Verifiers in the CBAM registry: access is open, accreditation remains the bottleneck

The Commission opens the registry to verifiers

On 28 August, the Commission published the procedure through which accredited verifiers have been able to access the CBAM Registry since 1 September. The document also sets out the roles of verifiers, accreditation bodies, the Commission and the national competent authorities. The last building block of the definitive period is now operational, and without it there are no verified actual values.

How registration works

The route into the registry runs through the portal for third-country installation operators and consists of three steps. First, each individual at the verifier creates a personal EU Login with two-factor authentication. The verifier then completes an onboarding form in the portal covering the country and number of accreditation, company details, and the allocation of roles between administrative and simple users.

A single PDF must be attached containing the accreditation certificate, the company registration extract, proof of representation and the identity document of the authorised representative, preferably in English or with a translation. In the third step, the verifier applies for registration with the competent authority of the country in which it was accredited. Authorised CBAM declarants can now ask their suppliers precisely where their verifier stands in this process.

From registry entry to the 2026 declaration

The Commission's timeline is tightly interlocked. National accreditation bodies have been accrediting since April 2026, verifier registration has been running since September 2026, verification reports can be issued from January 2027, and the CBAM declaration for 2026 is due by September 2027.

That leaves roughly eight months between the first possible verification report and the filing deadline, during which every installation of every supplier has to be verified. Anyone who cannot find a registered verifier within that window will file on default values and carry the difference to well documented actual values as a cost.

The bottleneck sits with the accreditation bodies

15 national accreditation bodies were accepting applications from verifiers established in the EU when registry access opened, roughly half the member states. Five countries accept applications from verifiers established outside the EU.

The legal framework explains why the second figure is the more critical one. Verifiers from the EU generally apply to the accreditation body of their country of establishment and may go elsewhere only if their own country does not offer the service. Verifiers from third countries may apply to any accreditation body offering CBAM accreditation, which means they compete for five addresses. For importers with suppliers in India, Türkiye or China, this is where the availability of actual values for the 2026 declaration is decided.

Verifiers will also confirm the carbon price paid

Article 9 of the CBAM Regulation allows a carbon price actually paid in the country of production to be deducted from the number of certificates to be surrendered, provided it was not rebated or otherwise compensated on export. That information has to be certified by an independent, accredited person.

The draft implementing regulation was open for feedback from 13 May, the window closed on 10 June, and the regulation has not yet been adopted. It provides for a report on the carbon price paid whose certification covers four areas, namely the scope of emissions, the attribution of costs to the CBAM goods, the treatment of rebates, and evidence of payment. The same verifier may certify both the embedded emissions and this report. The verifier is therefore needed for two forms of evidence, for the emissions and for the cost reduction.

The United Kingdom names 16 recognised schemes

On 27 August, the UK government published a provisional list of the carbon pricing schemes that qualify for carbon price relief under the UK CBAM. It names 16 schemes, among them the EU Emissions Trading System, China's national emissions trading system, India's Carbon Credit Trading Scheme, the emissions trading systems of Japan, Korea, Kazakhstan, New Zealand, Montenegro and Switzerland, Australia's Safeguard Mechanism, Canada's federal Output-Based Pricing System, the carbon taxes of Chile, Serbia, Singapore and South Africa, and Taiwan's carbon fee.

The list reflects information available as of 19 June 2026. Emissions covered by free allowances in the originating scheme are excluded from relief, because no effective carbon price has been paid on them. Rebates or refunds received reduce the amount that can be claimed.

Who certifies what was paid under the UK CBAM

The regulations governing the calculation of the UK CBAM rate and the determination of carbon price relief were made on 13 July and come into force on 1 January 2027. They require a carbon pricing verification form, completed by an accredited independent verifier, in order to claim relief. The form covers the annual relevant emissions volumes, the share subject to the respective scheme element, monetary support received, and, for indirect schemes, the emission factors. The verifier must hold accreditation to the standards specified by HMRC, and the records including the form must be kept for six years after the accounting period.

For companies importing into both markets, two evidence chains will run in parallel from 2027, drawing on the same scarce pool of accredited verifiers.

Outlook

The final version of the implementing regulation on the deduction of a third-country carbon price is still pending and is intended to apply retroactively from 1 January 2026. The UK list is explicitly provisional and will be updated, and the UK CBAM starts on 1 January 2027. The sensible step now is to ask every supplier which verifier audits them, in which country that verifier is accredited, and whether it can also certify the report on the carbon price paid.

Support

If you would like to understand how verifier access to the registry and the UK list of recognised carbon pricing schemes affect your CBAM processes, for instance when selecting a verifier for suppliers in third countries or when assessing which actual values will realistically be available for the 2026 declaration, please get in touch at helge@kolum.earth.