CBAM reporting evidence checklist

A practical checklist for structuring the evidence behind a CBAM reporting set and making the gaps visible: confirming goods scope, identifying suppliers, tracking which emissions data is in, referencing the evidence behind each figure, documenting assumptions, reviewing precursor consistency, and capturing the questions to raise with your adviser or National Competent Authority. Each item links to an official source or to a source-backed CBAM Pulse page. It is a structuring aid, not a determination that your data is complete or ready to file. Nothing is stored, and no account is required.

Last updated: 2026-07-04Sources: Regulation (EU) 2023/956 (consolidated text)EC DG TAXUD — Carbon Border Adjustment Mechanism

0 of 24 evidence areas reviewed. Ticks are a working aid only — they are not saved and do not mean your data is complete, verified, or ready to file.

1. Goods and CN scope confirmed

Start from what is actually in scope: which of your imported goods are CBAM goods, by CN code.

Identify the CN codes of the goods you import and record which of them are CBAM goods.
See: CN goods checker (shows the source)
Note any precursors and downstream goods that are also in scope, so the reporting set covers the whole chain, not just finished products.
See: Guide: CBAM precursors and data consistency (shows the source)
Record the Annex I basis for each in-scope good, so the scope decision is traceable later.
Source: Regulation (EU) 2023/956 (consolidated text)

2. Suppliers identified for each in-scope good

For every in-scope good, know who produced it — the supplier and, where relevant, the installation.

Identify the supplier(s) and, where relevant, the production installation behind each in-scope good.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Record which party provides the emissions data for each good — typically the non-EU producer or exporter — and who reports on the EU side.
See: Guide: CBAM exporter–importer data flow (shows the source)
List any in-scope goods that do not yet have an identified supplier, so the gap is visible.
See: Guide: CBAM supplier data and evidence (shows the source)

3. Embedded-emissions data received, requested, or outstanding

Track the status of the embedded-emissions data behind each good — received, requested, or still outstanding.

For each good, record whether embedded-emissions data has been received, has been requested, or is still outstanding.
See: Guide: CBAM supplier data and evidence (shows the source)
Note, at a high level, where actual emissions data is available and where a default value is being relied on instead.
Source: Regulation (EU) 2023/956 (consolidated text)
List the suppliers still to respond, so follow-ups can be prioritised.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism

4. Supporting evidence referenced for each figure

Every emissions figure is only as strong as the evidence behind it — keep a reference to that evidence, not a verdict on it.

For each emissions figure, record a reference to the supporting document or calculation it came from.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Note the type and location of each evidence item, so it can be found again — this is a reference, not a judgement on sufficiency.
See: Guide: CBAM supplier data and evidence (shows the source)
Keep dated versions of figures and evidence rather than overwriting, so you can reconstruct what applied when.
Source: Regulation (EU) 2023/956 (consolidated text)

5. Assumptions documented

Where actual data is thin, an assumption is normal — leaving it undocumented is the risk.

Document each assumption made where actual data was unavailable, and the reason for it.
See: Guide: CBAM supplier data and evidence (shows the source)
Note what better data would replace each assumption, and when it might arrive.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Record who reviewed each assumption internally, so the reasoning is legible to an adviser or reviewer later.
See: Guide: CBAM reporting in practice (shows the source)

6. Boundaries and precursors reviewed for consistency

The same precursor, boundary, or assumption should line up wherever it appears in the set.

Review that system boundaries are drawn the same way across the reporting set.
See: Guide: CBAM precursors and data consistency (shows the source)
Check that shared precursor figures are used consistently wherever they appear, rather than re-keyed differently.
See: Guide: CBAM precursors and data consistency (shows the source)
Note upstream data changes that should propagate to the downstream goods that depend on them.
Source: Regulation (EU) 2023/956 (consolidated text)

7. Unresolved gaps listed

The point of the checklist is to make gaps visible — not to declare them closed.

List the goods, suppliers, figures, or evidence still missing from the set.
See: Guide: CBAM reporting in practice (shows the source)
Note the impact of each gap and what would close it.
See: Guide: CBAM reporting in practice (shows the source)
Record an owner and a target date for each open gap.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism

8. Questions for adviser / NCA captured

Capture what needs checking with a qualified adviser or your National Competent Authority before you rely on it.

Capture the open questions to raise with a qualified adviser about your evidence and assumptions.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Identify your National Competent Authority and note its published guidance and contact points.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Note which points need checking against the official source before you rely on them in a decision.
Source: Regulation (EU) 2023/956 (consolidated text)

This checklist helps structure reporting evidence and open questions. It is informational only and is not a determination that your data is complete, verified, audit-ready, legally sufficient, or ready for CBAM filing. You remain responsible for checking your evidence, assumptions, and obligations with qualified advisers and your National Competent Authority.

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Guide: CBAM reporting in practice
Guide: CBAM supplier data and evidence
Guide: CBAM exporter–importer data flow
Guide: CBAM precursors and data consistency
CN goods checker
CBAM readiness checklist
CBAM updates feed