Compliance and Penalties
      Back to home
      1. Help & Support
      2. CBAM Academy
      3. Compliance and Penalties

      When is Verification Required for CBAM Data and Who Performs It?

      Understanding the Verification Process for Emissions Data Under CBAM

      When is Verification Required?

      1. Transitional Period (2023-2025):

        • Importers must report embedded emissions but do not need to purchase CBAM certificates.
        • Verification of reported emissions is required, but with slightly less stringent standards.

      2. Full Implementation (from 2026):

        • Strict verification is mandatory for all reported emissions data.
        • Verified data must accompany CBAM certificate purchases.

      Who Performs the Verification?

      1. Accredited Verifiers:

        • Verifiers must be accredited under the EU ETS Accreditation and Verification Regulation.
        • These verifiers may be based in the EU or third countries if they meet EU standards.

      2. National Accreditation Bodies:

        • These bodies are responsible for accrediting verifiers and ensuring they meet required standards.

      Verification Process:

      1. Data Collection: Importers collect emissions data from non-EU suppliers.
      2. Initial Assessment: Verifiers review data and methodologies used for emissions calculations.
      3. Risk Analysis: Verifiers assess the risk of material misstatements in the data.
      4. Verification Plan: A plan is developed based on the risk analysis for thorough checking.
      5. Detailed Verification: May include site visits, document reviews, and data sampling.
      6. Addressing Issues: Discrepancies are reported for correction by the importer.
      7. Final Report: Verifiers issue a report confirming whether the emissions data is accurate.

      Key Points on Verification:

      • Importer Responsibility: The importer is responsible for hiring an accredited verifier.
      • Annual Requirement: Verification is required annually for each reporting period.
      • Scope: Verification includes both the calculation methodology and the final emissions figures.
      • Expertise: Verifiers must have sector-specific expertise.
      • Independence: Verifiers must be independent of the importer and the non-EU producer to avoid conflicts of interest.

      The EU is still refining some verification details for the transition period, but the system aims to align with existing EU ETS procedures for consistency and reliability.