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What the verification examines.

Verification is not the confirmation of a number. It is the confirmation that the operator complied with the Methodology Act — a wider test than most operators expect.

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

The six tests

Six things a CBAM verification tests.

  • 01 · Monitoring plan conformityWhether the plan itself complies with the Methodology Act, and whether the methodology applied through the year matches it. What is tested: installation boundaries; the grouping of CN codes into production processes; activity levels and functional units; the procedures for obtaining suppliers’ verification reports and for selecting the correct default value where none exists; chemical analyses and laboratory arrangements; heat flows, waste gases and the treatment of data gaps.
  • 02 · CompletenessEmission sources and source streams; the production processes present and the goods produced under each; precursors used, including those produced on site; direct and indirect emissions; heat imports and exports; waste-gas and electricity flows.
  • 03 · CorrectnessQuantities of fuels and materials consumed and produced; calculation factors — carbon content, emission factors, net calorific values, biomass fraction; quantities of heat and electricity; quantities of precursors in each production process.
  • 04 · AttributionWhether goods and interim products carry the correct CN codes; whether they are attributed to production processes without gaps or double counting; whether non-CBAM goods have been drawn into a production-process boundary by mistake; whether goods added during the year were assigned correctly. Activity levels count only goods that meet specification — off-spec output, scrap and waste are excluded, and packaging material is excluded while emissions from a packaging process are not.
  • 05 · Data flow and controlsThe data-flow activities and the control system behind them, tested by walk-through from the primary record to the reported figure, with recalculation and cross-checks against internal and external sources. Frequent weak points: manual transfers between logs, spreadsheets and reporting templates; unit conversions; automated controls that are absent or not working; no separation between the person who enters the data and the person who checks it.
  • 06 · Reliance on other verification reportsFor a precursor produced elsewhere: that a verification report exists for the confirmed production year, that it carries a positive statement, that the verifier’s accreditation was live and covered the relevant scope when it was signed, and that the figures used match it. Where any of those fails, the actual data must be replaced by the applicable default value. Evidence of a production year before 2026 is disregarded.
Commission guidance of 24 August 2026, §3.6 pp.41–43, §4.7 pp.53–58, §7.2–§7.7; Delegated Regulation (EU) 2025/2551, Annex II §§2.7–2.11
Where it goes wrong

Non-conformities that recur across installations.

These are examples of non-conformity drawn from the Commission’s own guidance, not from any engagement of ours.

  • Fuel quantities determined by instruments or methods other than those listed in the monitoring plan.
  • Emission factors different from those in the plan, used without justification.
  • Meters not maintained or calibrated as the plan requires, or used outside the manufacturer’s specification.
  • A fuel reported that the monitoring plan does not list.
  • A default value used for the wrong country of origin.
  • Actual data used for a precursor with no verification report from the installation that produced it.

Describing the test is not advice on how to pass it. Where a verification identifies an issue, it is reported as a finding.

Commission guidance of 24 August 2026, §6.1 p.82
Who may issue the report

Accreditation comes from one place, and one place only.

CBAM accreditation is granted by the national accreditation bodies of the EU and EEA states. The Commission states that they are the only stakeholders competent to grant it. A verification report signed by a body accredited under any other arrangement is not a CBAM verification report.

A verification company established in an EU or EEA country applies to the national accreditation body of that country, and may approach another body only where its own country does not offer the service. A company established outside the EU may apply to any national accreditation body that offers CBAM accreditation. That is the route Energy Up International LLC is following: the company is established in the Kingdom of Saudi Arabia and its application sits with ACCREDIA under ref. DC26PRT0296.

An applicant has to demonstrate three things to the accreditation body: technical competence in the industrial sectors concerned, independent and impartial operation, and verification approaches that are consistent and reliable.

The Commission expects the first CBAM verifiers to be accredited around September 2026, and will publish a list of accredited verifiers. Accreditation on its own is not enough to sign a report — the verifier also has to be registered in the CBAM Registry.

European Commission, CBAM verification — taxation-customs.ec.europa.eu
  • Consultancy is an unacceptable conflictA verifier — or any part of the same legal entity — that has provided consulting services to develop part of the monitoring and reporting process, or technical assistance to develop or maintain the monitoring and reporting system, cannot verify that installation. Commission Delegated Regulation (EU) 2025/2551, Annex II, point 1.7.2.
  • Independence runs in both directionsThe verifier is independent from the operator, from the competent authorities and from the Commission itself. Annex II, point 1.7.1.
  • The lead auditor rotatesWhere a CBAM lead auditor has carried out five annual verifications of the same installation and no other lead auditor has verified it in that time, the lead auditor takes a three consecutive year break from verifying that installation. Annex II, point 1.7.6.
  • The review cannot be outsourcedA verifier may not outsource the independent review or the drafting of the verification report, and retains full responsibility for anything it does outsource. Annex II, point 1.7.4.
Commission Delegated Regulation (EU) 2025/2551, Annex II, point 1.7. Energy Up International LLC performs validation and verification only; preparation, consultancy and training for a client are carried out by a separate entity and never by the body that verifies the same claim.
Where the report goes

Three parties, one verified figure.

  • 01 · The operator of the non-EU installationMonitors and calculates the embedded emissions of the goods it produces, following the CBAM methodology, and provides the accredited verifier with the information the verification needs.
  • 02 · The accredited CBAM verifierAssesses the monitoring approach, examines the calculation and the supporting evidence, and issues the verification report on which the declaration will rest.
  • 03 · The CBAM declarantThe authorised importer retrieves the verified emissions from the CBAM Registry and uses them in the annual CBAM declaration.

The report is not the end of the chain. Verification reports may be reviewed by the European Commission and by the National Competent Authorities of the member states. That is the practical reason for the standard applied here: a finding closed on paper but not in the evidence is a finding that survives into someone else’s review.

European Commission, CBAM verification; Guidance on CBAM verification and accreditation, 24 August 2026; Commission Implementing Regulation (EU) 2025/2546; Commission Delegated Regulation (EU) 2025/2551; Commission Implementing Regulation (EU) 2025/2547.
How CBAM verification works What the verifier receives

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.

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