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EU CBAM Verification 2026–2027: Accredited Verifiers, Evidence Requirements and the Declarant Compliance Guide

A CBAM Journal Intelligence Report

Sekason Research Limited · London

Published date: 18 August 2026


1. Executive Summary

The official Q2 2026 CBAM certificate price stands at €75.28 per tonne of CO₂e, published by the European Commission on 6 July 2026 — and every tonne of embedded emissions that an authorised CBAM declarant declares on actual values must be verified by an accredited independent verifier before the first annual declaration can be submitted by 30 September 2027. Commission Delegated Regulation (EU) 2025/2551 Annex I establishes twelve distinct CBAM accreditation activity groups, meaning a verifier accredited for iron/steel products does not automatically hold authority to verify upstream sintered ore, pig iron, or crude steel — each is a separate accreditation scope with separate evidence requirements. The European Commission confirmed on 24 July 2026 that the first accredited CBAM verifiers were expected to emerge from national accreditation bodies around September 2026, leaving compliance managers a narrow window to identify, assess, appoint, and brief verifiers for a full year of 2026 import data before the declaration deadline.


This report delivers four operational tools built directly from the primary legislative texts.

  • The 15-point Verifier Due-Diligence Checklist (Section 7.2) converts the legal requirements for a valid verification report into a structured procurement assessment that compliance managers can apply before contracting any verifier.

  • The Supplier Evidence Readiness Matrix (Section 7.3) specifies the minimum documentation a non-EU installation must provide before verification can begin, organised by evidence item, data owner, and common deficiency.

  • The RACI Framework (Section 3.2) separates the legally distinct responsibilities of the non-EU installation operator, the accredited verifier, and the authorised declarant — eliminating the attribution ambiguity that frequently creates compliance gaps.

  • The 2026–2027 Verification Readiness Timeline (Section 4.1) gives compliance managers a quarter-by-quarter action plan structured around the hard deadline of 30 September 2027.

  • Navigate to Section 6 for sector-specific verifier-scope requirements, Section 5 for financial exposure analysis, and Section 7 for the full operational framework.

EU CBAM verification 2026–2027 title slide with deadline note for 30 September 2027 and August 2026 report footer.

2. Regulatory Context


2.1 The Three-Regulation Architecture

  • FINDING: Commission Implementing Regulation (EU) 2025/2546, Article 5 establishes a 5% materiality threshold for total specific embedded emissions — the operational standard that every accredited CBAM verifier must apply to all actual-value declarations from 1 January 2026.

  • SO WHAT: A compliance manager whose verifier selection process relied only on Regulation (EU) 2023/956 has missed the accreditation scope requirements in Delegated Regulation (EU) 2025/2551 and the prescribed verification report content in Implementing Regulation (EU) 2025/2546, both of which directly determine whether the verification report produced is legally adequate for annual declaration purposes.

  • NOW WHAT: Obtain and read Implementing Regulation (EU) 2025/2546, specifically Article 5 (materiality threshold) and Article 6 with its Annex (verification report content requirements), before shortlisting any verifier by Q4 2026.


Three regulations govern EU CBAM verification. Each operates at a distinct level of the legal architecture, and understanding the division of labour between them is the starting point for any compliance manager assessing whether current arrangements are adequate.


Regulation (EU) 2023/956 is the primary instrument. Articles 8(1) and 18 establish the core verification obligation and the requirement for national accreditation body (NAB) oversight. Annex VI specifies the minimum content a CBAM verification report must contain. These provisions create the obligation — they do not define how the obligation is satisfied.


Commission Delegated Regulation (EU) 2025/2551 fills the first operational gap. It prescribes the conditions under which NABs grant CBAM-specific accreditation: verifier competence, verification procedures, quality systems, documentation standards, and personnel performance requirements. Critically, it establishes the twelve distinct CBAM accreditation activity groups in Annex I — the taxonomy that determines whether any given verifier's accreditation actually covers a declarant's specific supply chain. A verifier's accreditation certificate lists the activity groups it covers. If an installation's production process falls outside those listed groups, the verification report that verifier produces is non-conforming.


Commission Implementing Regulation (EU) 2025/2546 addresses the verification process itself: the risk-based methodology, physical site-visit requirements, the 5% materiality threshold, and the complete prescribed format for the verification report. This is the operational specification document. A compliance manager cannot assess whether a verifier's methodology is adequate without understanding what this instrument requires.

Regulation

Key provisions

Operational implication for declarant

Regulation (EU) 2023/956

Arts 8(1), 18, Annex VI

Creates verification obligation; specifies minimum verification report content; sets NAB accreditation requirement

Commission Delegated Regulation (EU) 2025/2551

Arts 2–5, Annex I

Defines verifier accreditation conditions; establishes 12 CBAM activity groups; governs NAB oversight and verifier competence

Commission Implementing Regulation (EU) 2025/2546

Arts 5, 6, Annex

Sets 5% materiality threshold; prescribes verification process and site-visit requirements; defines complete verification report format

2.2 What the Definitive Regime Changed on 1 January 2026

  • FINDING: From 1 January 2026, any authorised CBAM declarant using actual embedded emissions in its annual declaration must ensure those emissions are verified by an accredited verifier — a requirement that did not exist under the transitional period, and for which no retrospective remedy is available if 2026 monitoring data is later found to be insufficient.

  • SO WHAT: Monitoring methodologies, production records, and emissions calculations for goods imported since 1 January 2026 are already the evidential foundation for the first annual declaration — evidence gaps created during 2026 cannot be retrospectively filled before the 30 September 2027 deadline.

  • NOW WHAT: Audit whether all key supplier installations have a current monitoring plan compliant with CBAM methodology requirements by Q4 2026, before any verification engagement begins.


The EU CBAM definitive regime changed two parameters simultaneously on 1 January 2026: the certificate purchasing obligation became binding, and any declarant relying on actual embedded emissions values must now ensure those emissions are verified by an accredited independent verifier — two requirements that simply did not exist during the transitional period, which ran from 1 October 2023 to 31 December 2025. During the transitional period, authorised declarants submitted quarterly reports on embedded emissions but faced no financial obligation and no requirement for third-party verification.


From 1 January 2026, CBAM certificates must be purchased at prices derived from EU ETS auction averages and surrendered against declared embedded emissions by the annual declaration deadline. Where a declarant uses actual embedded emissions rather than Commission default values, those emissions must be verified by an accredited independent verifier. There is no opt-in, no transitional arrangement, and no grace period within the definitive regime on this requirement.


The practical implication is temporal. Monitoring plans at non-EU installations need to have been operational from the start of 2026 for the 2026 data to be verifiable. A supplier whose emissions monitoring approach was adequate for transitional reporting but does not meet definitive-regime standards — because the monitoring plan is not current, the production boundaries are not correctly defined, or the calculation methodology is not compliant — cannot fix that retrospectively. The installation's 2026 data will either be verifiable or it will not. If not, the declarant faces the choice of using default values with the applicable mark-up cost, or requesting supplier corrections that the verifier will still need to review and assess.


The European Commission confirmed CBAM successfully entered into force on 1 January 2026, with customs and CBAM Registry integration operational from that date. Definitive-period default values and benchmarks were published on 13 February 2026, establishing the alternative cost basis against which actual-value verification must be economically assessed.


2.3 UK CBAM: A Different and Later Framework

  • FINDING: The UK Emissions and Verification Regulations 2026 remain in draft as of 18 August 2026 — meaning the UK verification framework is not yet legally finalised, while the EU framework has been fully operative under Delegated Regulation (EU) 2025/2551 and Implementing Regulation (EU) 2025/2546 since 1 January 2026.

  • SO WHAT: Businesses importing into both the EU and UK cannot assume that an accredited EU CBAM verifier automatically satisfies UK obligations — the UK framework requires verifier accreditation to ISO/IEC 17029:2019 and ISO 14065:2020, a different standard from the EU's NAB-based CBAM-specific accreditation system under Delegated Regulation (EU) 2025/2551.

  • NOW WHAT: Monitor HMRC's publication of the Emissions and Verification Regulations through Q4 2026 and do not commit to a UK verifier accreditation standard before the secondary legislation is finalised.


UK CBAM begins on 1 January 2027 under Finance Act 2026, Part 5. The intended direction of the UK verification framework is clear: actual emissions data must be verified, verifiers must be independent and accredited to an eligible accreditation body, physical site visits are required subject to exceptions, and a 5% materiality threshold applies. The Emissions and Verification Regulations 2026, however, were not among the secondary legislation laid on 13 July 2026 — which included the Administrative


Provisions Regulations 2026, the Calculation of CBAM Rate and Determination of Carbon Price Relief Regulations 2026, and the Transitory Provision Regulations 2026. HMRC's current policy summary identifies the Emissions and Verification Regulations as draft legislation due to be laid later in 2026.

HMRC published guidance on 16 July 2026 on carbon pricing verification forms, including verifier accreditation and independence requirements. This guidance confirms the ISO-standard accreditation route but does not constitute the final secondary legislative instrument.


The practical consequence for compliance managers importing into both regimes is clear: the EU framework and UK framework require separate assessment. EU CBAM verifier accreditation does not constitute UK CBAM verifier qualification under the currently expected UK framework. Planning for both regimes simultaneously, while prudent, must be done on the basis that the UK accreditation standard may be confirmed differently from what current drafts indicate.

Feature

EU CBAM

UK CBAM

Legal basis

Reg. (EU) 2023/956; Delegated Reg. (EU) 2025/2551; Implementing Reg. (EU) 2025/2546

Finance Act 2026, Part 5; secondary legislation (ongoing)

Live date

1 January 2026

1 January 2027

Verification obligation

Mandatory for actual-value declarations under Art. 8(1)

Intended — secondary legislation pending

Accreditation standard

NAB-based, 12 CBAM-specific activity groups

ISO/IEC 17029:2019 and ISO 14065:2020 (draft)

Materiality threshold

5% — Implementing Reg. (EU) 2025/2546, Art. 5

5% — draft regulations

Electricity sector

In scope

Not in initial UK CBAM scope

Verification secondary legislation

Final — in force from 1 January 2026

Draft — not laid as of 18 August 2026

Record retention guidance

No EU CBAM-specific retention period confirmed as of research date

6 years — HMRC guidance, 16 July 2026


3. Compliance Obligations


3.1 The Declarant's Non-Delegable Verification Duty

  • FINDING: Article 5(7) of Regulation (EU) 2023/956 explicitly places legal responsibility for verified CBAM declarations with the authorised declarant — not with any customs agent, software platform, or third-party CBAM service provider — with certificate surrender obligations due by 30 September 2027 covering all 2026 import year data.

  • SO WHAT: A declarant that has outsourced CBAM declaration preparation remains the legally liable party if the embedded emissions used in the declaration were not properly verified by an appropriately accredited verifier — the Article 26 penalty and any residual surrender obligation fall on the declarant, not the service provider.

  • NOW WHAT: Review all third-party CBAM service agreements by Q4 2026 to confirm they specify verifier accreditation requirements, the evidence the third party will obtain from non-EU installations, and the liability position if verification is later found to be deficient.


Article 5(7) of Regulation (EU) 2023/956 removes any ambiguity about what outsourcing achieves and what it does not — outsourcing declaration preparation to a customs agent, software platform, or CBAM specialist does not transfer the underlying legal liability. The authorised declarant remains the accountable party regardless of which entity has prepared the declaration, calculated the embedded emissions, or uploaded data to the CBAM Registry.


Outsourcing the mechanics of declaration preparation is permissible. Outsourcing the legal responsibility is not. If a third-party service provider selects a verifier without the correct activity group accreditation, obtains insufficient evidence from the non-EU installation, or relies on a monitoring methodology that does not meet the definitive-regime standard, the resulting compliance deficiency belongs to the declarant.


Service agreements for CBAM compliance support are typically written to define the scope of the provider's service, not to allocate regulatory liability. An agreement that commits a CBAM consultancy to "assist with declaration preparation" without specifying verifier accreditation requirements, evidence standards, or remedies for deficient verification leaves the declarant legally exposed while the service provider has delivered what it contracted to deliver.


The questions to direct to any third-party service provider are specific:

  • Which accredited verifier is being engaged for each installation?

  • On what basis has the provider confirmed that verifier's accreditation scope covers the relevant CBAM activity groups?

  • What evidence will the provider obtain from the non-EU installation, and what is the escalation path if that evidence is insufficient for verification?

  • If satisfactory answers are not available by Q4 2026, the compliance manager should not treat the outsourcing arrangement as an adequate substitute for internal oversight.


3.2 The Installation Operator's Role and the Evidence Chain

  • FINDING: The CBAM Registry is the mandatory channel through which verified embedded emissions flow from non-EU installation to authorised declarant, with the first declaration and certificate surrender deadline of 30 September 2027 requiring all verified data to be in the Registry before submission.

  • SO WHAT: A declarant whose supplier has not engaged an accredited verifier — or whose supplier's monitoring methodology is non-compliant — will have no verified data available in the Registry by the declaration deadline, regardless of how well the declarant has managed its own obligations.

  • NOW WHAT: Initiate supplier-readiness assessments for all non-EU installations generating more than 5% of your estimated annual CBAM certificate liability by Q4 2026.

Flowchart titled EU CBAM Verification: The Actor Chain shows four navy panels linked by red arrows and a warning box.

The Commission has confirmed the actor chain: the non-EU installation operator monitors and calculates embedded emissions; the accredited verifier verifies those emissions at installation level; the verification report data flows to the CBAM Registry; the authorised declarant retrieves that data and incorporates it into the annual declaration. These are four roles with four sets of legal obligations. The declarant operates at the end of the chain — and the chain must be complete for the declaration to be valid.


That downstream position creates structural risk. The activities that make verification possible — maintaining a compliant monitoring plan, generating auditable production records, providing the evidence package the verifier requires — happen at the non-EU installation, outside the declarant's direct control. A supplier that has not engaged an accredited verifier by the time the verification engagement must begin, or whose monitoring methodology cannot support verified actual-value reporting, creates a problem the declarant cannot resolve unilaterally.


Supplier-readiness assessment is not a courtesy exercise. It is a required component of the declarant's own compliance risk management, and it needs to happen well before the verification engagement is scheduled.

Task

Non-EU Installation Operator

Accredited Verifier

Authorised Declarant

Establish and maintain emissions monitoring plan

Responsible

—

Requests confirmation

Monitor and record embedded emissions

Responsible

—

—

Calculate specific embedded emissions

Responsible

Reviews and verifies

—

Provide production records and evidence package

Responsible

Reviews

Requests

Appoint accredited verifier

Responsible (typically)

—

Oversees and confirms accreditation

Facilitate site visit (where required)

Facilitates

Responsible

—

Apply 5% materiality threshold

—

Responsible

—

Issue verification report

—

Responsible

—

Upload verified data to CBAM Registry

—

Responsible

—

Retrieve verified data from CBAM Registry

—

—

Responsible

Submit annual CBAM declaration

—

—

Responsible

Surrender CBAM certificates

—

—

Responsible

Retain declarant compliance file

—

—

Responsible

3.3 Actual Values vs Default Values: The Verification Choice

  • FINDING: The default value mark-up schedule under Implementing Regulation (EU) 2025/2621 imposes penalties of +10% in the first year, rising to +20% and +30% in subsequent years — applied to the official Q2 2026 certificate price of €75.28/tCO₂e.

  • SO WHAT: For any installation whose verified actual emissions intensity is materially below the applicable default value, the cost of verification is recouped within the first declaration cycle through reduced certificate liability — making the decision not to verify a quantifiable financial loss, not a conservative compliance choice.

  • NOW WHAT: For every installation where annual import volume exceeds 1,000 tonnes of CBAM-covered goods, run a default-versus-actual cost comparison using the Q2 2026 certificate price of €75.28/tCO₂e before Q1 2027 to determine where verification effort is commercially justified.


Default values are available. The Commission published definitive-period default values and benchmarks on 13 February 2026. A declarant may use those values without engaging a verifier. The regulatory cost of that choice is the mark-up schedule.


At the Q2 2026 certificate price of €75.28/tCO₂e, a +10% first-year mark-up adds €7.53/tCO₂e to every certificate purchased. For illustrative planning purposes only — actual liability depends on verified installation-specific embedded emissions — a declarant importing 10,000 tonnes of a CBAM-covered good at an assumed embedded emissions intensity of 1.8 tCO₂e/tonne faces a base certificate liability of approximately €1.35 million. The first-year default mark-up on that illustrative position adds approximately €136,000. By Year 3, the same assumed position with a +30% mark-up adds approximately €406,000. These are not abstract figures. They are the compounding cost of an available regulatory choice that many compliance teams have not yet subjected to a formal cost-benefit calculation.

Factor

Actual Values

Default Values

Verification required

Yes — accredited verifier, correct activity group scope

No

Certificate cost basis

Verified installation-specific emissions intensity

Commission published default value

Mark-up applied

None

+10% (Year 1), +20% (Year 2), +30% (Year 3+)

Financial benefit

Reduced liability where actual intensity below default

No verification cost

Financial risk

Verification cost; risk of failed verification requiring fallback to default

Higher certificate cost; mark-up penalty compounds each year

Where appropriate

High-volume imports; installations with compliant monitoring infrastructure

Low-volume imports; suppliers without monitoring data; transitional-year default election

The decision framework is direct: estimate the verified actual intensity for each significant installation (even using an unverified supplier estimate as a planning input), compare it against the relevant default value, apply the Q2 2026 certificate price, factor in the expected cost of verification, and determine whether actual-value reporting is economically justified for that installation in year one. The calculation should be run for each installation separately — not at portfolio level, which can mask high-mark-up exposures within a larger supply chain.


4. Key Dates and Deadlines


4.1 The 2026 Compliance Calendar

  • FINDING: The European Commission confirmed on 24 July 2026 that first accredited CBAM verifiers are expected around September 2026 — leaving approximately 12 months between the emergence of the first accredited verifiers and the first annual declaration deadline of 30 September 2027.

  • SO WHAT: Twelve months is not adequate lead time for a declarant with multiple installations requiring verification across multiple sectors — a full verification cycle (evidence preparation, verifier engagement, site visit, report issuance, Registry upload) spans several months per installation, and verifier capacity is constrained by definition in the year accreditation begins.

  • NOW WHAT: Complete verifier contracting for all priority installations by 31 December 2026 — waiting until 2027 risks being unable to secure an accredited verifier with the correct activity group scope before peak verification demand in mid-2027.


EU CBAM verification readiness timeline infographic with blue-red deadline stages, compliance icons, and risk table with prices and penalties

Date

Milestone

Regime

Who must act

Required action

1 January 2026

EU CBAM definitive regime begins

EU

Authorised declarants

Begin monitoring actual-value emissions for all relevant installations; actual-value verification obligation active

13 February 2026

Definitive default values and benchmarks published

EU

Authorised declarants

Compare default values against estimated actual intensities to assess verification economics

31 March 2026

Initial authorisation application deadline

EU

Authorised declarants

Confirm authorisation status; address any outstanding authorisation gaps

23 June 2026

Commission clarifies actual vs default values guidance

EU

Authorised declarants

Review clarified guidance on conditions for actual-value declarations

6 July 2026

Q2 2026 CBAM certificate price published — €75.28/tCO₂e

EU

Compliance managers / CFOs

Update financial models with confirmed Q2 2026 price

24 July 2026

Commission publishes accreditation state-of-play

EU

Compliance managers

Identify NABs offering CBAM accreditation; begin mapping verifier market

~September 2026

First accredited CBAM verifiers expected

EU

Compliance managers

Begin verifier due-diligence using 15-point checklist; commence contracting for priority installations

31 December 2026

Target date for completing verifier contracting

EU

Compliance managers

Finalise verifier appointments for all Tier 1 and Tier 2 installations

1 January 2027

UK CBAM begins

UK

UK importers

UK CBAM obligations commence — separate regime requiring separate verification framework

February 2027

CBAM certificate purchasing opens for 2026 imports

EU

Authorised declarants

Begin purchasing certificates based on estimated 2026 embedded emissions liability

31 July 2027

Internal deadline for completing all installation-level verification

EU

Authorised declarants

All verification reports received; Registry data confirmed; approximately two months before declaration

30 September 2027

First annual declaration and certificate surrender

EU

Authorised declarants

Submit annual declaration; surrender certificates covering 2026 embedded emissions

4.2 The 30 September 2027 Deadline in Detail

  • FINDING: Under Articles 6(1) and 22 of Regulation (EU) 2023/956 as amended, the first annual CBAM declaration covering 2026 import data and the corresponding certificate surrender are both due 30 September 2027 — and under Article 26, payment of any non-compliance penalty does not extinguish the residual certificate surrender obligation.

  • SO WHAT: A declarant that fails to complete verification before 30 September 2027 must either switch to default values with the mark-up cost or miss the declaration deadline — and in either case the Article 26 penalty and the certificate surrender obligation are additive, not alternative.

  • NOW WHAT: Build 30 September 2027 into all internal project management as a hard regulatory deadline with no grace period, and confirm that all installation-level verification is complete no later than 31 July 2027, allowing approximately two months for declarant-side review, Registry reconciliation, and certificate calculation.


The 30 September 2027 deadline is a composite obligation. It is not simply a form submission. On that date, an authorised CBAM declarant must have submitted the annual declaration covering all 2026 import data and surrendered the CBAM certificates corresponding to the total embedded emissions in that declaration after applicable adjustments for third-country carbon price relief.


The certificate surrender mechanism requires advance planning. CBAM certificate purchasing opens in February 2027. Declarants need an accurate estimate of their 2026 embedded emissions liability before purchasing — and that estimate must ultimately reconcile with the verified actual values or confirmed default values used in the declaration. Declarants who have not completed verification by mid-2027 are estimating their certificate requirements without a verified figure, which creates both procurement risk and potential shortfall risk at surrender.


The Article 26 enforcement structure matters here. Failure to surrender sufficient certificates by 30 September 2027 triggers a financial penalty equivalent to the EU ETS excess-emissions penalty for the relevant year. Payment of that penalty does not resolve the surrender obligation — the declarant still owes the certificates. There is no net saving from missing the deadline; the penalty is an additional cost on top of the underlying CBAM liability.


Working backwards from 30 September 2027: all verification should be complete by 31 July 2027 at the latest. That leaves approximately two months for the declarant to review verification reports received from verifiers and the Registry, confirm total embedded emissions figures, calculate certificate requirements, purchase any additional certificates needed, and submit the declaration. Verification completion in July requires engagement to have been underway from early 2027 — which, in turn, requires verifier contracting to have been completed in Q4 2026.


5. Financial Exposure and Risk


5.1 CBAM Certificate Price and the Cost of Unverified Emissions

  • FINDING: The official Q2 2026 CBAM certificate price is €75.28/tCO₂e, published by the European Commission on 6 July 2026 based on EU ETS auction averages — and from 2027, the price will be updated weekly rather than quarterly, materially increasing volatility in financial planning.

  • SO WHAT: The shift to weekly pricing from 2027 means declarants cannot build a stable forward cost estimate on a quarterly-update basis as they can currently, and the certificate liability at €75.28/tCO₂e represents a material financial exposure for mid-sized importers even at current price levels.

  • NOW WHAT: Use the official Q2 2026 price of €75.28/tCO₂e as the current planning benchmark in all financial models built before Q3 2026 price publication, and update models when Q3 2026 prices are published.


The Q2 2026 CBAM certificate price of €75.28/tCO₂e is the correct official price to use for current compliance planning. Unofficial EU ETS spot-price estimates should not be substituted — the Commission calculates CBAM certificate prices from EU ETS auction averages under a specific methodology, not from spot prices, and the two figures may differ materially. The Q3 2026 price will be published by the Commission and should be used to update financial models when available.


From 2027, the weekly pricing mechanism will introduce volatility that quarterly modelling cannot capture. Declarants who have built internal financial models on a quarterly-update basis will need to revise their approach — either by updating models more frequently or by building a certificate price uncertainty range into their financial planning.


For illustrative planning purposes only — actual liability depends on verified installation-specific embedded emissions. The following table uses the official Q2 2026 certificate price of €75.28/tCO₂e and assumed emissions intensities that are not verified sector averages.

Import volume (tonnes)

Assumed intensity (tCO₂e/tonne)

Illustrative base liability (€)

+10% default mark-up (€)

+30% default mark-up (€)

1,000

0.5

37,640

3,764

11,292

5,000

1.0

376,400

37,640

112,920

10,000

1.8

1,355,040

135,504

406,512

50,000

2.5

9,410,000

941,000

2,823,000

At any significant import volume, certificate liability is a material financial exposure. The default mark-up is not a marginal administrative cost — at Year 3's +30%, it can exceed the cost of obtaining verified actual-value data for most large installations by a considerable margin.


5.2 The Penalty for Non-Compliance with Certificate Surrender

  • FINDING: Under Article 26 of Regulation (EU) 2023/956, failure to surrender required CBAM certificates by 30 September 2027 attracts a penalty equivalent to the EU ETS excess-emissions penalty for the year of importation — and payment of that penalty does not extinguish the obligation to surrender the outstanding certificates.

  • SO WHAT: The Article 26 penalty and the residual certificate surrender obligation run simultaneously — treating the penalty as an alternative to compliance doubles the financial exposure rather than resolving it.

  • NOW WHAT: Record both the Article 26 penalty exposure and the residual certificate surrender obligation as separate line items in your compliance risk register by Q3 2026, and confirm that neither is assumed in your risk modelling to discharge the other.


The Article 26 enforcement structure is frequently misread as analogous to a late-payment fine — pay the charge, and the underlying obligation is settled. It is not. The Regulation is explicit on this point: the penalty is additive. A declarant that fails to surrender required certificates by 30 September 2027 faces both the penalty for that failure and the continued obligation to surrender what it owes.


The practical consequence is that non-compliance is always more expensive than compliance. The penalty adds a financial charge on top of the full underlying CBAM liability — which remains payable regardless. There is no net saving from missing the deadline, only an additional cost on top of the original obligation.


Regulation (EU) 2023/956 provides a separate and more severe enforcement pathway for importers who introduce CBAM-covered goods without any attempt to engage with the CBAM framework — that is, without authorisation and without any declaration. Authorised declarants face the Article 26 surrender-shortfall penalty structure. Importers who have not engaged with the CBAM system at all face higher sanctions under the Regulation's separate circumvention provisions. This confirms that the Regulation treats different types of compliance failure differently, with the severest penalties reserved for deliberate avoidance rather than administrative shortfall.


5.3 Verifier Market Costs: What Is and Is Not Known

  • FINDING: As of 18 August 2026, no authoritative EU-wide published standard fee for accredited CBAM verifiers exists — the market is unregulated, nascent, and the first CBAM accreditations are only expected around September 2026, meaning supply is structurally constrained relative to anticipated 2027 verification demand.

  • SO WHAT: Cost estimates from verification companies currently offering CBAM services reflect individual commercial positioning in a pre-accreditation market and are not reliable benchmarks for budget planning.

  • NOW WHAT: Request indicative fee quotes from at least three verification providers per sector by Q4 2026 and document the pricing range in your compliance risk register as a market reference point.


No authoritative EU-wide published tariff or fee schedule for CBAM verifiers exists. Several verification companies have begun marketing CBAM verification services ahead of formal accreditation, but these are commercial offerings positioned before the accreditation process has concluded, not regulated fee schedules. In a market where supply is just beginning to form, pricing will reflect availability pressures as much as cost structure.


Requesting indicative quotes from at least three providers per sector, for specific installation types and activity group scopes, produces a working budget range and reveals early information about verifier availability by geography and sector. Early movers in Q3–Q4 2026 are likely to encounter less competition for verifier capacity than those who begin the procurement process in Q1 2027, when verification demand begins to peak ahead of the declaration deadline.


6. Sector-Specific Impact Analysis


6.1 Accreditation Activity Groups: Why Sector Determines Verifier Scope

  • FINDING: Commission Delegated Regulation (EU) 2025/2551 Annex I establishes 12 distinct CBAM accreditation activity groups — including separate groups for sintered ore/pig iron/DRI/crude steel, ferro-alloys, iron/steel products, unwrought aluminium, aluminium products, cement, hydrogen/ammonia, nitric acid, urea/mixed fertilisers, electricity, indirect emissions, and CCUS.

  • SO WHAT: A verifier accredited for iron/steel products does not hold automatic authority to verify sintered ore, pig iron, DRI, crude steel, or ferro-alloys — each is a separate accreditation scope — meaning an importer sourcing from an integrated steel mill may need a verifier holding multiple activity-group accreditations covering the entire production chain.

  • NOW WHAT: Map every supplier installation to its specific CBAM accreditation activity group(s) under Delegated Regulation (EU) 2025/2551 Annex I by Q4 2026 before beginning verifier selection.


Accreditation under the CBAM framework is not sector-generic. The twelve activity groups represent distinct production processes with distinct emissions profiles, monitoring requirements, and evidence standards. A verifier holds accreditation for specific groups — and those listed groups determine what it can legally verify, not what it claims experience in.


A declarant who selects a verifier on the basis of general CBAM experience or brand reputation, without confirming the precise activity group coverage on the verifier's accreditation certificate, risks receiving a verification report that is non-conforming for one or more of the installation's production activities. A non-conforming report cannot support actual-value emissions in the annual declaration.

Sector

CBAM Activity Group(s) — Delegated Reg. (EU) 2025/2551 Annex I

Scope complexity

Iron and steel — upstream

Sintered ore / pig iron / DRI / crude steel

Separate from finished products; upstream production stage

Iron and steel — alloys

Ferro-alloys

Separate from pig iron and finished products

Iron and steel — products

Iron/steel products

Does not cover upstream production stages

Aluminium — primary

Unwrought aluminium

Separate from downstream products

Aluminium — products

Aluminium products

Does not cover unwrought production

Cement

Cement

Single group; note indirect electricity dependency

Hydrogen and ammonia

Hydrogen/ammonia

Separate from nitric acid and fertiliser groups

Nitric acid

Nitric acid

Separate from urea/mixed fertilisers

Fertilisers

Urea/mixed fertilisers

Separate from nitric acid and hydrogen/ammonia

Electricity

Electricity

Specific scope for electricity imports

Indirect emissions

Indirect emissions

Cross-sector; required where electricity-embedded emissions are declared on actual basis

CCUS

CCUS

Carbon capture, utilisation and storage

6.2 Steel: Multiple Groups and Complex Upstream

  • FINDING: Steel verification under Delegated Regulation (EU) 2025/2551 Annex I spans at least 4 distinct accreditation activity groups — sintered ore/pig iron/DRI/crude steel, ferro-alloys, iron/steel products, and potentially indirect emissions — with Implementing Regulation (EU) 2025/2546 requiring evidence on precursor inputs, production routes, direct and indirect emissions, and allocation among co-products across the full production chain.

  • SO WHAT: A steel importer sourcing hot-rolled coil from an integrated mill that produces sinter, crude steel, and finished products cannot assume a verifier accredited for iron/steel products has scope to verify the upstream production stages — a non-conforming verification report on any production stage invalidates the actual-value declaration for that installation.

  • NOW WHAT: Request a process-flow diagram from each steel supplier by Q4 2026 showing production inputs, intermediate products, and finished goods, and use it to identify every relevant activity group in the verification scope before appointing a verifier.


Steel presents the most structurally complex verification challenge in the CBAM framework. An integrated steel mill — one that processes iron ore through sinter, pig iron or DRI, crude steel, and then finished products — may fall across three or four separate accreditation activity groups. Each production stage carries its own emissions profile and evidence requirements.


Implementing Regulation (EU) 2025/2546 requires verification evidence to cover precursor materials and quantities, production quantities by CN code, production routes, direct and indirect emissions, specific embedded emissions calculations, and applicable methodologies. For an integrated steel producer, precursor data means iron ore, coking coal, and scrap inputs; production routes mean the distinction between blast furnace and electric arc furnace pathways; and allocation of embedded emissions requires documented calculation of how emissions are distributed across co-products at each production stage.


India provides direct context for the scale of this challenge. India was the EU's largest import partner for iron and steel in 2024 by value at €3.9 billion, representing 10.5% of EU iron and steel import value — a figure that grew by 89.2% between 2019 and 2024. Declarants sourcing steel from major Indian producers will face verification complexity spanning multiple activity groups across large integrated facilities, where verifier selection and evidence preparation are more consequential than in simpler single-product supply chains. Jindal Stainless, one of India's largest stainless steel producers with FY2024 standalone sales of 2,174,610 tonnes, stated in January 2026 that it was waiting for clarity on how verification would be conducted and which entities would be authorised to verify emissions calculations. That uncertainty has been resolved at the regulatory level — but the practical capacity to deliver accredited verification for installations of that scale is still developing.


6.3 Aluminium: Unwrought vs Products, and Indirect Emissions

  • FINDING: Commission Delegated Regulation (EU) 2025/2551 Annex I creates 2 separate aluminium activity groups — unwrought aluminium and aluminium products — plus a dedicated indirect electricity emissions accreditation scope, and the Commission's verification report template requires specific evidence on electricity-import conditions where actual electricity-based emissions are declared on an actual-value basis.

  • SO WHAT: An aluminium declarant importing semi-fabricated products who appoints a verifier accredited only for unwrought aluminium will receive a verification report invalid for the aluminium products activity group — and where electricity emissions are material to the declaration, the absence of indirect electricity emissions scope compounds the deficiency.

  • NOW WHAT: Before contracting any aluminium verifier, obtain written confirmation that their accreditation covers both the relevant product activity group and the indirect electricity emissions scope under Delegated Regulation (EU) 2025/2551 Annex I.


Aluminium production is electricity-intensive. The EU CBAM framework treats indirect electricity emissions — those arising from the electricity consumed in the production process — as a significant dimension of the embedded emissions calculation, with a dedicated accreditation scope for their verification. The verification report template explicitly requires evidence on electricity-import conditions where actual electricity-based emissions are declared.


The distinction between unwrought aluminium and aluminium products is legally significant. A verifier accredited for primary aluminium smelting does not hold automatic accreditation for extrusions, rolled products, or other downstream semi-fabricated goods. Declarants importing aluminium products must confirm the appropriate activity group before contracting — the group listed on the verifier's accreditation certificate must match the products being verified.


6.4 Fertilisers and Hydrogen: Three Distinct Groups

  • FINDING: Fertiliser and hydrogen verification spans 3 separate accreditation activity groups under Delegated Regulation (EU) 2025/2551 Annex I — nitric acid, urea/mixed fertilisers, and hydrogen/ammonia — meaning a single integrated fertiliser facility producing ammonia, urea, and nitric-acid-derived products may require a verifier holding accreditation across all three groups.

  • SO WHAT: A fertiliser declarant that appoints a verifier accredited for only one of the relevant activity groups will receive a partial verification report — inadequate to support actual-value declarations for the products outside that verifier's accreditation scope.

  • NOW WHAT: Obtain a product-by-product CN code breakdown from each fertiliser and hydrogen supplier by Q4 2026 and confirm which accreditation activity groups each product falls into before specifying verifier requirements in any engagement brief.


The fertiliser and hydrogen verification landscape is fragmented by design. The three activity groups reflect distinct production processes and emissions profiles. Nitric acid production involves catalytic oxidation of ammonia, with distinct process-related emissions requiring dedicated verification scope. Urea and mixed fertilisers involve carbon-containing compounds whose embedded emissions calculation covers both production process emissions and embedded carbon content.


Hydrogen/ammonia activity covers production processes where the primary embedded emissions parameter is the hydrogen production route and its associated energy and feedstock inputs.

An integrated fertiliser complex may produce all three product categories from a shared upstream base. In that configuration, a verifier accredited for urea/mixed fertilisers cannot produce a compliant verification report for the nitric acid or hydrogen/ammonia outputs from the same facility. Declarants importing from integrated facilities need either a single verifier accredited across all three relevant groups, or a coordinated multi-verifier engagement with a clear scope division — and both require advance planning.


6.5 Cement and Electricity: Production Boundary and the Dual-Scope Requirement

  • FINDING: Cement has 1 dedicated accreditation group and electricity has 1 dedicated group under Delegated Regulation (EU) 2025/2551 Annex I — but the Commission's verification report template requires evidence of electricity-import conditions where actual electricity-based emissions are declared, creating a dual-scope requirement for cement and other electricity-intensive production.

  • SO WHAT: A verifier appointed for a cement installation that lacks the indirect electricity emissions accreditation scope cannot produce a compliant verification report where electricity-embedded emissions are declared on actual values — forcing the declarant to either use default values for electricity or find a second verifier with the indirect emissions scope.

  • NOW WHAT: Before appointing a verifier for any cement or electricity-intensive installation, obtain written confirmation that the verifier holds both the primary CBAM activity group accreditation and the indirect electricity emissions scope under Delegated Regulation (EU) 2025/2551 Annex I.


Two separate accreditation scopes are required before an actual-value cement declaration can include electricity-embedded emissions: the cement activity group and the indirect electricity emissions group, each listed separately under Delegated Regulation (EU) 2025/2551 Annex I. A verifier accredited only for the cement activity group cannot produce a verification report that covers electricity-embedded emissions declared on an actual-value basis — the accreditation gap creates an immediate compliance deficiency in the verification report.


Cement production involves high direct emissions from the calcination of limestone — a chemical process that releases CO₂ independent of energy source. Electricity is nonetheless a significant production input, and where the cement declarant wishes to declare electricity-embedded emissions on an actual-value basis, the verification report must include evidence on the conditions under which that electricity was produced and transmitted. The accreditation requirement follows directly: the verifier must hold both the cement activity group accreditation and the indirect electricity emissions accreditation scope.


For electricity imports specifically, the dedicated electricity accreditation group reflects the distinct evidentiary requirements of confirming actual electricity emission factors, which depend on the specific conditions under which the electricity was produced and transmitted, as assessed by the verifier under Implementing Regulation (EU) 2025/2546. Declarants importing electricity should confirm that their verifier's accreditation explicitly covers the electricity activity group, not simply a general CBAM accreditation that does not list electricity specifically.


7. Practical Action Framework


7.1 Step 1: Build the Installation Register

  • FINDING: The verification obligation under Article 8(1) of Regulation (EU) 2023/956 attaches at installation level — not at declarant level — with the first annual declaration covering all 2026 import year data due 30 September 2027, requiring every installation supplying actual-value goods to be verified by an accredited verifier before that date.

  • SO WHAT: A declarant without a complete installation-level inventory cannot assess verification scope, prioritise effort, budget accurately for verifier costs, or confirm that all verification is on track — the absence of the register is itself a compliance control failure, not simply an administrative gap.

  • NOW WHAT: Build a complete installation register by Q4 2026, tiering installations by import volume and default-versus-actual cost differential to determine which installations to prioritise for verification first.


The installation register is the foundation document for all subsequent verification planning. Without it, there is no reliable basis for scope assessment, verifier selection, evidence preparation, or deadline monitoring. It is not a complex document, but it must be complete and current as at the start of the verification planning cycle.

Field

Description

Installation name

Legal name of the non-EU installation

Country

Jurisdiction

Sector

CBAM sector (steel, aluminium, cement, fertilisers, hydrogen, electricity)

CN codes

Commodity codes of CBAM-covered goods supplied from this installation

CBAM activity group(s)

Specific group(s) under Delegated Reg. (EU) 2025/2551 Annex I

Estimated annual import volume

Tonnes of CBAM-covered goods imported from this installation in 2026

Estimated embedded emissions

Estimated tCO₂e based on available supplier data

Monitoring basis

Actual values or default values (current and intended)

Verifier required

Yes/No — and if yes, activity group scope required

Supplier evidence status

Confirmed / In progress / Not started

Priority tier

1 (high volume, actual values) / 2 (medium) / 3 (low volume, default values)

Use the priority tier to allocate verifier contracting effort. Tier 1 installations — those with high import volumes where actual-value reporting generates material cost savings over default values — warrant verifier engagement in Q4 2026. Tier 3 installations — where default values are economically rational — require only a documented default-value election, with no verification engagement needed.


7.2 Step 2: The 15-Point Verifier Due-Diligence Checklist

  • FINDING: The verification report that a declarant relies upon must record the verifier's accreditation number, accreditation body, accreditation expiry date, and applicable accreditation scope per Regulation (EU) 2023/956 Annex VI and Implementing Regulation (EU) 2025/2546 Article 6 and Annex — meaning any deficiency in the verifier's credentials is directly traceable in the declarant's regulatory record.

  • SO WHAT: Appointing a verifier without conducting structured due diligence on accreditation scope, activity group coverage, sector competence, and site-visit capacity creates a foreseeable risk of receiving a non-conforming verification report that cannot legally support actual-value emissions in the annual declaration.

  • NOW WHAT: Apply the 15-point checklist to every prospective verifier before signing any verification contract, and reject any verifier that fails to provide written confirmation of its CBAM activity group accreditation scope.


Apply this checklist at the contracting stage, before any verification engagement begins. Retain the completed checklist in the declarant verification file as evidence of due diligence in verifier selection.

Point

What to verify

How to verify

Pass criterion

Fail consequence

1

National Accreditation Body (NAB) name

Verifier's CBAM accreditation certificate

Named EU NAB that offers CBAM accreditation

Verifier not accredited by qualifying NAB

2

CBAM accreditation certificate number

Accreditation certificate

Unique certificate number confirmed

Cannot confirm CBAM-specific accreditation

3

Accreditation validity period and expiry date

Expiry date on certificate

Valid through at least Q3 2027

Risk of accreditation lapse before declaration deadline

4

CBAM activity groups listed on certificate

Annex I groups stated on certificate

All relevant activity groups for this installation explicitly listed

Scope does not cover required activity group(s)

5

Coverage of all relevant activity groups

Cross-reference against installation register

Every group in the register is covered by this verifier's accreditation

Partial coverage — must source additional verifier or scope expansion

6

Sector-specific competence documentation

CV, reference list, or NAB assessment evidence

Documented experience in the relevant CBAM sector(s)

No demonstrable sector competence beyond general CBAM claim

7

Installation type and production-process experience

Reference installations or prior verification reports

Experience with comparable production processes

First-time verification in this production context without documented competence

8

Geographic capability for non-EU site visits

Verifier's staff location and travel policy

Confirmed capacity to conduct physical site visits in the relevant country

Remote-only without documented risk-based justification

9

Physical site-visit capacity and timeline

Availability confirmation for 2026–2027 verification window

Confirmed availability for site visits before July 2027

Cannot schedule site visit before declaration deadline

10

Verification team qualifications

CVs of assigned verification team members

Team members hold relevant technical qualifications for the CBAM activity group(s)

Assigned team lacks required technical background

11

Independence and impartiality declaration

Written declaration from verifier

No commercial, advisory, or financial relationship with the installation

Conflict of interest identified

12

CBAM Registry access and upload capability

Verifier confirms Registry registration and access

Verifier can upload verification data to CBAM Registry

Cannot upload data to Registry

13

Verification report format compliance

Verifier's standard report template

Template covers all Implementing Reg. (EU) 2025/2546 Annex content requirements

Report format does not meet prescribed content requirements

14

Availability for 2026 data within required timeline

Signed engagement letter or scope of work

Written commitment to complete verification of 2026 data by July 2027

Cannot commit to the required timeline

15

Fee, scope, and timeline proposal

Written fee proposal

Scope, methodology, timeline, and fee agreed in writing before engagement begins

Terms unconfirmed prior to commencement

7.3 Step 3: The Supplier Evidence Readiness Matrix

  • FINDING: Implementing Regulation (EU) 2025/2546 Article 6 and its Annex specify the minimum content of a CBAM verification report — including production processes, production routes, direct and indirect emissions, precursor information, and quantities by CN code — with a 5% materiality threshold under Article 5 applied across all declared data, implicitly defining the minimum evidence the non-EU installation must hold before verification begins.

  • SO WHAT: A supplier that cannot produce a current monitoring plan, production boundary documentation, and raw emissions calculation data before the verifier's engagement begins will delay or prevent verification completion — a timeline risk to the declarant's 30 September 2027 declaration regardless of how well the declarant has managed its own controls.

  • NOW WHAT: Issue a formal supplier evidence request to every significant non-EU installation by Q4 2026, using the matrix below as the request template, and require written confirmation of evidence readiness before confirming the verification engagement timeline.


Issue this matrix to each significant supplier as a structured readiness request. Do not allow the verification engagement to be confirmed until the supplier has responded to each item.

Evidence item

Data owner

Source document

What the verifier checks

Common deficiency

Declarant control action

Installation identity and location

Installation operator

Regulatory registration; site permits

Identity matches CBAM Registry record

Outdated or inconsistent registration details

Request current registration documents; verify against Registry

Current monitoring plan (version and date)

Installation operator

Approved monitoring plan

Plan current; version approved; meets CBAM methodology requirements

No monitoring plan; plan not updated for definitive regime

Request current approved plan; flag as critical gap if absent

Production boundary definition

Installation operator

Process map; system boundary document

Boundary consistent with CBAM embedded emissions methodology

Boundaries drawn to exclude high-emission processes

Request boundary diagram and definition document; flag inconsistencies

Direct emissions data (by process, by period)

Installation operator

Fuel consumption logs; process measurement records

Calculations traceable to source measurements; complete for 2026

Monthly data gaps; estimation without documented basis

Request raw measurement logs for full 2026 period

Indirect emissions data (where applicable)

Installation operator

Electricity consumption records; emission factor source

Electricity quantities and applicable emission factor confirmed and sourced

Emission factor not from an authoritative source

Confirm source of electricity emission factor; cross-check against recognised national grid factor

Precursor materials and quantities

Installation operator

Purchase records; mass balance documentation

Precursor quantities reconcile with production output and CN code quantities

Precursor data not segregated by CBAM-covered product

Request product-specific precursor allocation documentation

Production quantities by CN code

Installation operator

Production logs; customs export records

Quantities match declared import data at declarant level

CN code classification inconsistent between installation and import records

Cross-reference with declarant's import documentation before verification

Specific embedded emissions calculation

Installation operator

Emissions calculation workbook

Calculation method compliant with CBAM methodology; traceable to source data

Calculation methodology not documented or not traceable to approved plan

Request calculation methodology document alongside workbook

Site diagram and production flow

Installation operator

Plant layout; process flow diagram

Physical layout consistent with system boundary documentation

Outdated diagram; process changes not reflected

Request current diagram signed by installation manager

Emissions measurement methodology documentation

Installation operator

Methodology document; calibration records

Methodology documented; applied consistently; measurement instruments calibrated

Methodology claimed but not documented; calibration records missing

Request methodology document and most recent calibration certificates

7.4 Step 4: Managing the Verification Engagement

  • FINDING: Implementing Regulation (EU) 2025/2546 Article 5 establishes a 5% materiality threshold for total specific embedded emissions — applied by the verifier using a risk-based methodology that includes physical site visits where the verifier's own risk assessment determines them necessary, not where the declarant's schedule makes them convenient.

  • SO WHAT: A declarant that has not confirmed whether physical site visits are planned for each installation faces both a schedule risk — international site visits require significant logistics lead time — and a governance risk, because if the verifier determines a site visit is necessary and the declarant has not planned for it, the verification timeline cannot proceed as intended.

  • NOW WHAT: At contracting stage, require each verifier to confirm in writing whether a physical site visit is planned for each installation, and factor adequate lead time (typically several weeks minimum) for any international site visit into the verification schedule.


The risk-based methodology in Implementing Regulation (EU) 2025/2546 means the verifier determines the scope and conduct of the verification engagement — including whether a physical site visit is required — based on its own professional risk assessment, not the declarant's scheduling preferences or commercial convenience. The verifier conducts this assessment across the installation's emissions data, monitoring plan, and evidence package. Where the risk assessment identifies elevated uncertainty — complex production processes, multiple precursor inputs, high materiality exposures, or prior evidence of data quality issues — a physical site visit is required. The implementing regulation does not allow the declarant to waive a site visit; the determination rests with the verifier.


Physical site visits to non-EU installations require advance planning. Visits to India, China, Turkey, Ukraine, or other major CBAM exporting countries involve travel scheduling, visa arrangements, access agreements with the installation, and coordination with the installation operator's own production calendar. A significant lead time — typically several weeks — should be built into the verification timeline for any international site visit.


When the verifier identifies a problem. If the verifier identifies a material misstatement in the installation's emissions data — a calculation error, an unsupported methodology claim, or a gap in the evidence record — the verification cannot be concluded with a positive opinion until the issue is resolved. The installation operator must provide corrected data or additional evidence. The verifier must then re-assess the corrected information before issuing its opinion. This correction cycle adds meaningful additional time — potentially several weeks — to the verification process. Build an explicit buffer into the timeline at each significant installation to accommodate a potential correction cycle.

If the verifier cannot issue a positive verification opinion because the evidence is fundamentally insufficient, the declarant loses the option of using actual values for that installation's goods in the relevant declaration. The fallback is default values with the applicable mark-up. This outcome should be anticipated explicitly in the compliance risk register for any installation where monitoring infrastructure has not been confirmed as adequate.


At the contracting stage, confirm what the verifier's escalation process is if issues arise mid-engagement: who at the installation, at the verifier, and at the declarant is notified of emerging problems, and within what timeframe. A defined escalation protocol reduces the risk of a material issue going unresolved until it is too late to address before the declaration deadline.


7.5 Step 5: Build the Declarant Verification File

  • FINDING: Under Article 5(7) of Regulation (EU) 2023/956, the declarant's compliance responsibility for verified emissions cannot be delegated — and HMRC's UK CBAM record-keeping guidance published on 16 July 2026 specifies a six-year retention period for CBAM records, providing the applicable benchmark for declarant verification file retention planning in the absence of a published EU CBAM-specific retention period as of the research date.

  • SO WHAT: A declarant that holds only the final verification report — without the underlying evidence bundle, accreditation certificates, due-diligence documentation, and Registry confirmation — cannot demonstrate the full compliance trail in the event of a regulatory enquiry or audit.

  • NOW WHAT: Create a declarant verification file for each installation by the date of the first verification report receipt, and retain all contents for a minimum of six years from the date of the relevant annual CBAM declaration.


The declarant verification file is the declarant's internal compliance record. It is distinct from the CBAM Registry — the Registry holds submitted declaration data; the verification file holds the evidence that the declaration data is defensible. In any regulatory audit or enforcement action, the verification file is the primary document the declarant produces to demonstrate that its declaration was based on properly verified, adequately evidenced embedded emissions data.


The file for each installation should contain, at minimum:

  1. The completed 15-point verifier due-diligence checklist, with supporting documents obtained from the verifier

  2. The verifier's CBAM accreditation certificate, showing the issuing NAB, accreditation number, expiry date, and listed activity groups

  3. The signed verification report covering the relevant reporting period, including the verifier's opinion and all prescribed content under Implementing Regulation (EU) 2025/2546 Annex

  4. The supplier evidence bundle as submitted to the verifier — monitoring plan, emissions calculations, production records, precursor data

  5. The monitoring plan version number and date used as the evidential basis for verification

  6. CBAM Registry submission records and confirmation of verified data upload

  7. Internal compliance sign-off confirming the declaration was reviewed, the verification file was complete, and the submission was approved


The six-year retention benchmark from HMRC's 16 July 2026 UK CBAM guidance is the most specific published guidance available on CBAM record retention as of the research date. No EU CBAM-specific declarant record retention period has been confirmed in the sources reviewed. EU CBAM compliance managers should apply the six-year benchmark as a minimum planning standard. For declarations covering 2026 imports submitted by 30 September 2027, a six-year retention period runs through to 30 September 2033.


8. Strategic Outlook


8.1 The Verifier Market Capacity Risk

  • FINDING: The European Commission confirmed on 24 July 2026 that first accredited CBAM verifiers were expected to emerge from national accreditation bodies around September 2026 — and India alone accounted for €3.9 billion of EU iron and steel imports in 2024, representing 10.5% of EU iron and steel import value, having grown 89.2% between 2019 and 2024.

  • SO WHAT: The verifier market is supply-constrained by definition in the year accreditation begins, and the sectors with the greatest concentration of CBAM-covered import value face the most acute availability risk in the first verification cycle.

  • NOW WHAT: Begin supplier conversations about verifier engagement for all installations where annual import volume exceeds 1,000 tonnes of CBAM-covered goods by Q3 2026, treating verifier availability as a procurement risk with real commercial consequences.


The verification market is forming in the same period that the 2026 compliance year data is being generated. National accreditation bodies are processing CBAM accreditation applications; the Commission's 24 July 2026 state-of-play confirmed that EU/EEA-established verification companies apply to their national NAB, while third-country verification companies can apply to an EU national accreditation body offering CBAM accreditation. The pool of accredited verifiers will grow as accreditation decisions are issued, but in Q3 and Q4 2026 that pool is minimal.


The scale of potential demand relative to available supply creates a structural constraint. Jindal Stainless, one of India's largest stainless steel producers with FY2024 standalone sales of 2,174,610 tonnes, stated in January 2026 that it was waiting for clarity on how verification would be conducted and which entities would be authorised to verify emissions calculations. That uncertainty has been resolved at the regulatory level by the publication of Delegated Regulation (EU) 2025/2551 and Implementing Regulation (EU) 2025/2546. The practical capacity to deliver accredited verification for installations of that scale across a single declaration cycle is still developing.


ArcelorMittal Nippon Steel India, which tracks CBAM methodology and reports emissions to European customers on a quarterly basis, and Tata Steel, which explicitly identifies EU CBAM as a material regulatory and market risk in its 2025–26 integrated report, represent the kind of large-scale EU-exposed installations where verification demand in a single company could absorb a significant share of accredited verifier capacity in a given quarter. Declarants importing from comparable installations should not assume that verification can be scheduled on demand in Q1 or Q2 2027.


8.2 CBAM Scope Expansion: New Verification Obligations on the Horizon

  • FINDING: The European Commission welcomed Council agreement in June 2026 to extend CBAM to selected downstream goods and reinforce anti-circumvention measures — adding new CN codes and potentially new accreditation requirements beyond the current 12 activity groups under Delegated Regulation (EU) 2025/2551 Annex I.

  • SO WHAT: Declarants who build their verification arrangements around current CBAM product scope will need to revise those arrangements when the expansion regulation is formally adopted — and newly covered goods will carry corresponding verification obligations from their date of entry into force.

  • NOW WHAT: Monitor the formal adoption of the CBAM scope expansion regulation and update the installation register within 30 days of publication to capture any new goods or CN codes that fall within the expanded verification scope.


The June 2026 Council agreement to extend CBAM to selected downstream goods represents the first significant scope expansion of the framework since Regulation (EU) 2023/956 was adopted. The specific goods to be covered and the implementation timeline have not yet been confirmed in final adopted legislation as of the research date. The anti-circumvention measures are separately significant: they address trade re-routing and minor processing designed to avoid CBAM obligations, and are expected to increase scrutiny applied to supply chains where CBAM-covered goods enter the EU via intermediate countries.


For compliance managers building verification arrangements, the practical implication is to treat the installation register as a live working document rather than a one-time scoping exercise. Scope expansion creates new installations and new goods that may trigger verification requirements. Anti-circumvention measures may affect how third-country processing is treated for CBAM purposes. Both developments are worth monitoring actively as the expansion legislation progresses.


8.3 The First Declaration Cycle as an Infrastructure Test

  • FINDING: The 30 September 2027 deadline for the first annual CBAM declaration covering 2026 imports is the first operational test of whether the EU verification infrastructure — expected to begin issuing accreditations around September 2026 — can handle the declaration volumes required by the definitive regime.

  • SO WHAT: Declarants that delay verifier engagement until mid-2027 risk finding accredited verifier capacity fully committed at the precise point when verification completion is critical for the declaration deadline, with no regulatory mechanism for an extension.

  • NOW WHAT: Check the Commission's CBAM verification page at minimum monthly from Q3 2026 to track the emergence of accredited verifiers by activity group and identify providers suitable for your specific installation portfolio.


The first annual declaration cycle will test every element of the EU CBAM verification infrastructure simultaneously: NAB accreditation readiness, verifier capacity by sector and geography, CBAM Registry integration between verifiers and declarants, and the Commission's ability to process first-cycle declarations at scale. No element of this infrastructure has been tested operationally before.


The Commission's dedicated CBAM verification page — published in its current form with a state-of-play update on 24 July 2026 — is the primary channel through which progress on accreditation will be communicated. As national accreditation bodies issue CBAM accreditation certificates, updates on verifier availability by sector will emerge. Tracking these monthly from Q3 2026 gives compliance managers early visibility of which activity groups have accredited verifier coverage and where market gaps persist.


The most significant risk in the first declaration cycle is convergence: declarants who delay verifier engagement will attempt to secure accredited verification capacity simultaneously in mid-2027, at the point when verification demand is at its highest and the declaration deadline is approaching. A compliance manager who has contracted verifiers for all Tier 1 installations, issued formal supplier evidence requests, and confirmed site-visit schedules by 31 December 2026 has the operational runway needed to complete verification, reconcile Registry data, and meet the 30 September 2027 first declaration deadline.


9. Frequently Asked Questions


Q1. How do I verify that a prospective CBAM verifier's accreditation scope actually covers my supplier's CBAM activity group?

Request the verifier's CBAM accreditation certificate from the issuing national accreditation body and confirm that the specific activity groups under Delegated Regulation (EU) 2025/2551 Annex I relevant to your supplier's production processes are explicitly listed on the certificate. A general claim of CBAM competence is not sufficient — the Annex I activity groups must appear by name. Cross-reference the listed groups against your installation register for each installation before signing any verification contract.


Q2. What documents and data should I require from a non-EU installation before the verification engagement begins?

At minimum, request the current approved monitoring plan with its version number and approval date, a production boundary definition document, 2026 direct and indirect emissions data with source measurement records, precursor material quantities and allocation documentation, and production quantities by CN code. Use the Supplier Evidence Readiness Matrix in Section 7.3 as the structured request template. Do not confirm the verification engagement timeline until written confirmation of evidence readiness has been received from the installation — an incomplete evidence package will delay verification and puts the 30 September 2027 declaration deadline at risk.


Q3. What happens if the verifier identifies a material misstatement in my supplier's embedded emissions data?

The verifier cannot issue a positive verification opinion while a material misstatement remains unresolved. The installation operator must provide corrected data or additional evidence, and the verifier must re-assess before concluding the engagement. This correction cycle adds meaningful additional time — potentially several weeks — to the verification timeline. If the misstatement cannot be resolved because the underlying evidence is fundamentally insufficient, the declarant loses the option of using actual values for that installation's goods in the declaration and must fall back to Commission default values with the applicable mark-up under Implementing Regulation (EU) 2025/2621.


Q4. What information must appear in an EU CBAM verification report before I can use actual embedded emissions in my annual declaration?

Under Regulation (EU) 2023/956 Annex VI and Implementing Regulation (EU) 2025/2546 Article 6 and Annex, the verification report must contain: the installation's identity and location; the verifier's accreditation number, issuing NAB, accreditation expiry date, and listed activity group scope; verification team details; site visit information; the monitoring plan version used; verification objective, scope, and criteria; production processes and routes; direct and indirect emissions data; precursor information; production quantities by CN code; specific embedded emissions; applicable methodologies; and the verifier's opinion. A report missing any prescribed element is non-conforming and cannot be used to support actual-value declarations in the annual submission.


Q5. What should I do if an accredited verifier with the correct activity group scope is unavailable for my installation before the 30 September 2027 deadline?

Document the market search and the absence of available accredited capacity as part of your declarant compliance file. Assess whether a third-country verification company with access to an EU national accreditation body may hold or be able to obtain the relevant scope. If no accredited verifier with the correct scope can be secured in time, the fallback is default values with the applicable mark-up for that installation — a worse financial outcome but a documented and defensible compliance position, provided the decision to use default values is clearly recorded in the declarant file alongside evidence of the failed market search.


Q6. How can I distinguish a genuinely accredited CBAM verifier from a company merely offering CBAM consultancy or ISO/GHG verification services?

A CBAM-accredited verifier holds a certificate issued by an EU national accreditation body specifically for CBAM verification under Delegated Regulation (EU) 2025/2551, with the specific Annex I activity groups it is authorised to verify listed on the certificate. ISO/IEC 17029 or ISO 14065 accreditation, or experience with EU ETS or other GHG verification programmes, does not constitute EU CBAM-specific accreditation under Article 18 of Regulation (EU) 2023/956. Request the CBAM accreditation certificate, confirm the issuing NAB is an EU national accreditation body operating under the Delegated Regulation, and verify the activity groups listed. Companies marketing CBAM verification services without CBAM-specific NAB accreditation are providing advisory support — not legally valid verification for the purposes of actual-value declarations.


Sources Used in This Report



Scope and Disclaimer

This report is published by CBAM Journal, operated by Sekason Research Limited (Company No. 14339910), London. It is provided for regulatory intelligence and general information purposes only. It does not constitute legal, financial, investment, engineering, or compliance-certification advice. Readers should not rely solely on this report when making compliance, commercial, or legal decisions — independent professional advice should be obtained for specific circumstances. References to named companies are for informational and illustrative purposes only and do not constitute an endorsement. Company-reported figures are attributed to the named company as source. This report reflects information available as of 18 August 2026; regulatory frameworks are subject to change. Full disclaimer and terms: cbamjournal.com/disclaimer.


© 2026 Sekason Research Limited · cbamjournal.com · contact@sekasonresearch.com

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