Guidance on verification and accreditation published: what the timeline means for importers

The Commission publishes its guide for verifiers and accreditation bodies

On 24 August 2026, the Directorate-General for Taxation and Customs Union (DG TAXUD) published the first guidance on CBAM verification and accreditation. The 141-page document is addressed to verifiers and national accreditation bodies and explains how emission reports from installations outside the EU are to be verified from the 2026 reporting year onwards. For importers, it sets out the timeline and the organisational framework in which the verified emissions data for the first CBAM declaration will be produced.

Mid-August becomes the de facto deadline

There is no statutory deadline for verification. The guidance derives the timeframe from the surrounding obligations instead. Since operators use the calendar year as their reporting period, a verification cannot be concluded before January of the following year. At the other end sits 30 September, when authorised CBAM declarants must submit their declaration. In between, declarants need time to compile the declaration, run internal quality assurance and purchase certificates. The Commission therefore recommends that verification reports reach declarants by mid-August at the latest. It also advises starting the verification during the reporting year itself rather than after year-end. Importers who want to use actual emissions data for 2026 should build this date into their supplier communication now.

For complex goods, the chain starts with the precursor

Operators producing complex goods need the verification reports of the precursor installations for their own verification. The guidance therefore recommends that operators of simple goods have their emission reports verified as early in the year as possible. Operators of complex goods should agree a timeline with their verifier and set themselves a cut-off date for receiving precursor data. If not all reports have arrived by then, the missing figures should be replaced with default values. For importers, the data quality of their goods thus also depends on installations with which they have no direct business relationship. The longer the precursor chain, the earlier verification at the start of the chain has to begin.

Accreditation takes time, the CBAM Registry decides

According to the guidance, a new accreditation typically takes six to twelve months. Verifiers already accredited for the EU ETS go through a simplified procedure. Their existing accreditation is treated as an extension of scope under Article 4 of Delegated Regulation (EU) 2025/2551. Unlike in the EU ETS, CBAM verifiers may also be established in third countries. After accreditation, verifiers must apply for registration in the CBAM Registry within two months. Only after this registration are they allowed to issue verification reports. Since the Registry is not public, the Commission intends to publish information on accredited verifiers on its website on a regular basis. Importers and operators will be able to check there whether a verifier is accredited for the relevant sector.

The monitoring plan becomes the verifier's task

In the EU ETS, the competent authority approves an installation's monitoring plan. Under the CBAM, this role does not exist. The assessment of the monitoring plan is carried out by the verifier itself, as the first step of every verification. The guidance suggests either integrating the assessment into the annual verification or commissioning it as a separate assignment. For installations with a stable configuration, the plan does not have to be reassessed every year. A cycle of two to five years is acceptable according to the guidance, explicitly as a recommendation and not as a legal requirement. Operators save recurring costs once their monitoring plan has been set up properly. For importers, it is worth asking whether their suppliers' installations already have an assessed plan.

Consultancy and verification do not mix

The guidance also spells out the independence requirements. A verifier may neither be owned by an operator nor have helped develop its monitoring plan or emission report. Personnel with a consultancy history are subject to a cooling-off period of at least two years. The CBAM lead auditor must take a three-year break after five consecutive years of verifying the same installation. The independent review and the issuance of the verification report must not be outsourced. The system is supervised by the national accreditation bodies, which carry out annual surveillance audits and, in case of breaches, can reduce the scope of an accreditation, suspend it or withdraw it entirely. Verification reports issued before such measures remain unaffected. Declarants relying on verified data are therefore working with a continuously supervised assurance system.

Outlook

The guidance is a first edition and will be updated. Still outstanding are the guidelines of the European co-operation for Accreditation (EA) for national accreditation bodies as well as the templates for information exchange announced by the Commission. For importers, the date that matters most is 30 September 2027, the deadline for the first CBAM declaration. Those who want to use actual emissions data should clarify now whether their operators have an accredited verifier under contract.

Support

If you would like to understand how the new verification guidance affects your CBAM declaration, for instance whether your suppliers can meet the mid-August timeline or when default values are the better option, please get in touch at helge@kolum.earth.