2026 CBAM Verification: Everything You Need to Pass the Audit

The Carbon Border Adjustment Mechanism (CBAM) is transitioning from its reporting phase to full implementation in 2026. With this shift comes a critical new requirement: mandatory third-party verification of emissions data. For importers of steel, cement, aluminum, fertilizers, electricity, and hydrogen into the EU, understanding these verification requirements is no longer optional—it's essential for compliance.

What Changes in 2026: The New Verification Mandate

Starting with the first definitive reporting period in 2026, all installations producing CBAM goods must undergo verification by accredited third-party verifiers. This represents a significant shift from the transitional phase, where self-reported data was acceptable.

Physical Site Inspections: What to Expect

One of the most significant requirements for 2026 is the mandatory physical site visit at every installation producing CBAM goods. This applies to:

• All production facilities manufacturing CBAM-covered products
• Electricity generation installations (though virtual alternatives may be permitted due to lower complexity)
• Every supplier in your supply chain producing covered goods

Site Visit Requirements Beyond 2026

From the second reporting period onward, the rules become more flexible:

• Physical site visits required at least every other reporting period
• Virtual visits or waivers possible from 2027 for low-risk installations
• Criteria for virtual/waived visits include negligible risk, unchanged operations, and comprehensive remote documentation

Who Can Verify Your Emissions Data?

Not just anyone can verify CBAM emissions data. The EU is establishing a formal system of accredited verifiers, closely aligned with EU Emissions Trading System (ETS) procedures.

Verifier Requirements

• Accreditation: Verifiers must be officially approved and registered under pending implementing regulations
• Independence: Must be independent from the installations they verify
• Competence: Technical expertise in emissions monitoring and industry-specific processes
• ETS Alignment: Verification processes follow established EU ETS methodologies

Standards and Procedures: What Verifiers Check

CBAM verification follows strict standards designed to ensure data accuracy and reliability:

Materiality Thresholds

Verifiers apply a 5% deviation threshold for:

• Total specific embedded emissions per product code
• Free allocations calculations

This threshold provides clear guidance on data reliability and acceptable margins of error.

Use of Default Values

An important clarification: default values are permitted for parts of the supply chain (such as precursors) if properly documented with:

• Combined Nomenclature (CN) codes
• Country of origin information
• Default emissions values from official sources

However, using default values for some inputs does not disqualify the rest of your verified data. The key is proper documentation and transparency.

Essential Documentation: What You Must Prepare

Standardized verification reports must include comprehensive documentation covering:

Essential Report Components

• Identification: Operator and verifier details, installation information
• Site Visit Logs: Documentation of physical or virtual site inspections
• Monitoring Summaries: Overview of emissions monitoring systems and methodologies
• Emissions Calculations: Both direct and indirect emissions with supporting data
• Product Details: Process descriptions, CN codes, production volumes
• Origin Data: Country of origin and supply chain information
• CBAM Benchmarks: Comparison with EU benchmark values

Pre-Verification Preparation Documents

To prepare for verification, installations should have ready:

• Monitoring Methodology: Detailed documentation of emissions reporting stages and procedures
• Process Flow Diagrams: Manufacturing process flows demonstrating completeness
• GHG Accounting: Greenhouse gas accounting aligned with CBAM methods, including activity data and emission factors

Consequences of Non-Compliance

While specific penalty amounts are still being finalized in implementing regulations, the consequences of non-compliance are clear:

Critical Dates for 2026 Compliance

• January 1, 2026: Authorised declarant status becomes mandatory
• March 31, 2026: Deadline for authorised declarant applications (grace period)
• Throughout 2026: Mandatory physical site visits at all installations
• February 2027: CBAM certificate purchases begin
• September 30, 2027: First CBAM declarations due (extended deadline)
• End 2025: Final implementing regulations expected

Your Roadmap to Verification Success

To ensure compliance with 2026 verification requirements, importers should:

1. Engage with suppliers now to ensure they understand verification requirements
2. Consider pre-verification services to identify and address gaps early
3. Establish monitoring methodologies aligned with CBAM standards
4. Document everything—comprehensive records are essential
5. Apply for authorised declarant status well before the March 2026 deadline
6. Budget for verification costs and potential CBAM certificate purchases
7. Stay informed on final implementing regulations expected by end-2025

Moving Forward with Confidence

The 2026 CBAM verification requirements represent a significant compliance challenge, but with proper preparation, they're entirely manageable. The key is starting early, engaging suppliers proactively, and establishing robust monitoring and documentation systems.

As final implementing regulations are released in late 2025, stay vigilant for updates and refinements to these requirements. The verification landscape may evolve, but the fundamental need for accurate, verified emissions data will remain central to CBAM compliance.