What an accredited verifier will ask you for, and when

By Ahmed Medhat · Published19 September 2026

Three acts govern the verification of embedded emissions: Regulation (EU) 2023/956 (Article 8, Article 10, Article 18 and Annex VI), Implementing Regulation (EU) 2025/2546 on the verification principles, and Delegated Regulation (EU) 2025/2551 on the accreditation of verifiers, whose Annex II sets out how a verification is carried out. Implementing Regulation (EU) 2025/2547, the calculation act, says what the operator prepares. This guide follows a verification from the operator's side, in the order it happens.

Who the duty sits on, and in which case

The duty in Article 8(1) of Regulation (EU) 2023/956 is addressed to the authorised CBAM declarant, and it has a condition: "Where the embedded emissions are determined on the basis of actual emissions, the authorised CBAM declarant shall ensure that the total embedded emissions declared in the CBAM declaration" are verified by a verifier accredited pursuant to Article 18, based on the verification principles set out in Annex VI. We found no provision in these acts that requires verification of emissions declared on default values.

The operator of an installation in a third country carries a duty of its own in one case. An operator that has registered its installation in the CBAM registry under Article 10 shall ensure that the embedded emissions it determined are verified in accordance with Annex VI by a verifier accredited pursuant to Article 18 (Article 10(5), point (b)). That operator may then disclose the information on the verification to an authorised CBAM declarant (Article 10(7)), and the declarant may choose to use that verified information to fulfil its own obligation (Article 8(2)).

On the calculation side, where the embedded emissions are calculated based on actual emissions, operators prepare the operator's emissions report "and a summary thereof" (Implementing Regulation (EU) 2025/2547 Art. 10(1)). That report is the document the verifier verifies.

Who may verify

A verifier is a legal person accredited by a national accreditation body (Regulation (EU) 2023/956 Art. 18(2)). Accreditation is granted for CBAM activity groups listed in Annex I to Delegated Regulation (EU) 2025/2551, and the verifier "shall only issue a verification report in respect of an operator's emissions report for the group of activities referred to in Annex I for which the verifier is accredited" (Annex II, Section 2.17.1). Before accepting an engagement the verifier assesses whether it falls within the scope of its accreditation (Section 2.2, point (b)). The accreditation certificate is valid for a period not exceeding five years (Art. 6(3)).

Two rules on independence matter when choosing one. 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 a CBAM lead auditor who undertakes five annual verifications for a given installation, where no other CBAM lead auditor has verified it during that time, takes a three consecutive year break from that installation (Section 1.7.6).

What the verifier receives from the operator

Section 2.3 of Annex II to the delegated act gives the list, and its timing: "Before the strategic analysis and at other points of time during the verification, the verifier shall receive from the operator all of the following". The list runs from point (a) to point (n). The items that apply to every installation are:

• 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 (point (a));
• relevant documentation or a description of the installation, procedures and processes or flowcharts kept up to date outside the monitoring plan (point (b));
• the operator's emissions report to be verified (point (e));
• information on databases and data sources used for monitoring and reporting purposes (point (m));
• any other relevant information necessary to plan and carry out the verification (point (n)).

The others apply where the case arises: a record of all changes made to the installation and to the monitoring plan since the last verification (point (c)); the sampling plan (point (d)); the operator's emissions report and the related verification report for the previous reporting period, if not verified by the same verifier (point (f)); information on how the operator has corrected non-conformities or addressed recommendations for improvement from the previous verification report (point (g)); the verification reports relating to precursors used but not produced at the installation (point (h)); and the evidence that supports particular choices in the calculation, on the time of production of a precursor, on precursors from several installations, and on electricity (points (i) to (l)).

Point (h) has a consequence that is often missed. Actual data for a precursor produced outside the installation, originating in a third country or territory that is not exempted pursuant to point 1 of Annex III to Regulation (EU) 2023/956, may be used only where it comes from a verification report that meets the conditions of Annex II point A.1(4) to the calculation act; where the operator does not have such a report, the relevant default values for the precursor are used (point A.1(5)). We set that out in why your supplier's precursor number is usually not usable.

The operator's emissions report, "its summary" and, if applicable, the declarant-specific addendum reach the verifier via the CBAM registry where the operator is registered there, and by other means where it is not (Implementing Regulation (EU) 2025/2547 Art. 10(2) and (3)). The report is submitted in English (Art. 10(4)).

The site visit

Annex VI to Regulation (EU) 2023/956 makes installation visits mandatory "except where specific criteria for waiving the installation visit are met" (point 1(c)). The delegated act describes a physical site visit at the installation where the goods are produced, to assess the operation of measuring devices and monitoring systems and to conduct interviews, and the verifier ensures that the operator provides access to its sites (Annex II, Section 2.13).

Implementing Regulation (EU) 2025/2546 sets the exceptions. The verifier may replace the physical site visit with a virtual one, or waive it, where all of the conditions in Article 3(1) are fulfilled. The first is that "a verifier has carried out a physical site visit during the reporting period immediately preceding the current reporting period" (point (a)); for a waiver, a physical site visit must have been carried out "during two reporting periods preceding the current reporting period" (point (b)). The rest concern the verifier's understanding of the installation, the complexity and risk of its monitoring system, the ability to obtain and assess all information remotely, the risk analysis, and the absence of significant changes to the installation or its monitoring plan since the last physical site visit (points (c) to (g)). Article 3(2) sets a separate waiver for an installation where electricity is the only good covered by Annex I to Regulation (EU) 2023/956 that it produces; among its conditions, a verifier has carried out at least one physical site visit in the last five reporting periods immediately preceding the current one (point (c)).

An installation in its first verified reporting period has no preceding physical site visit, so it cannot meet point (a) of Article 3(1), nor point (c) of Article 3(2). Recital 3 of the act says the same in plain words: in the first year subject to verification a physical site visit should be required in all cases, and physical site visits should occur every two years at least. One separate route exists: a virtual site visit where the verifier is prevented from visiting by "serious, extraordinary and unforeseeable circumstances outside the control of the operator" that cannot be overcome after using all reasonable efforts (Art. 4, point (a)).

The decision is the verifier's, and the verifier informs the operator of it without delay (Art. 2(3)).

The number: 5 % per tonne of good

When assessing misstatements, the verifier applies, for each tonne of the relevant good identified by its CN code, two materiality levels: 5 % of the total specific embedded emissions, and 5 % of the total specific embedded free allocation (Implementing Regulation (EU) 2025/2546 Art. 5(1)). Two details sit next to that figure. A misstatement is "an omission, misrepresentation or error in the operator's reported data, not considering the uncertainty associated with measuring instruments or laboratory analyses" (Art. 1(1)). And 5 % is not a safe harbour: the verifier also uses expert judgement as to whether misstatements below the materiality level, individually or when aggregated with others, are to be considered material (Art. 5(2)).

When the verifier finds something

Where the verifier identifies misstatements, non-conformities or non-compliance, it informs the operator without delay and requests the operator to correct them (Delegated Regulation (EU) 2025/2551 Annex II, Section 2.14.1). Where the operator does not correct the misstatements or non-conformities, the verifier, before issuing the verification report, requests the operator to explain the main causes and the reasons for not making the requested corrections (Section 2.14.2).

What comes out: four statements, three of them unsatisfactory

The verification report carries one of four opinion statements (Annex II, Section 2.17.2):

• "the report is verified as satisfactory";
• "the report is verified as unsatisfactory", where the operator's emissions report contains material misstatements or non-conformities that were not corrected before the verification report was issued;
• "the report is verified as unsatisfactory", where non-conformities provide insufficient clarity and prevent the verifier from stating with reasonable assurance that the report is free from material misstatements;
• "the report is verified as unsatisfactory", where the scope of verification is too limited and the verifier could not obtain sufficient evidence.

The operator's emissions report may be verified as satisfactory only where it is free from material misstatements. The situations that limit the scope include missing data, a monitoring plan that does not provide sufficient scope or clarity, and the case where "the operator has failed to make sufficient information available to enable the verifier to carry out the verification" (Section 2.18).

The verification report is prepared on an electronic template provided by the Commission via the CBAM registry (Implementing Regulation (EU) 2025/2546 Art. 6), and it is completed in English. From 1 January 2027 the verifier issues it in the CBAM registry. It is transmitted to a registered operator via the registry; to an operator that is not registered, the verifier exports and transmits it by other means. There is one verification report per installation and reporting period: the verifier does not issue one where a report already covers the same reporting period for the same installation, though it may issue a revised version at the operator's request (Delegated Regulation (EU) 2025/2551 Annex II, Section 2.17.3).

The dates the acts set, and the ones they do not

The reporting period follows the goods. Where a good was imported during the year 2026, the reporting period is the year 2026; for another year it is by default the calendar year of import, unless there is sufficient evidence to identify the actual time of production (Implementing Regulation (EU) 2025/2547 Art. 7(1)). The date the verification feeds is the declarant's: the CBAM declaration is submitted by 30 September of each year, for the first time in 2027 for the year 2026 (Regulation (EU) 2023/956 Art. 6(1)).

We looked in these acts for a date by which the operator must hand the operator's emissions report to the verifier, and for a deadline by which the verifier must issue the verification report, and found neither. The working timetable is therefore set in the verification contract, counted back from the date on which the declarant needs the verified figures.

Two record-keeping periods run side by side. A registered operator keeps a copy of the verification report and the records of the information required to calculate the embedded emissions for four years after the verification has been performed (Regulation (EU) 2023/956 Art. 10(5), point (c)). Separately, complete and transparent records of all data relevant for determining embedded emissions are kept at the installation for at least six years after the reporting period (Implementing Regulation (EU) 2025/2547 Annex II point A.2(4)).

The short version

Verification applies where embedded emissions are determined on actual emissions; the duty is the authorised CBAM declarant's, and a registered operator carries its own. The verifier must be accredited for the activity group of your goods and cannot be the firm that drafted your monitoring plan or your report. It receives the monitoring plan, the installation description, the operator's emissions report, the data sources and, where they apply, the change record, last year's reports and the verification reports of bought-in precursors. The first verified period cannot meet the Article 3 conditions for a virtual site visit or a waiver. The materiality level is 5 % per tonne of good, and below 5 % can still be material. Of the four statements a verification report can carry, one is "verified as satisfactory".

Regulatory sources: Regulation (EU) 2023/956 Art. 6(1), Art. 8(1) and (2), Art. 10(5) and (7), Art. 18(2) and Annex VI point 1(c); Implementing Regulation (EU) 2025/2546 Art. 1(1), Art. 2(3), Art. 3(1) and (2), Art. 4, Art. 5(1) and (2), Art. 6 and recital 3; Delegated Regulation (EU) 2025/2551 Art. 6(3) and Annex II Sections 1.7.2, 1.7.6, 2.2, 2.3, 2.13, 2.14, 2.17 and 2.18; Implementing Regulation (EU) 2025/2547 Art. 7(1), Art. 10(1) to (4) and Annex II points A.1(4), A.1(5) and A.2(4).