Evidence that withstands scrutiny
Evidence that withstands scrutiny
What happens in a CBAM verification, in what order, and where each stage is written in the legislation.
CBAM accreditation · assessment under way · ACCREDIA DC26PRT0296 — status record
Scope, sector, competence and independence. The first gate, and the one that protects everything after it.
May be declinedExamination of the version actually applied and of the changes that matter to the reporting period.
VerifierUnderstanding the installation, its goods, its production routes and its data flow.
VerifierLocating where misstatement and non-conformity are most likely.
VerifierThe type, depth and location of testing follow the risk analysis.
VerifierTracing evidence, interviews, data and measurement testing.
On siteThe response is examined. No correction is proposed.
No corrections proposedBy a reviewer who took no part in the execution.
Independent reviewerAfter accreditation, and in accordance with the operational requirements of the CBAM Registry.
After grantThese nine stages group the process requirements of Annex II to Delegated Regulation (EU) 2025/2551, as explained in the Commission’s guidance of 24 August 2026. The Commission does not fix a number of stages; the reference for each is given here.
| Stage | Annex II, Reg. (EU) 2025/2551 | Commission guidance |
|---|---|---|
| 01 — Pre-engagement | §2.2 | §4.2, pp.46–47 |
| 02 — Information received | §2.3 (a)–(n) | §4.3, pp.47–48 |
| 03 — Monitoring plan assessment | §1.2 | §5.1–§5.2, pp.71–75 |
| 04 — Strategic analysis | §2.4 | §4.4, pp.49–50 |
| 05 — Risk analysis | Article 1 definitions | §4.5, pp.51–52 |
| 06 — Verification plan | §2.6 | §4.6, p.53 |
| 07 — Verification activities and site visit | §2.7 · §2.9 · §2.13 | §4.7, §4.9 |
| 08 — Findings and correction | §2.9 | §4.10, §6 |
| 09 — Independent review and report | §1.7.4 · §2.17.2 · §2.17.3 | §4.14, §4.15 |
CBAM sets no deadline for verification itself, but three fixed points shape every engagement. Verification cannot be concluded before January of the year following the reporting period, because complete data to 31 December is needed first. The authorised declarant’s annual CBAM declaration is due by 30 September. Working back from that, verification reports should reach declarants by mid-August at the latest.
The consequence for an operator is simple: the verification window for a reporting year runs from January to roughly July of the following year, for every installation in the world at once. Engagements are accepted in the order there is competent capacity to run them.
One more timing fact worth stating plainly: verification examines what happened, not what was intended. Monitoring that did not exist during the reporting period cannot be reconstructed after it.
Commission guidance of 24 August 2026, §4.1, pp.44–45Tell 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.
