EU Releases CBAM Verification and Accreditation Operational Guidelines

On August 24, 2026, the European Commission issued the Carbon Border Adjustment Mechanism (CBAM) Verification and Accreditation Guidelines, providing the first systematic operational guidance for third-party verification work after CBAM enters its implementation period (from January 1, 2026). The document is aimed at third-party verifiers in non-EU regions and National Accreditation Bodies (NABs) in EU Member States, detailing the processes, standards, and compliance requirements for carbon emissions data verification.

Main Contents

I. Core Concepts of CBAM Verification

1. Scope of Coverage: Six categories of goods—cement, electricity, chemicals (hydrogen), fertilizers, iron and steel, and aluminum—identified by CN codes.
2. Types of Emissions:
• Direct Emissions: Emissions from production processes and consumed heat/cold (including special greenhouse gases such as N₂O and PFCs).
• Indirect Emissions: Only counted for specific goods (cement, fertilizers, sinter, etc.) for emissions from electricity generation.
3. Embedded Emissions: Based on installation-level emissions, attributed to each production process, plus the embedded emissions of precursors, divided by the functional unit (usually metric tons, or "tons of clinker" for cement, "kg of nitrogen" for fertilizers, "kWh" for electricity), resulting in the Specific Embedded Emissions (SEE).
4. Precursors: CBAM goods used in the production of complex goods that themselves have embedded emissions. Actual data for precursors must come from verification reports issued by accredited verifiers; otherwise, default values shall be used.
5. Specific Embedded Free Allocation (SEFA): During the transitional implementation of CBAM, to reflect the phase-out of free allowances under the EU ETS, the specific embedded free allocation shall be calculated based on CBAM benchmarks, CBAM factors, and the Cross-Sectoral Correction Factor (CSCF).

II. Verification Principles

Verification must achieve a reasonable level of assurance. Core principles include:

• Reliability: Reported data must truthfully reflect actual emissions.
• Independence: Verifiers must have no conflicts of interest with operators, the European Commission, or competent authorities.
• Professional Skepticism: Maintaining a questioning and critical assessment of evidence.
• Materiality: The quantitative materiality threshold for SEE/SEFA is 5% of the total SEE/SEFA per ton of goods; other parameters are determined by the verifier using professional judgment.
• Completeness: Covering emission sources, production processes, precursors, heat and electricity flows, etc.

III. Verification Process (Key Steps)

Verification is a risk-based, cyclical process, mainly including:

1. Pre-contractual Phase: Assess risks, independence, own capabilities, and scheduling.
2. Strategic Analysis: Understand the scale and complexity of the installation, production processes, Monitoring Plan (MP), and historical data.
3. Risk Analysis: Identify inherent risks, control risks, and verification risks, and develop a verification plan accordingly.
4. Process Analysis (Actual Verification):
• Test data flows and control activities (walkthrough tests).
• Data verification (trace back to original data sources, cross-checking, recalculation).
• Analytical procedures (trend and fluctuation analysis).
• Check correct application of monitoring methods.
5. Site Visit: In principle, must be conducted on-site, but virtual visits may be used when strict conditions are met (e.g., on-site visit conducted in the previous year, no significant changes, risks controllable), or exempted under stricter conditions (maximum once every three years).
6. Handling Misstatements and Non-conformities: All misstatements must in principle be corrected by the operator; the verifier must assess their materiality and determine the verification opinion.
7. Independent Review: Before the verification report is issued, it must undergo quality review by personnel not involved in the verification of this project.
8. Verification Report: Must include a verification statement (positive/negative/limited scope) and be submitted through the CBAM registry in English.

IV. Assessment of the Monitoring Plan (MP)

Unlike the EU ETS, CBAM requires verifiers to directly assess whether the Monitoring Plan complies with the methodology regulation:

• At the first verification or when significant changes occur, the verifier must conduct a comprehensive assessment of the MP.
• If the MP has been assessed and no non-conformities were found, simplified assessments may be conducted in subsequent years, focusing on changes and implementation.
• Assessment contents include: installation boundaries, production process definitions, data flows, control activities, measuring equipment, sampling plans, uncertainty assessments, etc.

V. Special CBAM Verification Topics

• Installation ID: At the first verification, a unique identifier must be created in the CBAM registry (country code + operator registration number + sequence number).
• Production Year: The default reporting period for precursors is the same as the production year of the complex good, unless sufficient evidence proves the actual production year is different.
• Reliance on Precursor Verification Reports: When verifying complex goods, the verification report relied upon for actual precursor data must be checked to ensure it was issued by a verifier with valid accreditation, contains a positive opinion, and the data is consistent.
• Weighted Average: For similar precursors from different sources/years, and electricity/heat from multiple sources, weighted averages must be calculated according to the methodology regulation; if claiming that a specific source is used for a specific process, sufficient evidence must be provided.
• Actual Electricity Emission Factors: Using actual values (instead of default values) must meet the conditions of "direct technical connection" or "Power Purchase Agreement (PPA)", and evidence such as smart meter data, single-line diagrams, and contracts must be provided.
• Electricity Imported as CBAM Goods: If actual emission data is used, five strict conditions must be met (PPA, no grid congestion, emissions ≤ 550g CO₂/kWh, capacity nomination matching production period, monthly intermediate reporting), and each must be confirmed item by item in the verification report.

CBAM verification bodies must complete registration in the CBAM registry within two months after obtaining CBAM accreditation. From January 2027 onwards, verification bodies will issue verification reports in the CBAM registry, enabling importers to use verified actual emissions to complete their CBAM declarations.

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