CBAM accredited verifiers: who can verify and how to check status

When is CBAM verification required?

Article 8(1) of Regulation (EU) 2023/956 applies where embedded emissions are determined on the basis of actual emissions. The authorised CBAM declarant has to ensure that the total embedded emissions declared in the annual CBAM declaration are verified by a verifier accredited under Article 18, applying the verification principles in Annex VI.

Article 8 is triggered by the use of actual emissions. Whether a declaration line should rely on actual emissions or on official default values is a separate route decision. A complex good can combine actual emissions for its own production process with default values for one or more precursors under Article 15 of Implementing Regulation (EU) 2025/2547; the Commission's verification guidance of 24 August 2026 states that verifiers then check whether the correct default value was selected.

Under Article 8(2), for goods produced in a third-country installation registered under Article 10, the declarant may use verified information that the operator discloses under Article 10(7). The operator's own duty, in Article 10(5)(b), is to ensure that the embedded emissions it determines are verified by an accredited verifier. Registration of the operator, or the sharing of a file, does not by itself make information verified; the operator-to-declarant disclosure path is mapped in a separate guide.

Who can carry out CBAM verification?

Under Article 18(2) of Regulation (EU) 2023/956, a national accreditation body may, on request, accredit a legal person as a verifier where it considers that the person can apply the Annex VI verification principles. Article 1(1) of Delegated Regulation (EU) 2025/2551 defines a verifier as a legal person accredited by a national accreditation body for CBAM purposes at the time a verification report is issued. Accreditation for the relevant scope therefore has to be in place on the date the report is issued, not only when an engagement is agreed.

The Commission's guidance explains that some verification work can take place while an accreditation process is still running, partly because the national accreditation body has to witness verification activity. The report itself can be issued only once accreditation has been granted.

Article 3 of the Delegated Regulation determines which body to approach. An applicant established in an EU Member State applies to the national accreditation body of that Member State, unless a listed exception applies — for example, where that body does not accredit the verification activities concerned or has not completed peer evaluation for the activity groups sought. An applicant established outside the EU applies to a national accreditation body of any Member State that provides CBAM accreditation. A body that cannot accredit a third-country applicant has to give reasons and a list of bodies that may be able to (Article 3(6)).

The Commission's guidance adds that national accreditation bodies are not obliged to accept applicants established outside the EU, and that a third-country applicant should apply to one body only. Under Article 23, Member States and competent authorities accept accreditation certificates, and recognise verification reports, from verifiers accredited by national accreditation bodies that have successfully undergone peer evaluation, subject to the conditions in that Article.

Accreditation is granted only by a national accreditation body. An importer, supplier, installation operator, adviser or software provider cannot grant it, and CBAM Pulse does not assess or confirm any verifier's status.

What does CBAM accreditation cover?

CBAM accreditation is scoped. Article 1(3) of Delegated Regulation (EU) 2025/2551 defines the scope of accreditation as the CBAM activity groups in Annex I for which accreditation is sought or granted, and every request covers one or more of those groups (Article 3(3)). Accreditation for one activity group does not extend to goods in another.

The Commission's guidance adds two scope points. Verifying an installation that produces electricity exported to the EU as a good requires activity group LI. Activity group LII (indirect emissions) is assessed together with groups I to V, and the guidance states that it cannot be granted as a stand-alone scope.

When a national accreditation body grants, renews or extends accreditation, it issues an accreditation certificate (Article 6). The certificate identifies the accreditation body, the verifier's name and unique accreditation identification, the scope of accreditation and groups of activities, the countries of establishment of the body and the verifier, the effective and expiry dates, and the normative documents used. A certificate is valid for no more than five years (Article 6(3)); the body reassesses the verifier before it expires and carries out annual surveillance.

Accreditation can change while a certificate is valid. Under Article 9, the body may suspend or withdraw accreditation, or reduce its scope, where the requirements are not met; it does so where the verifier asks; it suspends or reduces scope after a serious or persistent breach, or a breach of the body's own specific conditions; and it withdraws accreditation in specified cases, including fraud or intentionally false information. These decisions take effect when the verifier is notified (Article 9(6)).

An EU ETS accreditation or a general ISO accreditation is not the same as CBAM accreditation. Article 18(2) requires the national accreditation body to take into account an existing accreditation under Implementing Regulation (EU) 2018/2067 for a relevant group of activities. Article 4 of the Delegated Regulation lets such an applicant apply for an extension of the scope of its accreditation to the corresponding CBAM activity groups, submitted to the body designated under Article 3(1). Under Article 8, that body decides whether the verifier meets the requirements for the requested extension, and a granted extension is recorded in an accreditation certificate. Evidence of competence under the relevant international standard can support an application (Article 3(4)(g)); it does not replace a CBAM scope.

Accreditation, Registry registration and portal access are different steps

Accreditation is a decision of a national accreditation body. Registration in the CBAM Registry is carried out by a competent authority under Article 10a of Regulation (EU) 2023/956. Access to the Registry portal is a technical user-access process. Each step answers a different question, and none of them is a verification.

Article 10a(1) requires a verifier, once accredited under Article 18, to submit a request for registration in the CBAM Registry to the competent authority of the Member State in which the national accreditation body is established. The request is submitted within two months of the date on which accreditation was granted, but not before 1 September 2026, and the competent authority registers the information. Under Article 10a(2), the request contains at least the verifier's name and unique accreditation identification, any scope of accreditation relevant for CBAM, its country of establishment, the effective and expiry dates of the relevant accreditation certificates, any administrative measures, and a copy of the accreditation certificate.

The verifier notifies the competent authority of later changes (Article 10a(4)). Under Article 18 of the Delegated Regulation, the national accreditation body also sends the competent authority, without delay, its decisions to grant, renew or extend accreditation, to suspend, withdraw or reduce it, and to revoke a suspension, and the competent authority updates the Registry. The competent authority deregisters a verifier that is no longer accredited under Article 18, or that has not reported changes (Article 10a(6)).

Portal access is organised separately. Implementing Regulation (EU) 2024/3210, as amended by Implementing Regulation (EU) 2025/2550, makes the CBAM Operators Portal the single entry point to the Registry for operators, verifiers and independent persons, and requires them to request access through the Commission's EU Access service. The Commission's access procedure for accredited verifiers — version 1.00, dated 25 August 2026, published on the CBAM Registry page on 28 August 2026 and marked 'Submitted for acceptance' — describes two stages: technical-user access approved by the Commission, then an application in the portal to become a registered accredited verifier, handled by the competent authority of the country of accreditation. The procedure states that it is not legally binding and may change.

From 1 January 2027, Annex II §2.17.3 to Delegated Regulation (EU) 2025/2551 requires the verifier to issue the verification report in the CBAM Registry. Where the operator is registered, the report is transmitted through the Registry; where it is not, the verifier exports the report and transmits it by other means, with an electronic copy for information. The Commission's guidance adds that a verifier cannot issue a report without Registry access and loses that ability without an active accreditation. The declarant- and operator-side Registry modules are mapped in a separate guide.

How to check a CBAM verifier's accreditation and status

No single check answers every question. As checked on 28 September 2026, the Commission had not published a list of accredited CBAM verifiers on its verification page, so status has to be read from the sources that hold each piece of information. Record the date and source of each check, because accreditation, scope and registration can change.

A practical order is: map the goods and installation to CBAM activity groups; identify the accrediting body and check any individual accreditation information it makes available; compare the certificate's scope with the goods and its effective and expiry dates with the report-issue date; and, once available, confirm registration against the Commission's published information. To identify which national accreditation bodies provide CBAM accreditation, use the state-of-play document linked from the Commission's verification page.

These checks establish a verifier's status, not the quality of its work or the outcome of a verification. CBAM Pulse does not maintain a directory of verifiers and does not confirm any verifier's accreditation or registration.

Official status as checked on 28 September 2026

What the Commission says: on 28 September 2026, the Commission's verification page still stated that the first CBAM verifiers were expected to receive accreditation around September 2026, that the list of accredited CBAM verifiers would be published on that page, and that CBAM verifiers are obliged to register in the CBAM Registry. Its timeline, which is operational information rather than a legal deadline, shows national accreditation bodies beginning CBAM accreditation in April 2026, accredited verifiers able to register in the Registry from September 2026, and first verification reports from January 2027.

What has been published: the Commission's guidance on CBAM verification and accreditation for verifiers and national accreditation bodies (24 August 2026, not legally binding); the Registry access procedure for accredited verifiers and related technical guides (published 28 August 2026); and a state-of-play document dated 25 September 2026. The state-of-play document records whether national accreditation bodies have agreed to provide CBAM accreditation, are ready to accept applications, and have agreed to accredit, or already accept applications from, applicants established outside the EU. It concerns the accreditation bodies' readiness, not individual verifiers, and it is not a list of accredited verifiers.

What is not yet established from Commission sources: which verifiers hold CBAM accreditation, and for which activity groups. The absence of a Commission list does not mean that no verifier has been accredited, and a provider's own announcement is not a substitute for the accrediting body's record. The binding dates do not depend on the list: registration requests are submitted not before 1 September 2026 (Article 10a(1)), and verification reports are issued in the Registry from 1 January 2027 (Annex II §2.17.3 to Delegated Regulation (EU) 2025/2551). Later dated changes are recorded on the CBAM Pulse updates page.

What a verification report and opinion represent

A verification report records the verifier's assessment of an operator's emissions report for an installation and reporting period. Under Annex VI to Regulation (EU) 2023/956, the total embedded emissions are considered verified only if the verifier finds, with reasonable assurance, that the report is free of material misstatements and material non-conformities. Article 1(9) of Delegated Regulation (EU) 2025/2551 defines reasonable assurance as a high but not absolute level of assurance, expressed positively in the verification opinion. The Commission's guidance adds that limited assurance is not sufficient for CBAM, so verification is performed to a reasonable-assurance standard.

Each report carries one opinion statement under Annex II §2.17.2 to Delegated Regulation (EU) 2025/2551, so it records a satisfactory or unsatisfactory opinion. The report is verified as satisfactory only where the operator's emissions report is free from material misstatements. It is verified as unsatisfactory where material misstatements or non-conformities were not corrected before the report was issued, where non-conformities prevent the verifier from stating with reasonable assurance that the report is free from material misstatements, or where the scope of verification was too limited to obtain sufficient evidence.

The report follows an electronic template provided by the Commission via the CBAM Registry (Article 6 of Implementing Regulation (EU) 2025/2546). Its verifier fields — accreditation number, accreditation body and its country, expiry date and CBAM scope — are what the status checks above compare. Installation visits are mandatory under Annex VI unless the criteria for a waiver are met; Articles 2 to 4 of Implementing Regulation (EU) 2025/2546 set when the verifier may replace a physical site visit with a virtual one or waive it, and the verifier takes that decision.

Preparing records for the verifier and reconciling a report when it arrives are covered in the guide to verification evidence, materiality and report receipt.

What accreditation or a verification report does not establish

Accreditation, registration, portal access and a verification report each answer a narrow question. The points below separate them from broader conclusions they do not support.

None of these checks is a legal or compliance determination for a particular importer. CBAM Pulse organises source references and preparation records; it does not verify emissions, accredit or rank verifiers, or connect to the CBAM Registry.

• Accreditation for one CBAM activity group does not cover goods in another group.
• An EU ETS accreditation, a general ISO accreditation or a pending application is not CBAM accreditation until the national accreditation body grants the CBAM scope.
• Registry registration or portal access does not replace accreditation, and a portal account shows neither accreditation nor registration.
• A national accreditation body's readiness to accept applications says nothing about any particular verifier.
• The existence of a verification report does not show that its opinion is satisfactory.
• A report covers one installation and one reporting period. The verifier does not issue a second report for the same installation and period, although it may issue a revised version at the operator's request.
• A satisfactory opinion is not a decision on the declarant's CBAM declaration. The Commission and competent authorities may review CBAM declarations under Article 19 of Regulation (EU) 2023/956, and the Commission states that verification reports used by importers may be reviewed.