The first accredited CBAM verifier is here: Where verification stands and how the scope extension moves on

The first accreditation has been granted

On 23 September 2026, a verification body based in Greece announced that it had been accredited by the country's national accreditation body as the first verifier of embedded emissions under CBAM, covering all six sectors. Two days later, the Commission updated its overview of the state of accreditation. For authorised CBAM declarants who want to work with actual emissions data for 2026, the verification system has become tangible for the first time.

Without a verifier, only default values remain

Since the Omnibus amendment, declarants have had the choice of determining the embedded emissions of their goods either on the basis of actual installation data or by using the Commission's default values. Default values are convenient, but they come with a mark-up and, according to the Commission itself, can turn out higher than verified, installation-specific data. Anyone who wants to use actual values needs a verification by an accredited verifier working to the applicable principles.

The requirements for these verifiers are set out in Delegated Regulation (EU) 2025/2551. Among other things, it requires competence in line with EN ISO/IEC 17029 and allows verifiers already accredited for the EU ETS to extend their scope to the corresponding CBAM activities instead of going through an entirely new procedure. Until this week, that choice was not really usable in practice, because there is no verification without an accredited verifier.

24 bodies, 15 accepting applications, 5 accrediting third-country providers

The Commission's updated overview of 25 September shows how uneven the accreditation map still is. 24 national accreditation bodies have agreed to offer CBAM accreditation. 15 of them are already accepting applications, including Germany's DAkkS, COFRAC in France, Accredia in Italy and the Raad voor Accreditatie in the Netherlands. Portugal, Romania, Slovakia and Slovenia intend to follow between September and November 2026. Croatia, Czechia and Hungary have agreed but are not yet ready. Cyprus, Estonia, Ireland and Malta do not offer CBAM accreditation. For an importer, the seat of the accreditation body is secondary, because a verifier accredited in one Member State is treated as accredited across the EU. What matters is whether enough verification capacity emerges before the 2026 data has to be verified.

The bottleneck lies outside the EU

The installations whose data must be verified are located in Türkiye, India, China, Ukraine or Egypt. Under Delegated Regulation (EU) 2025/2551, third-country verifiers can apply for accreditation to any national accreditation body that offers this procedure. According to the Commission's overview, seven currently do, and only five are actually accepting such applications, namely France, Italy, the Netherlands, Poland and Sweden. The Netherlands has concluded an agreement with the Turkish accreditation body TÜRKAK for this purpose, Sweden with Ukraine's NAAU. DAkkS does not accredit third-country providers. In mid-September, trade press already reported warnings of a bottleneck in accredited verifiers.

Accredited verifiers must register in the CBAM Registry within two months, and the Commission intends to publish the list on its verification page. So far, that list is empty. Importers should therefore clarify with their suppliers now whether their installations can deliver verified data for 2026, who will carry out the verification and when. The first CBAM declaration for 2026 imports is due by 30 September 2027, and certificate sales start on 1 February 2027. Anyone who only initiates verification in 2027 will compete with every other importer for the same scarce capacity and, in case of doubt, end up with default values.

Council and Parliament sort out the extension

In parallel, the legislative procedure to extend CBAM to downstream goods continues. On 15 September, Parliament adopted its position by 464 votes to 50, with 159 abstentions, and wants to include around 457 products. The Council agreed in June on roughly 200 products, while the Commission had proposed 180. On 24 September, the Council's Ad Hoc Working Party on CBAM discussed the proposal again to prepare the negotiating mandate for the trilogues. More than 250 products separate the lists, alongside open questions on anti-circumvention, on a special rule for accession candidates such as Ukraine, and on the Decarbonisation Fund, which Parliament wants to finance from 2027 rather than 2028. For importers of steel and aluminium goods such as fasteners, wire or household articles, the coming weeks will decide whether they fall within scope from 2028, as the Council position foresees.

Outlook

According to reports from Brussels, the first trilogue is expected to take place on 20 October in Strasbourg, and the Irish Council Presidency is aiming for an agreement by 30 November. On 5 October, the Commission will publish the certificate price for the third quarter of 2026. The Commission's verification page is worth checking regularly in the coming weeks, because that is where the list of accredited verifiers is to appear once the first registrations in the CBAM Registry are complete.

Support

If you would like to understand how the state of verifier accreditation affects your CBAM declaration for 2026, which of your suppliers can realistically deliver verified installation data and where default values remain the better choice, please get in touch at helge@kolum.earth.