Guide
CBAM supplier evidence: preparing records for verification
A CBAM supplier-evidence record should show what the figure is, which installation and production process it covers, its reporting period and method, which monitoring plan, emissions report, and source records support it, and whether accredited verification exists. Supplier-reported, default-value, actual-emissions, and verified states are not interchangeable. CBAM Pulse helps organise preparation; it does not verify, certify, approve, or decide completeness.
Last updated: 15 July 2026Sources: Regulation (EU) 2023/956 — consolidated 20 October 2025Commission Implementing Regulation (EU) 2025/2546 — verificationCommission Implementing Regulation (EU) 2025/2547 — emissions calculationCommission Delegated Regulation (EU) 2025/2551 — verifier accreditationEuropean Commission — Verification of CBAM emissions
Record the basis of each emissions figure
Regulation (EU) 2023/956 distinguishes official default values from actual emissions. Record that basis next to the value, unit, goods, and period. A supplier-reported value is not automatically actual emissions that have been verified under Article 8.
When actual emissions are used in a declaration, the declared actual emissions require verification by an accredited verifier. Keep the verification report as a separate referenced record rather than turning a generic evidence tick into a verification status.
Keep the installation and calculation context together
Commission Implementing Regulation (EU) 2025/2547 ties the operator's calculation record to the installation, production process, reporting period, monitoring plan, emissions report, method, and source data. Evidence references are more useful when they preserve those relationships instead of pointing to an unlabeled file or number.
Use the supplier request to identify the goods and CN code, operator and installation, period, production process, requested method information, report version, and supporting-record references. The request is preparation, not a prescribed verification template.
Version revisions and verification status separately
Keep the received date, reporting period, report version, superseded value, replacement value, and reason for change. Separately record whether the value is supplier-reported, based on an official default, calculated as actual emissions, or accompanied by an accredited verifier's report.
That status record helps the operator, declarant, adviser, and verifier inspect the same history. It does not prove that the evidence is sufficient or that verification passed.
What the accredited verifier does
Under Commission Implementing Regulation (EU) 2025/2546, the accredited verifier applies a risk-based process to the monitoring approach, calculation, controls, and evidence under a reasonable-assurance standard. The verification report records a satisfactory or unsatisfactory opinion; issuing the report does not by itself mean the data received a satisfactory opinion. Delegated Regulation (EU) 2025/2551 places accreditation with national accreditation bodies and sets competence and independence requirements.
CBAM Pulse can surface missing references and open questions. It does not perform that assessment, accredit the reviewer, issue an opinion, certify evidence, or provide an adviser conclusion.