The plain-English explainer

CBAM verification: when you need a verifier

CBAM verification is the independent check of the emissions data behind your annual declaration, carried out by an accredited verifier. Crucially, it applies only where you use actual embedded-emissions values. If you rely solely on default values, you are not subject to verification. DG TAXUD

Last updated · 8 June 2026

TL;DR

  • When: verification applies only when you use actual emissions values — not when you rely solely on default values.
  • Who: independent verifiers accredited under EU rules, like EU ETS verifiers.
  • What is checked: installation data, monitoring methodology, system boundaries and any foreign-carbon-price claim.
  • The trade-off: actual values are usually cheaper than marked-up defaults, but they require verification.
  • Still moving: first-year (2026) site-visit rules were being finalised in late 2025 — confirm before you plan.
Actual vs default valuesThe compliance checklist

The rule that catches people out

No verification if you use only default values.

Verification is not a blanket requirement for every importer. It is triggered only when you choose to use actual embedded-emissions values. That makes verification a decision you control, traded off against the usually higher cost of conservative, marked-up default values. DG TAXUD: 2025 simplifications

Who does the verifying

CBAM emissions data is verified by independent accredited verifiers. They are accredited by national accreditation bodies under EU rules, in much the same way EU ETS verifiers are accredited — so the system deliberately builds on a framework that already exists and that many sectors know. The verifier must be independent of the installation whose data it checks. DG TAXUD: CBAM hub

You choose your verifier; one is not assigned to you. That gives you control, but also responsibility to pick an accredited, capable firm and to engage them early enough.

What gets verified

The verifier examines the actual embedded-emissions data that underpins your annual CBAM declaration. In practice that means four things.

Installation data

The production and emissions data from the installation where the goods were made, as supplied by your non-EU producer.

Monitoring methodology

How emissions were measured and calculated — whether the methodology used is sound and applied consistently.

System boundaries

Which processes and precursors are counted, so that nothing in scope is left out and nothing out of scope is wrongly included.

Foreign carbon-price claims

Any claim that a carbon price was already paid in the country of origin, which can be deducted from your CBAM obligation.

The trade-off: actual values vs default values

You can base your declaration on actual values (verified, installation-specific data) or on default values (Commission-published fallback figures). Actual values are usually cheaper, because default values are deliberately conservative and carry a mark-up. But actual values require verification, and default values do not. So the real question for most importers is whether the saving from lower actual figures outweighs the cost and effort of verification. DG TAXUD

See the default-values reference for the figures and mark-ups, and the certificates page for how this feeds into cost.

How to choose a verifier

  • Accreditation. Confirm the verifier is accredited under the relevant EU framework for CBAM, not only for adjacent schemes.
  • Relevant experience. EU ETS verification experience and familiarity with your sector (steel, aluminium, cement, fertilisers, electricity or hydrogen) make the process smoother.
  • Timing. Engage early. The verifier needs time to review installation data and, potentially, to arrange a site visit before your declaration is due.
  • Clarity up front. Agree scope, cost and timeline before you start, and check how they will coordinate with your non-EU suppliers' data.

First-year site-visit rules were still being finalised

For the first definitive reporting year (2026), the rules for whether each installation reporting actual values needs a physical site visit from an accredited verifier were being finalised in late 2025. Treat the site-visit position as not fully settled: confirm the final rules with your verifier and the latest DG TAXUD guidance before you commit to a plan. We will update this page when the implementing rules are confirmed. DG TAXUD: CBAM hub

Where verification fits in the bigger picture

Verification is one step in the full compliance sequence: confirm scope, get authorised, gather supplier data, calculate emissions, verify (if using actual values), then budget and surrender certificates. See the CBAM compliance checklist.

FAQ

People also ask

When do I need a CBAM verifier?
You need an independent accredited verifier only where you use actual embedded-emissions values in your CBAM declaration. If you rely solely on default values published by the Commission, you are not subject to verification. So verification is the trade-off you accept in exchange for the usually lower emissions figures that actual data provides.
Who can verify CBAM emissions data?
CBAM data is verified by independent verifiers accredited by national accreditation bodies under EU rules, in the same way EU ETS verifiers are accredited. They must be independent of the installation whose data they verify. You choose an accredited verifier yourself; it is not assigned to you.
What does a CBAM verifier check?
The verifier checks the actual embedded-emissions data behind your annual declaration: the installation data, the monitoring methodology, the system boundaries used, and any claim that a carbon price was already paid abroad. The aim is reasonable assurance that the emissions figures are accurate and complete.
Do I need verification if I use default values?
No. Importers relying solely on default values are not subject to verification. Default values are deliberately conservative and carry mark-ups, so they are usually more expensive than verified actual values, but they spare you the verification step. Many importers will weigh the cost of verification against the saving from lower actual figures.
Are site visits required for CBAM verification?
For the first definitive year (2026), the rules for whether each installation reporting actual values needs a physical site visit were being finalised in late 2025. Treat the site-visit position as not fully settled and confirm the final rules with your verifier and the latest DG TAXUD guidance before you plan. We will update this page when the implementing rules are confirmed.
How do I choose a CBAM verifier?
Choose an independent verifier accredited under the relevant EU accreditation framework, ideally with EU ETS verification experience and familiarity with your sector. Engage early, because the verifier needs time to review installation data and, potentially, to arrange any site visit before your annual declaration is due. Confirm scope, cost and timing up front.

This is guidance, not legal advice

This is an independent guide to help you understand CBAM verification, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. We cannot guarantee compliance, and you should be wary of anyone who says they can.

Sources

  1. [1]European Commission (DG TAXUD): CBAM hubretrieved 8 Jun 2026
  2. [2]DG TAXUD: Officially published — simplifications for CBAM (20 Oct 2025)retrieved 8 Jun 2026
  3. [3]European Commission (DG TAXUD): CBAM Registry and reportingretrieved 8 Jun 2026
  4. [4]EUR-Lex: CBAM summary, Regulation (EU) 2023/956retrieved 8 Jun 2026
  5. [5]German DEHSt: CBAM definitive regimeretrieved 8 Jun 2026

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