CBAM: Moving Towards Full Compliance
The EU Carbon Border Adjustment Mechanism (CBAM) is entering a new phase, with increasing attention on the verification and quality of embedded emissions data.
Under CBAM, importers must submit annual declarations based either on actual verified emissions data or on applicable default values. Where actual emissions are used, the data must be verified by independent CBAM verifiers accredited by EU national accreditation bodies.
The verification process is designed to ensure that emissions data reported by non-EU producers is reliable, consistent and comparable. Non-EU installation operators are responsible for monitoring and calculating embedded emissions, while accredited verifiers assess the methodology, calculations and supporting evidence.
The implementation timeline is now moving forward. In September 2026, accredited CBAM verifiers can register in the CBAM Registry and begin verification activities. The first verification reports can be issued from January 2027, while declarants will be able to purchase CBAM certificates from February 2027.
The European Commission also published updated guidance on CBAM verification and accreditation on 24 August 2026, providing additional information for verifiers and National Accreditation Bodies.
Why it matters
CBAM compliance increasingly depends on the quality, traceability and verification of emissions data throughout the supply chain.
Importers should work with their non-EU suppliers to establish clear processes for collecting emissions information and supporting documentation. Businesses should also identify potential data gaps and clarify responsibilities between importers, suppliers and verification bodies.
Key takeaway: CBAM is moving beyond reporting towards a structured verification process. Reliable emissions data and strong documentation will be essential for effective compliance.
