EU CBAM Verification: What Companies Need to Know Before 2026

The countdown is on. The EU Carbon Border Adjustment Mechanism (CBAM) definitive period begins on January 1st, 2026, without delays—as officially confirmed by the EU Commission. This phase introduces a new key requirement that affects both CBAM Declarants and non-EU manufacturers: verification.

The End of Unverified Data

During the current transitional phase, EU importers have enjoyed a degree of flexibility around the use of actual emissions data: unverified data from suppliers has been permitted. But once the definitive phase kicks in, the rules tighten considerably.

CBAM Declarants will only be permitted to report actual emissions data from their non-EU suppliers if it has been verified by an accredited verifier. Without verified data in hand, EU importers will be forced to fall back on default values—which will be more costly and less favorable.

This post breaks down what the CBAM Regulation currently specifies about verification, what details are still to come in implementing and delegated acts, how the approved Omnibus CBAM reforms will affect verification, and what this means for both CBAM Declarants and non-EU manufacturers.

Core Principles of Verification

Regulation (EU) 2023/956 (from now on referred to as the EU CBAM Regulation) establishes the legal basis for verification, setting out the main rules, principles and content of a verification report.

Professional Scepticism

Verifiers must approach their work with an attitude of professional scepticism—meaning they can’t simply take data at face value.

Reasonable Assurance Required

The total embedded emissions to be declared in a CBAM declaration can only be considered verified if the verifier determines, with reasonable assurance, that the verification report is free from material misstatements and material non-conformities in the calculation of embedded emissions.

Installation Visits Are the General Rule

Physical installation visits by verifiers are mandatory unless specific criteria for waiving this requirement are met. This ensures verifiers can assess operations firsthand rather than relying solely on documentation.

Materiality Thresholds Matter

When deciding whether misstatements or non-conformities are material, verifiers must use thresholds provided by implementing acts.

For parameters where no threshold has been established, verifiers must rely on expert judgment to determine whether misstatements or non-conformities, individually or when aggregated with other misstatements or non-conformities, are material based on their size and nature.

What Does a Verification Report Include?

Annex VI of the EU CBAM Regulation outlines that a verification report should include, at least, the following information:

Identification of the installations where the goods were produced
Contact information of the operator of the installations where the goods were produced
The applicable reporting period
Name and contact information of the verifier
Accreditation number of the verifier, and name of the accreditation body
The date of the installations visits, if applicable, or the reasons for not carrying out an installation visit
Quantities of each type of declared goods produced in the reporting period
Quantification of direct emissions of the installation during the reporting period
A description on how the installation’s emissions are attributed to different types of goods
Quantitative information on the goods, emissions and energy flows not associated with those goods
In case of complex goods:
- Quantities of each input material (precursor) used
- The specific embedded emissions associated with each of the input materials (precursors) used
- If actual emissions are used: the identification of the installations where the input material (precursor) has been produced and the actual emissions from the production of that material
The verifier’s statement confirming that he or she finds with reasonable assurance that the report is free of material misstatements and of material non-conformities regarding the calculation rules of Annex IV (i.e., the EU CBAM methodology)
Information on material misstatements found and corrected
Information of material non-conformities with calculation rules set out in Annex IV found and corrected

Who Can Be a Verifier?

The regulation leverages existing infrastructure from the EU Emissions Trading Scheme (ETS). Any person accredited under Implementing Regulation (EU) 2018/2067—which lays down the rules for accreditation of verifiers under the EU ETS—can serve as a CBAM verifier. The current list of EU ETS verifiers can be found in the Union Registry.

National accreditation bodies may, on request, accredit a person as a verifier if such person demonstrates the capacity to apply the CBAM verification principles outlined in Annex VI.

How Do the Omnibus CBAM Reforms Affect Verification?

The reforms introduced to the EU CBAM as a result of the Omnibus I package were officially adopted on the 29 September 2025 with the Council’s approval finalising the legislative process. One of the key changes introduced will be the new de minimis threshold, which will shift to a mass-based threshold of 50 tonnes per importer per year.

Regarding verification requirements, the new changes will make verification applicable only to actual emissions data. Therefore, verification does not apply to the use of default values. In addition, accredited verifiers will be allowed access to the CBAM registry upon request from an operator in a third country, to verify embedded emissions.

What's Still Missing?

While the main framework is established, key operational details remain to be finalized through additional delegated acts and implementing regulations:

Conditions for granting accreditation
Control and oversight mechanisms for accredited verifiers
Procedures for withdrawing accreditation
Mutual recognition and peer evaluation of accreditation bodies
Expanded verification principles: More granular details on how verification should be conducted
Verifier qualifications: How CBAM verifier qualifications align with those required under the EU ETS
Installation visit waivers: The specific circumstances under which the mandatory installation visit can be waived
Materiality thresholds: Clear definitions for determining when misstatements or non-conformities are material
Documentation requirements: The supporting documentation needed for verification reports, including standardized formats

What This Means for Companies

The shift to verified data requirements isn’t just a new bureaucratic formality—it has real business implications for both EU importers and non-EU manufacturer.

For EU importers, companies that wait until the last minute to secure verified emissions data from their suppliers risk:

Higher costs from relying on default values
Competitive disadvantages compared to peers with verified data
Supply chain complications if suppliers aren’t prepared for verification requirements

For non-EU manufacturers, companies that can provide verified emissions data will:

Strengthen their market position with EU buyers
Avoid having their products associated with higher default values
Demonstrate compliance readiness that differentiates them from competitors

The time to act is now. Companies across the supply chain should be preparing for verification requirements and engaging with accredited verifiers to ensure their emissions data is properly documented and ready for verification well in advance of the January 2026 deadline.

How Does Carbon Glance Help?

At Carbon Glance, we specialise in helping importers and non-EU manufacturers successfully navigate CBAM, providing comprehensive digital solutions to tackle all their CBAM challenges.

Our CBAM software for non-EU manufacturers helps them calculate their CBAM emissions in line with the EU methodology, preparing all the data that will be required to be shared with the verifier.

Our CBAM software for CBAM Declarants helps them streamline CBAM compliance, request and track CBAM emissions data from suppliers, monitor CBAM costs and generate CBAM quotes to anticipate carbon costs and negotiate more effectively with suppliers.