Guide
CBAM verification in 2026: what importers should prepare
When embedded emissions in a CBAM declaration are based on actual emissions, Article 8 of Regulation (EU) 2023/956 requires those declared emissions to be verified by a verifier accredited under Article 18. The 2025 verification and accreditation acts set the framework for reasonable assurance, site visits, verification reports, competence, independence, and oversight. Importers can prepare the records and supplier handoffs, but only an accredited verifier performs the verification.
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
When CBAM verification applies
Article 8 of the consolidated CBAM Regulation applies when embedded emissions are determined on the basis of actual emissions. The authorised CBAM declarant must ensure that the total actual embedded emissions declared under Article 6 are verified by a verifier accredited under Article 18.
The annual declaration may instead use official default values where the Regulation permits them. An actual-emissions calculation for a complex good can also contain a permitted default for a precursor, so keep the data basis visible at component level rather than describing every value as verified. The Article 8 rule does not mean every importer needs verification regardless of the Article 2a threshold and scope rules.
Who can act as an accredited verifier
Under Article 18 and Commission Delegated Regulation (EU) 2025/2551, accreditation is granted by a national accreditation body. A legal person seeking accreditation must demonstrate the competence, independence, impartiality, organisation, and procedures required for the relevant CBAM activity scope.
The Commission's verification page explains that EU national accreditation bodies are the competent bodies for granting CBAM accreditation. A verification company established outside the EU may apply to a national accreditation body that offers the service; the verifier is not accredited by an importer, supplier, consultant, or software provider.
What reasonable assurance means
Commission Implementing Regulation (EU) 2025/2546 requires a risk-based verification approach. The verifier's objective is to reach reasonable assurance — a high, but not absolute, level of assurance — that the operator's emissions report is free from material misstatements and material non-conformities.
Reasonable assurance does not mean every number is perfect. It is a defined verification opinion based on the records, calculations, controls, risks, and evidence the verifier evaluates.
Site visits and verification reports
A physical visit to the installation where the goods are produced is the default verification principle. Implementing Regulation (EU) 2025/2546 sets detailed conditions for a virtual visit or a waiver in specified circumstances, and requires the verification report to record the relevant visit details and reasons.
The verification report uses the Commission's electronic template and contains information about the verifier, accreditation, verification team, installation, visit activity, findings, and opinion. The report supports the authorised declarant's annual CBAM declaration and can be reviewed by the Commission and national competent authorities.
Current accreditation timing
The European Commission's verification page says the first CBAM verifiers are expected to receive accreditation around September 2026. It also says the list of accredited CBAM verifiers will be published on that official page.
Expected timing is not the same as a published accreditation. Check the Commission page and the relevant national accreditation body for the current list and status rather than relying on an earlier announcement or a provider's marketing claim.
What an importer can organise before verification
Commission Implementing Regulation (EU) 2025/2547 sets the emissions-reporting and calculation information the verification process examines. At a practical level, importers can keep the installation and operator identity, goods and production-process context, emissions-report version, calculation method, source records, supplier contact, reporting period, and unresolved questions linked together.
That preparation helps a supplier, adviser, declarant, and verifier inspect the same record. It does not make the data sufficient, complete, approved, or verified, and CBAM Pulse does not perform accreditation or verification.