European Commission Publishes CBAM Verifier Guidance: Key Points for Importers

On 24 August 2026, the European Commission published new guidance on verification and accreditation under the Carbon Border Adjustment Mechanism (CBAM). The Commission subsequently published a procedure describing how accredited verifiers may obtain access to the CBAM Registry from 1 September 2026. These documents provide additional operational detail ahead of the first annual CBAM declarations covering imports made in 2026. 

From January 2027, accredited verifiers will issue verification reports through the CBAM Registry, enabling authorised CBAM declarants to use verified actual emissions where the applicable legal conditions are met. Where compliant verified data is unavailable, declarants may need to use the applicable default values. Whether actual emissions are commercially more favourable depends on the installation’s emissions intensity and the relevant default value.

The announcement is available on the Commission's Taxation and Customs Union website. The guidance is explanatory and is not legally binding. Applicable EU legislation and legally binding acts published in the Official Journal of the European Union take precedence.

What did the Commission publish?

The Commission materials address verification, accreditation and access to the CBAM Registry:

• Guidance for verifiers and National Accreditation Bodies. The guidance explains the requirements applicable to verifiers intending to verify emissions reports prepared by operators of installations outside the EU that produce CBAM goods. It also covers the accreditation and surveillance functions of National Accreditation Bodies.
• CBAM Registry access procedure. The procedure explains how accredited verifiers may apply for access to the CBAM Registry and describes the respective roles of verifiers, accreditation bodies, the European Commission and national competent authorities.

Accreditation by the relevant National Accreditation Body is the first step. The verifier then applies for access to the CBAM Registry. The relevant national competent authority checks that the verifier is duly accredited before granting access.

Selected key CBAM dates for verification and the first reporting cycle 

Date	Milestone
1 January 2026	CBAM definitive regime begins
24 August 2026	Guidance for verifiers and accreditation bodies published
1 September 2026	Registration of accredited verifiers in the CBAM Registry opens
Within two months of accreditation	Deadline for a verifier to register in the CBAM Registry, but not before 1 September 2026
From January 2027	Verifiers begin issuing verification reports in the CBAM Registry
By 30 September 2027	First annual CBAM declaration due, with the corresponding number of CBAM certificates to be surrendered, for imports made in 2026.

The European Commission states that accreditation is followed by an application for Registry access, that registration must take place within two months of accreditation but not before 1 September 2026, and that verification reports will be issued in the Registry starting in January 2027. The amended CBAM Regulation provides that the first annual declaration, covering 2026, must be submitted by 30 September 2027 and that the corresponding certificates must be surrendered by the same date.

Where this fits in the CBAM timeline

CBAM has applied under its definitive regime since 1 January 2026. It covers imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity into the EU. Authorised CBAM declarants are subject to reporting obligations and must purchase and surrender CBAM certificates corresponding to the embedded emissions of imported goods, subject to the applicable rules and adjustments.

The verification infrastructure is an important operational link between emissions reporting and the annual CBAM declaration. Verified actual emissions may reduce the number of CBAM certificates required where an installation’s emissions intensity is below the applicable default value. This is not automatic. The outcome depends on the applicable methodology and the installation’s emissions, relevant adjustments. 

From January 2027, accredited verifiers will issue verification reports through the CBAM Registry, and authorised CBAM declarants will use the reports when completing their declarations where actual emissions are declared and the applicable legal conditions are satisfied.

What should importers and suppliers consider now?

For companies importing CBAM goods, the guidance signals that the compliance chain for 2027 is being assembled on schedule. Practical steps for the coming months include:

• Map the supply chain. Identify which non-EU installations supply CBAM goods and whether their operators monitor emissions in a form a verifier can review.
• Compare actual against default. Estimate the CBAM cost under default values and under expected actual emissions. The gap defines how much verification is worth.
• Secure verifier capacity early. Accreditation and Registry registration take time, and verifier availability may tighten as the first CBAM declaration deadline approaches.
• Factor certificate costs into contracts.CBAM certificate prices track EU ETS allowance prices, and the pricing relationship shapes the cost of certificates over time.

Electricity is a CBAM good, so the mechanism also matters for cross-border power flows into the EU from non-EU neighbours.

FAQ

What is a CBAM verifier?

A CBAM verifier is a legal entity accredited by a National Accreditation Body to perform verification activities under the applicable CBAM rules. The verifier assesses emissions information and issues a verification report. The precise verification requirements depend on the goods and emissions concerned. Verification may be required for an authorised CBAM declarant to use actual embedded emissions, but other legal conditions may also apply.

When must CBAM verifiers register in the CBAM Registry?

Within two months of receiving their accreditation, and not before 1 September 2026. After registration, the National Competent Authority grants Registry access once it has confirmed the accreditation.

Can importers still use default values in their CBAM declarations?

Yes. Default values apply where emissions are determined on that basis under the CBAM rules, including where compliant verified actual emissions are unavailable.Actual verified emissions usually lower the CBAM cost for goods produced with lower carbon intensity than the default assumption, which is why verification capacity matters commercially. However, actual emissions are not necessarily more favourable in every case. Their effect depends on the installation’s emissions intensity and the applicable default value.

When are the first CBAM declarations due?

The first annual CBAM declaration is due by 30 September 2027 and covers goods imported during 2026. The authorised CBAM declarant must also surrender the corresponding number of CBAM certificates by that date. From January 2027, accredited verifiers will issue verification reports through the CBAM Registry.

Does CBAM apply to electricity imports?

Yes. Electricity is one of the six product groups covered by CBAM, alongside cement, iron and steel, aluminium, fertilisers and hydrogen.

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Disclaimer

This article is prepared by D.TRADING for general informational purposes only and does not constitute legal, financial, investment, accounting, tax, or regulatory advice. The information contained herein is based on publicly available sources and reflects opinion on the regulatory environment as of the publication date. D.TRADING makes no representations or warranties, express or implied, as to the accuracy, completeness, or timeliness of the information provided. This document is not an offer or solicitation to buy or sell any energy products, commodities, or financial instruments.