Steel coils on a European port quay at dusk
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Independent verification of actual embedded emissions.

Under the CBAM definitive regime the operator of a non-EU installation monitors and calculates its own embedded emissions. Where a declaration rests on actual emissions rather than default values, an accredited CBAM verifier assesses the monitoring approach, examines the calculations and the supporting evidence, and issues a verification report. The operator produces the number. The verifier tests it.

CBAM accreditation · assessment under way · ACCREDIA DC26PRT0296 — status record

Submit pre-engagement information Accreditation status

The regime is running

Applied since 1 January 2026. First filing 30 Sep 2027.

Actual or default

Both routes are lawful. The operator chooses.

Verification follows data

Required only where the declaration rests on actual data.

Who does what

Four parties.
The boundaries are structural.

A non-EU installation

Non-EU operator

Sets the boundary and the monitoring methodology, records the data, and produces the emissions report.

Accredited verifier

Assesses the plan, examines the calculations and the evidence, visits the site, issues the report.

A verification team examining evidence
Emissions data held in a register

CBAM Registry

Holds the verified data. No active accreditation and Registry entry, no report can be issued.

Authorised declarant

Retrieves the verified emissions, files the declaration and surrenders certificates.

A European import terminal at night

Above the chain sits the EU national accreditation body, which accredits the verifier for named activity groups and oversees it through annual surveillance. Energy Up International sits in one box only. — Regulation (EU) 2023/956, as amended, Articles 7, 8 and 10a

A verifier reading an operator's monitoring plan
Independent review of verification evidence
The CBAM difference

ETS approves the plan.
CBAM makes the verifier assess it.

In the EU Emissions Trading System a competent authority approves the installation’s monitoring plan, and the verifier only checks that it was applied. CBAM has no equivalent authority step: the Commission’s guidance states that the separation is not possible under CBAM and that the assessment has to be carried out by the verifier itself.

the verification standard

  • Both validation and verification
  • ETS accreditation does not cover CBAM
  • The verifier assesses, never drafts
Sampling and inspection during a site visit

Commission guidance of 24 August 2026, §5.1–§5.2 and §9.2.4; Delegated Regulation (EU) 2025/2551, Annex II §1.2 and §1.7.3

  • +1

    activity groups applied for, plus LII

  • items the operator provides

  • things a verification tests

  • %

    materiality, on emissions and on free allocation

The engagement

What a verification
actually involves.

What the verifier receives

Fourteen items, from the monitoring plan to the precursor and electricity verification reports. Every one of them is held by the operator; none is produced by the verifier.

THE FOURTEEN ITEMS

What it examines

Six tests: the monitoring plan’s conformity, completeness, correctness, attribution to production processes, the data flow and its controls, and reliance on another verifier’s report.

THE SIX TESTS

The order it works in

Nine stages, from pre-engagement and the monitoring-plan assessment through risk analysis, the site visit and correction, to an independent review before the report is signed.

THE NINE STAGES
The outcome

What the verification
report actually says.

CBAM verification is performed to obtain reasonable assurance — a high but not absolute level — that the operator’s emissions report is free from material misstatement. Limited assurance does not meet CBAM requirements. Materiality is 5% of the total specific embedded emissions for each good, and 5% of the total specific embedded free allocation.

Positive statement

Verified without comments, or with comments

Negative statement

Three named triggers, no graded scale

A site visit at an industrial installation
  • A site visit is part of the verification, not an option
  • A virtual visit only in defined cases — never a first verification
  • Independent review before signature, never outsourced

Implementing Regulation (EU) 2025/2546, Article 5(1)(a), 5(1)(b) and 5(2); Delegated Regulation (EU) 2025/2551, Annex II §2.17.2 and §1.7.4

An independent review of verification evidence
Reporting basis and sectors

Actual verified data,
or default values.

Sampling for producer-specific data
Verification required

Producer-specific data, monitored through the reporting period and subject to independent verification. It reflects the installation’s own performance, and it requires that the monitoring existed while the year was running.

Actual data

Article 7(2) — first route

Published default values
No verification

The applicable default values, published by the Commission. No verification, and no figure that reflects what the installation actually does.

Default values

Article 7(2) — second route

Sectors and activity groups

The goods CBAM covers,
and where they sit.

Every CBAM good sits in an activity group under Delegated Regulation (EU) 2025/2551, Annex I. The group decides the competence a verifier must hold; the bar shows how many groups the sector spans.

Cement

I

Fertilisers

III · IV

Iron and steel

V · VI · VIII

Aluminium

VII · VIII

A kiln line at a cement installation

Indirect emissions are activity group LII. Imported electricity is LI and CCUS is L; neither is part of our accreditation application.

Delegated Regulation (EU) 2025/2551, Annex I

Energy Up International’s accredited CBAM activity scope will be published once the accreditation process is complete. Nothing on these pages indicates an accredited scope.

An operator team and a verifier reviewing installation drawings
Recording activity data at an installation
Common questions

The questions that come
before a contract.

These come up before any contract is signed. The answers reflect the rules as they stand under Regulation (EU) 2023/956 and the implementing acts in force, and our own position within them.

Are you an accredited CBAM verifier?

Not yet. Our application is accepted by ACCREDIA under ref. DC26PRT0296 and the assessment is under way. Accredited work follows the grant.

01

Who assesses our monitoring plan?

There is no authority approval step under CBAM. The verifier assesses the plan against the Methodology Act, and may not have helped write it.

02

Do we need verification at all?

Only where the declaration rests on actual emissions. A declaration built on default values is not verified. Both routes are lawful.

03

Can you help us prepare the file you would later verify?

No. We take no part in developing a monitoring methodology, drafting a monitoring plan or drafting an emissions report for an operator we may verify. Where verification identifies an issue it is reported as a finding, not as advice.

04

When does verification have to happen?

It cannot be concluded before January of the year following the reporting period, because complete data to 31 December is needed. The declaration is due 30 September, so reports should reach declarants by mid-August at the latest.

05

Describe the claim — not the service.

Tell us what must be relied on, who will rely on it and by what date. We will confirm the correct programme, evidence requirement and responsible entity — or tell you it is outside our scope.