest in monitoring systems, and collaborate with accredited verification bodies will be better positioned to manage carbon costs, reduce financial exposure, and maintain uninterrupted access to the EU market in a rapidly evolving carbon-regulated trade environment.

Source: Delegated regulation – EU – 2025/2551 – EN – EUR-Lex

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