Twenty-two elements a CBAM monitoring plan must contain

By Ahmed Medhat · Published21 September 2026

A verification starts with a document request, and the first item on it is your monitoring plan. Delegated Regulation (EU) 2025/2551 puts it first in the list of what the verifier receives: "the latest version of the operator's monitoring plan, prepared in accordance with point A.5 of Annex II to Implementing Regulation (EU) 2025/2547" (Annex II, Section 2.3, point (a)). We set out the whole document request in what an accredited verifier will ask you for, and when. This guide opens the one item that guide named and stopped at.

The duty is short. "For the purpose of paragraphs 1 to 4, operators shall design and implement a monitoring plan containing at least the elements outlined in point A.5 of Annex II" (Implementing Regulation (EU) 2025/2547 Art. 5(5)). Paragraphs 1 to 4 of that article are the monitoring rules for direct emissions, heat flows, precursors in complex goods, and indirect emissions. The plan is what holds those four methodologies in one place. "The monitoring plan shall be submitted in English" (Art. 5(6)).

Point A.5 of Annex II is headed "Monitoring plan Template containing the minimum elements to be contained in the monitoring plan". It runs to twenty-two numbered elements, carrying fourteen lettered sub-points between them: two under element 7, four under element 17, and eight under element 22. Neither states the number: the article says "at least" and the heading says "minimum elements", so twenty-two is a floor, not a ceiling, and other points of Annex II add further things that have to be laid down in the plan. "At least" and "minimum elements" mean twenty-two is a floor, not a ceiling, and other points of Annex II add further things that have to be laid down in the plan. We come to those below.

The elements below are given in the act's own wording, because they are the labels the verifier will work through. What each one means in practice is ours.

What the act does not say

Three questions come up on every first plan, and on all three the act is silent.

It names no recipient. Article 5(6) says the plan shall be submitted in English. It does not say to whom. Recital 9 of the act explains the language rule by reference to "an efficient verification process and review process of CBAM declarations by the Commission and competent authorities", but a recital is not an operative provision, and we found no article in the calculation act requiring the operator to lodge the monitoring plan with a competent authority, with the Commission, or in the CBAM registry. What the acts do establish is that it reaches the verifier, under Section 2.3(a) of Annex II to the delegated act.

It sets no approval step. There is no provision in these acts by which an authority approves, refuses or endorses a monitoring plan before it is used. The plan is assessed inside the verification: the verifier checks whether the plan presented to it is the most recent version (Delegated Regulation (EU) 2025/2551 Annex II, Section 2.4.1, point (a)), whether "the operator has acted in conformity with the installation's monitoring plan" (Section 2.1.2, point (b)), and "whether the monitoring plan is properly implemented" (Section 2.7). If the verifier discovers that a plan "is not in compliance with Implementing Regulation (EU) 2025/2547", it takes action under Section 2.14, which means informing the operator without delay and requesting the correction. A plan that "does not provide sufficient scope or clarity to reach a conclusion on the verification" is one of the three grounds on which a verifier may conclude that the scope of verification was too limited (Section 2.18, point (b)) — an unsatisfactory opinion.

It sets no date. We looked for a deadline by which the monitoring plan must be written, submitted or updated, and found none in the calculation act. The plan has to exist before the data does, because element 1 is its date and version number and the whole point of it is that the methods are fixed in advance and used consistently. The date that actually binds the chain sits further downstream and belongs to someone else: the authorised CBAM declarant — an EU-established importer, an indirect customs representative, or, where the importer is not established in a Member State, that representative acting for it (Regulation (EU) 2023/956 Art. 5(1), 5(1a) and 5(2)) — submits the CBAM declaration by 30 September of each year, for the first time in 2027 for the year 2026 (Art. 6(1)). Your verification has to be finished before that. The working date is therefore the one in the verification contract, counted back from it.

Elements 1 to 6: what the installation is and what it makes

These six describe the plant and its output. They are the part a verifier reads first to size the engagement.

1. The date and version number of the monitoring plan. The only element that is about the document rather than the installation, and the one most often missing. The delegated act asks for "the latest version" (Section 2.3(a)) and, if applicable, "a record of all changes made to the installation and to the monitoring plan since the last verification" (Section 2.3(c)). Neither request can be answered by a document with no version history.
2. A description of the installation and production processes carried out by the installation.
3. A list of all relevant goods produced by CN code and functional unit, and where applicable the specific compositions in terms of clinker content and nitrogen content, including precursors not covered by separate production processes in accordance with Article 4. The functional unit is not a free choice: tonnes under the same CN code by default, kWh for electricity, kilograms of nitrogen or the supplementary units for fertilisers, and tonnes of clinker for the four CN codes Art. 4(5) names (Art. 4(2) to 4(5)).
4. A list of all CBAM production processes and routes carried out at the installation and list of goods delivered per production processes.
5. If relevant, a list of non-CBAM goods produced per production process and the quantity produced. The goods outside CBAM still have to be declared here, because they share the plant with the goods inside it and the attribution has to add up.
6. A list of the relevant CBAM benchmarks to be used for the determination of the free allocation adjustment for all relevant goods produced. The plan names which benchmarks apply to your goods; it does not compute the adjustment. The benchmarks and the adjustment sit in a separate act, Implementing Regulation (EU) 2025/2620, and we deal with that topic on its own — including the July 2026 correction to the default-value annexes that had made the adjustment impossible to calculate for some production routes.

Elements 7 to 12: how each number is produced

This is the methodological core, and the part a verifier tests against what it finds on site.

1. The methods for monitoring data per each production process, including: (a) "a detailed description of the calculation-based methodology when applied, including a list of input data and calculation formulae"; and (b) "a description of the measurement systems used, and exact location of the measuring instruments to be used for each of the source streams to be monitored". Exact location means exact. A verifier on a physical site visit assesses the operation of the measuring devices against this description.
2. The methods for determining calculation factors and sampling plan for each source stream, if applicable.
3. A list of source streams and emission sources and their description for each production process.
4. A list of source streams for which the calculation-based standard method or the mass balance method is used, including the detailed description of the determination of each relevant parameter provided in point B.3.4.
5. A list of emission sources for which a measurement-based methodology is used, including the description of all relevant elements provided in point B.6.
6. A description of the monitoring methodology as far as perfluorocarbons from primary aluminium production are monitored.

Elements 10 and 11 divide the installation between the two methodologies the act allows: the calculation-based methodology, in its standard or mass balance form, and the measurement-based methodology using continuous measurement of concentration and flue gas flow (Annex II point B.2). The act tells you to choose "the monitoring methodology that gives the most accurate and reliable results", except where a sector-specific requirement under point B.9 forces one, and it allows a combination across different parts of the installation. Elements 10 and 11 are where that combination is written down.

Element 13: the diagram, and what it has to prove

Element 13 is a single sentence that carries more work than any other in the list: "a suitable diagram and process description of the installation including the system boundaries of the installations and different production processes, providing evidence that there is neither double counting nor data gaps in the emissions of the installation".

Three things follow from it. The diagram is mandatory, not a courtesy. It has to show boundaries — both the installation's and each production process's. And it is evidential: the test is not that it looks like the plant, it is that it demonstrates completeness and no overlap. The same completeness rule is stated as a principle elsewhere in the annex: "The boundaries of the installation and its production processes shall be clearly known to the operator and defined in the monitoring plan", covering as a minimum all relevant emission sources and source streams associated directly or indirectly with production of the listed goods, including emissions from start-up, shut-down and emergency situations, and excluding mobile machinery for transportation purposes (Annex II point B.1).

If a flow leaves one production process and enters another, the diagram is where a verifier sees whether it was counted once or twice.

Elements 14 to 21: the eight case-by-case declarations

Each of these turns on a fact about your installation. Where the fact is absent the element is short, but the plan should say so rather than leave the reader guessing.

1. The precursors used in each production process and, if produced in other installation, name and country of origin of their suppliers. Where a precursor comes from outside, the plan is the first place its origin appears; what happens to its emissions figure afterwards is a separate problem, which we set out in why your supplier's precursor number is usually not usable.
2. Whether any zero-rated fuels are used and how the operator demonstrates the applicability of zero-rating of the fuels. Note the second half: the claim and the demonstration both belong in the plan.
3. Whether measurable heat is imported from or exported to other installations, and an identification of those installations, plus a detailed description of the methods to determine the emissions attributed to the heat flows for each production process.
4. For indirect emissions, whether electricity is produced inside the installation; if so, whether it is (a) produced by co-generation; (b) produced by separate generation; (c) produced from fossil or renewable sources; (d) exported from the system boundaries of a production process.
5. Where the indirect emissions are determined on the basis of actual emissions, the information needed to provide the relevant parts of the elements of evidence laid down in point D.4.3.
6. Where the embedded emissions of electricity imported into the customs territory of the Union are determined on the basis of actual emissions, the information needed to provide the elements of evidence laid down in point D.2.4, "including, where this information is not directly available to the operator, how the operator plans to receive it". That last clause is unusual and worth reading twice: the plan has to describe the plan for getting data you do not yet hold. The conditions behind point D.2.4 are the ones we go through in the five conditions for using actual emissions on imported electricity.
7. Whether waste gases are produced and used in the installation, or imported from or exported to other installations, and an identification of those installations.
8. Whether CO2 capture, storage and/or use in accordance with point B.8.2 apply, the identity and contact data of a responsible person of the receiving installations or transport infrastructure or entities to which it is transferred, and the monitoring methodology in accordance with point B.8.3. A named person with contact details, in the plan.

Element 22: the control system, in eight parts

The last element is a system rather than a fact: "a control system to ensure the data quality which shall include, where applicable":

• (a) quality assurance of the relevant measurement equipment, ensuring all relevant measuring equipment is calibrated, adjusted and checked at regular intervals including prior to use, and checked against measurement standards traceable to international measurement standards where available, proportionate to the relevance of the equipment;
• (b) risk assessment where sources of risks of errors in the data flow from primary data to final data are identified;
• (c) quality assurance of information technology systems, ensuring the relevant systems are designed, documented, tested, implemented, controlled and maintained so as to process reliable, accurate and timely data in accordance with the risks identified in the risk assessment;
• (d) segregation of duties in the data flow activities and control activities, as well as management of necessary competencies;
• (e) internal reviews and validation of data;
• (f) corrections and corrective action;
• (g) control of outsourced processes;
• (h) keeping records and documentation including the management of document versions.

Point (b) is the one the verification leans on hardest, because the verifier runs its own risk analysis and checks "whether the procedures listed in the monitoring plan are effective to mitigate the inherent risks and control risks and whether the procedures are implemented, sufficiently documented and properly updated" (Delegated Regulation (EU) 2025/2551 Annex II, Section 2.7). Procedures that exist on paper and not in the plant are found here. Point (h) closes the loop back to element 1: document version management is itself a control.

What else the act tells you to lay down in the plan

Point A.5 is the template. It is not the whole of the plan's job. Other points of Annex II each add a sentence of the form "shall be laid down in the monitoring plan", and a verifier reading for compliance with the calculation act will look for them:

• The selected methods, so they are used consistently. "Monitoring and reporting shall be consistent and comparable over time. To that end, the selected methods shall be laid down in a monitoring plan so that the methods are used consistently. The methodology shall be changed only if objectively justified" (Annex II point A.2(2)).
• The data sources chosen, defined in the plan for use in determining and reporting embedded emissions (point A.3(4)), and any additional data sources identified for corroboration (point A.3(5)).
• New, better data sources. It shall be checked regularly, and at least once per year, whether new data sources have become available; where they are more accurate they "shall be laid down in the monitoring plan and be applied from the earliest date possible" (point A.3(6)).
• A justification where a methodology is technically not feasible (point A.3(7)), and a justification where it incurs unreasonable costs (point A.3(8)). The act prices that second argument: the benefit is calculated by multiplying an improvement factor by a reference price of EUR 80 per tonne of CO2e, and measures to improve an installation's monitoring methodology are not deemed to incur unreasonable costs up to an accumulated EUR 4 000 per year (point A.3(8)(a) and point A.3(8)(c)).
• Standard values, laid down in the plan and changed only where there is evidence that the new value is more adequate and representative; where a standard value changes annually, the plan names the authoritative applicable source of that value instead of the value itself (Annex II point B.5.2).
• Continuous improvement. "Operators shall regularly check if the monitoring plan and its monitoring methodologies can be improved", and shall consider for implementation, within a reasonable timeframe, any recommendations for improvement in the verification report (point A.2(9)).

Alongside the plan, complete and transparent records of all data relevant for determining embedded emissions, with supporting documents, are kept at the installation for at least six years after the reporting period, and that documentation "shall include a record of all changes in the functioning of the installation, of the monitoring methodology and control system applied as documented in the monitoring plan" (Annex II points A.2(4) and A.2, transparency principle).

The summary of the plan that goes into the report

The plan itself does not travel into the operator's emissions report; a defined summary of it does. Point 1.1, item 2 of Annex IV requires a "Summary of the installation's monitoring plan, containing at least the following information", in eight sub-points (a) to (h):

• (a) list of all CBAM production processes and routes carried out at the installation;
• (b) list of non-CBAM production processes carried out at the installation;
• (c) list of the five most important (by mass) goods produced per production process, identified by CN code;
• (d) list of the five most important (by energy content provided) fuels used at the installation;
• (e) list of the five most important (by emissions) materials used at the installation leading to process emissions;
• (f) if continuous emissions measurement is used at the installation, the relevant greenhouse gases and the five biggest emissions sources to which it is applied;
• (g) whether any zero-rated fuels are used and how the operator demonstrates the applicability of zero-rating of the fuels;
• (h) whether measurable heat is imported from or exported to other installations, and an identification of those installations.

Three of those are "five most important" lists, ranked on three different measures — mass for goods, energy content for fuels, emissions for process materials — and a fourth asks for the five biggest emission sources under continuous measurement. Getting those rankings out of a plan that was never built to be sorted is a known time sink, which is a practical reason to hold the underlying lists as data rather than as prose. Sub-point (g) repeats element 15 word for word, and (h) repeats the first half of element 16 without its description-of-methods clause, so write those once and reuse them.

Who reads the plan, and what they do with it

The verifier receives the latest version before the strategic analysis (Delegated Regulation (EU) 2025/2551 Annex II, Section 2.3(a)), checks at that stage that it is the most recent version and whether the installation or the plan changed during the reporting period (Section 2.4.1), reviews "the monitoring plan as well as the specifics of the monitoring methodology laid down therein" (Section 2.4.3, point (b)), carries the findings of that strategic analysis into its risk analysis (Section 2.5), and then tests whether the plan was actually implemented (Section 2.7).

Two constraints follow for the operator. The firm that wrote your plan cannot verify it: an unacceptable risk to impartiality arises where the verifier or any part of the same legal entity provides consulting services to develop part of the monitoring and reporting process, "including development of the monitoring methodology, drafting of the emissions report, or drafting of the monitoring plan" (Annex II, Section 1.7.2, point (a)). And where the verifier finds something, the correction is expected in the plan as well as in the report: recital 18 of the calculation act says operators should correct, in the monitoring plan and the operator's emissions report, any misstatements, non-conformities or non-compliance notified by the verifier, and provide the verifier with the final version of the document afterwards. That is a recital, so it states the intention rather than imposing the duty directly; the operative request comes from the verifier's side under Section 2.14.1.

The short version

The monitoring plan is a required document under Article 5(5) of Implementing Regulation (EU) 2025/2547, written in English, containing at least the twenty-two elements of point A.5 of Annex II and the fourteen lettered sub-points inside them. Six describe the installation and its goods, six describe how each number is produced, one is a diagram that has to evidence neither double counting nor data gaps, eight are case-by-case declarations, and the last is a control system in eight parts. Other points of Annex II add further items that must be laid down in the plan — the chosen methods and data sources, justifications for technical infeasibility or unreasonable costs, standard values, and annual improvement checks. A defined eight-point summary of the plan goes into the operator's emissions report, including three "five most important" rankings. The act sets no authority to file the plan with, no approval step and no deadline; the plan reaches the verifier, which checks that it is current, compliant and actually implemented, and a plan too unclear to conclude on is a ground for an unsatisfactory opinion. Version it, date it, and keep the change record — the second verification asks for both.

Regulatory sources: Implementing Regulation (EU) 2025/2547 Art. 4(2) to 4(5), Art. 5(1) to 5(6), recitals (9) and (18), Annex II points A.2(2), A.2(3), A.2(4), A.2(9), A.3(4) to A.3(8), A.5 (elements 1 to 22), B.1, B.2, B.5.2 and B.9, and Annex IV point 1.1 item 2; Delegated Regulation (EU) 2025/2551 Annex II Sections 1.7.2, 2.1.2, 2.3, 2.4.1, 2.4.3, 2.5, 2.7, 2.14, 2.17.2 and 2.18; Regulation (EU) 2023/956 Art. 5(1), 5(1a), 5(2) and Art. 6(1); Implementing Regulation (EU) 2025/2620 (free allocation adjustment), referred to but not set out here.