How to choose a CBAM accredited verifier

Since 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM, known as MACF in French) has made EU importers of steel, aluminium, cement or fertilisers pay for the carbon emitted to produce them. To declare the plant's actual emissions rather than the Commission's flat default value, the importer needs a report signed by a CBAM verifier: a body accredited in the EU that has checked the plant's figures and visited it.

This verifier is chosen and contracted by the operator of the plant, in Morocco, Türkiye or India, not by the importer. The sections below are written for the 2 of them: the plant that has to choose, and the importer that needs to know which report to require.

1Who can act as a CBAM accredited verifier?

Only a legal entity accredited by the national accreditation body of a Member State may verify CBAM emissions. This is laid down in Article 18 of Regulation (EU) 2023/956, as amended by the October 2025 "omnibus" regulation. The verifier only verifies actual emissions: default values are never verified, as our article on choosing between default values and actual emissions points out.

An accreditation issued in the EU

The procedure is laid down in Delegated Regulation (EU) 2025/2551, applicable since 1 January 2026. The verifier must comply with 2 standards: ISO/IEC 17029, which sets the rules for any validation and verification body, and ISO 14065, which applies them to environmental information. In France, COFRAC opened accreditation on 20 August 2026: bodies established in France submit their application, while those established abroad first get in touch with COFRAC.

Accreditation is granted by group of activities. The 11 groups follow the CBAM sectors (cement, fertilisers, iron and steel, aluminium, hydrogen, electricity) and add carbon capture and indirect emissions. A verifier accredited for cement cannot sign the report of a steelworks.

EU ETS verifiers

Bodies that already verify the emissions of European plants covered by the EU carbon market (EU ETS) are no longer recognised automatically. The 2023 version of the regulation gave them this equivalence, and the omnibus regulation removed it. They apply for an extension of their accreditation to the CBAM groups of activities that match their sectors, through a simpler procedure than a first accreditation.

Verifiers established outside the EU

A body established in Morocco, Tunisia or Türkiye can be accredited by any European accreditation body that accepts applications from third countries. As at 21 October 2026, 7 of the 28 bodies do so, including COFRAC, according to the Commission's table. The Netherlands has signed an agreement with the Turkish accreditation body, and Sweden with its Ukrainian and British counterparts.

As at 27 October 2026, the Commission's page on verification announces a list of accredited verifiers without having published it yet, and COFRAC does not publish one either. On its page updated on 16 October, France's Directorate General for Energy and Climate still gives no date for the first verifications in France.

2Who chooses the verifier: the non-EU operator or the importer?

The plant, and the plant alone. The Commission's FAQ says so: only operators outside the EU may decide to calculate their emissions and have them verified. They may use any accredited verifier, and the verification covers the installation, not an import.

The operator outside the EU

The verifier checks the installation's emissions report, drawn up by the operator for a calendar year. It issues only one per installation per year: a plant that supplies 10 importers in 5 countries sends them the same report. If the plant has registered in the CBAM Registry, the report goes through it directly; otherwise, the plant sends it to its customers by its own means, which remains allowed in 2027.

No text says who pays for the verification. The Commission's guidance lists the operator paying the verifier among the impartiality risks, which implies that the plant usually pays. How this cost is split between the plant and its customers is settled in the purchase contract, like the other costs detailed in our article on the cost of CBAM.

The EU importer

The importer does not choose the verifier, but it remains solely responsible for its declaration, verification report included. If a verifier's error leads it to surrender too few certificates, the national authority may reduce the penalty. According to the Commission, its first step is to ask each supplier whether it will provide verified actual emissions. It then requires 3 items, as for any verification of a supplier's data:

• The verifier's name, its accreditation body and its scope, which must cover the group of activities of the product purchased.
• A report covering production year 2026, with a satisfactory conclusion: for goods imported in 2026, no other year counts.
• The summary of the emissions report, by product, which the Commission suggests sending with its communication template, recommended but not mandatory.

Without a verified report, the default value applies, with a 10% mark-up in 2026, and only 1% for fertilisers.

Fake report offers

According to the Commission, a third party offering an importer a paid verification report is probably running a scam. The report covers an installation: only the plant that made the goods can pass it on. For 2026 emissions, a report without a visit to the plant, or delivered before January 2027, cannot be compliant.

3What criteria should an operator use to choose a verifier?

No text provides a selection grid: the criteria are found in the regulation and in the Commission's guidance. They are checked before signing, in this order.

The scope of accreditation

The accreditation certificate states the body that issued it, the groups of activities covered, the countries, the validity dates and the standards. Ask for it before the quote, and compare its scope with the plant's product: a report signed outside the scope is worthless. Once the verifier is registered in the CBAM Registry, its name, scope and dates become public.

Independence

Regulation 2025/2551 prohibits the verifier from checking a plant it has helped to set up its monitoring. An unacceptable risk exists as soon as the verifier, or an entity in its group, has provided one of these services:

• Advice on the monitoring methodology, or drafting the monitoring plan or the plant's emissions report.
• Technical assistance to set up or maintain the system for monitoring and reporting emissions.
• The same service provided by an organisation linked to the verifier through capital, management, staff or contracts.

The guidance also recommends waiting at least 2 years before assigning an auditor who comes from consultancy to a verification. The same lead auditor cannot carry out more than 5 annual verifications of an installation in a row: they then take a 3-year break.

Language and site visit

The lead auditor must speak English, and the team must include at least one auditor who speaks the plant's language: Arabic or French in the Maghreb, Turkish in Türkiye. The verifier must also be able to travel there: an office in the country is not mandatory, but the guidance asks the verifier to consider security, visas and travel time before signing. It may entrust part of the work to a local body, with the plant's consent, except the independent review and the report.

On the quote, the guidance describes 2 ways of handling the monitoring plan. The verifier assesses it within its engagement, or in a separate engagement, which the Commission considers more transparent about the number of days billed. No minimum duration is set, and there is no public fee schedule: the time depends on the size and complexity of the installation and on how remote it is, and the contract must provide for adjusting it.

4How does a CBAM verification work?

Verification provides reasonable assurance, the most demanding level of audit: the verifier must be able to state that the report contains no material misstatement, not merely that it saw nothing abnormal. The level is set by the regulation, whereas the third-party verification of a Bilan Carbone® (the French carbon accounting method) leaves it to the company to choose. Implementing Regulation (EU) 2025/2546 sets out its principles, and the graphic below shows its steps.

The plant visit

In the first year, a physical visit to the installation is mandatory in all cases, except in serious, extraordinary and unforeseeable circumstances. In the following years, the verifier may replace it with a remote visit if the installation is simple, well known and has not changed significantly, or waive it after 2 years of physical visits. A physical visit is still required at least every 2 years.

The 5% threshold

A misstatement becomes material above 5% of the emissions per tonne of each product, identified by its Combined Nomenclature customs code. The same threshold applies to the free allocation embedded in the product. For a product declared at 2 tCO2e (tonnes of CO2 equivalent) per tonne, a discrepancy of more than 0.1 tCO2e per tonne prevents a satisfactory conclusion if it is not corrected. Below this threshold, an error may still count, depending on the verifier's judgement.

The verification report

The report follows the Commission's electronic template, in English, and the verifier issues it in the CBAM Registry from 1 January 2027. Its conclusion falls into 4 cases:

• Satisfactory: the actual emissions may be declared.
• Not satisfactory, because of uncorrected material misstatements.
• Not satisfactory, because of non-conformities that prevent a conclusion.
• Not satisfactory, because the scope of the verification was too limited.

The guidance advises delivering reports to importers by mid-August at the latest, so that they can prepare the declaration due on 30 September 2027 and buy their certificates.

5What should the plant prepare before the verifier's visit?

The time billed and the outcome of the verification depend mainly on what the plant puts on the table. The Commission recommends signing with a verifier early in the reporting year, and starting the work during that year rather than afterwards, to avoid the bottleneck of the first months of 2027.

The plant's file

For a first verification, the file brings together 6 documents, drawn mostly from Implementing Regulation (EU) 2025/2547 on calculating emissions:

• The monitoring plan, written in English, which describes the installation, its processes, its measurement points and its calculation methods.
• The year's emissions report and its summary, with the minimum content set by Annex IV, which the plant then sends to its customers.
• The emissions of purchased precursors, with their own verified report: no threshold allows small quantities to be left out.
• For cement and fertilisers, evidence of the electricity consumed, and of any direct connection to a power plant.
• The installation's identifier, which the verifier checks itself if the plant has not registered in the CBAM Registry.
• Where applicable, evidence of the carbon price paid in the country of origin, certified by an independent person.

The Commission's guidance and FAQ rule out 3 shortcuts: precursors without a verified report, evidence dated before 2026, and emission factors taken from a life cycle assessment or a database.

The timetable

For 2026 emissions, the reporting year is drawing to a close. No verification work starts before accreditation, but the Commission invites plants to get in touch now with the verifiers that are applying for it. The risk analysis and the visit will therefore take place, for the most part, in early 2027, before the final check and the report. A plant that buys precursors from other plants waits for their reports before finalising its own; failing that, it uses the default values for those precursors. The full timetable, from measurement to declaration, is in our article on default values.

At Projet Celsius, we think the first year will hinge on the monitoring plan, which the verifier must be able to check in a single visit. A plant that documents its measurement points, traces its precursors and writes its plan in English before signing reduces the time billed and the risk of an unsatisfactory report. Accredited verifiers are likely to be scarce in early 2027, when every plant will want its report. And whoever helps the plant write its plan will not be able to verify it: the regulation prohibits combining the 2 roles.

6Key takeaways

• The operator of the plant outside the EU chooses its CBAM verifier and signs the contract, and a single report a year serves all its customers.
• The verifier must be accredited by a European national body for the plant's group of activities; 7 bodies accept verifiers from third countries.
• It cannot have advised the plant on its monitoring, must speak English and the site's language, and must be able to travel there.
• In the first year, a physical visit to the plant is mandatory, and the report can only be issued from January 2027.
• As at 27 October 2026, no list of accredited verifiers has been published: plants would do well to book early.

The cost of CBAM per tonne, country by country, is detailed in our article on the cost of CBAM, and the obligations of European producers in our CBAM guide for industrial producers.

Further resources

Frequently asked questions

1Who can be a CBAM accredited verifier?

A legal entity accredited by the national accreditation body of a Member State, such as COFRAC in France, for the group of activities of the product verified. It must comply with the ISO/IEC 17029 and ISO 14065 standards. A body established outside the EU can be accredited by a European body that accepts third countries: 7 out of 28 do so as at 21 October 2026.

2Can an EU ETS verifier verify emissions for CBAM?

Not automatically. The October 2025 omnibus regulation removed the automatic equivalence provided for in the 2023 version. A verifier accredited for the EU carbon market must apply for an extension of its accreditation to the corresponding CBAM groups of activities, through a simpler procedure than a first accreditation.

3Who chooses and pays the CBAM verifier?

The operator of the plant outside the EU chooses it and signs the contract: the importer cannot commission a verification on its own account. No text sets who pays, but the Commission's guidance lists payment by the operator among the impartiality risks, which implies that the plant usually pays. How the cost is shared with customers is settled in the purchase contract.

4Is a site visit mandatory for CBAM verification?

Yes, in the first year, in all cases, except in serious, extraordinary and unforeseeable circumstances. In the following years, the verifier may replace it with a remote visit or waive it, under strict conditions: a simple installation with no changes, and physical visits in previous years. A physical visit is still required at least every 2 years.

5How much does a CBAM verification cost?

There is no public fee schedule, and the regulation sets no minimum duration for a verification. The time billed depends on the size and complexity of the installation, how remote the site is and the state of the monitoring plan. The Commission's guidance advises separating, on the quote, the assessment of the plan from the verification.

6Where can I find the list of CBAM accredited verifiers?

On the European Commission's "Verification of CBAM emissions" page, which announces it but had not yet published it as at 27 October 2026. Accredited verifiers have been able to register in the CBAM Registry since 1 September 2026, within 2 months of their accreditation, and their name, scope and dates become public there. Accreditation bodies such as COFRAC will also have to publish the list of the verifiers they accredit; COFRAC does not yet publish one for CBAM.

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