On 24 August 2026, the European Commission published 141 pages of guidance for CBAM verifiers and national accreditation bodies. The document explains how the definitive verification and accreditation rules should be applied to goods imported from 1 January 2026.

The guidance creates no new legal obligation and leaves the emissions methodology, default values and reporting deadline unchanged. It describes the audit required to support an actual-emissions claim: the verifier assesses how the non-EU installation defines its production boundary, measures emissions and controls the data reported to the authorised CBAM declarant.

Reviewing a supplier certificate is insufficient because verification takes place at installation level. One installation report may cover several products and production processes, but the verifier still checks whether each product has been assigned to the correct combined nomenclature (CN) code, production route and calculation boundary.

The First Verification Normally Requires A Physical Visit

A physical site visit allows the verifier to compare the monitoring plan with the installation itself. The audit covers production boundaries, emission sources, technical connections, meters and the controls used to move operating data into the emissions calculation.

An ordinary virtual visit is available only when a physical visit took place in the immediately preceding reporting period, the verifier already understands the installation and no significant change has occurred. A complete waiver requires physical visits during both preceding reporting periods. These exceptions cannot be combined.

A first verification will therefore normally include a physical visit. Force majeure can support a virtual visit under separate conditions, while a limited waiver exists for qualifying zero-emission electricity installations. For most steel, aluminium, cement, fertiliser and hydrogen plants, the operator should plan for a verifier to enter the installation.

The verifier also assesses the monitoring plan. Under the EU ETS, the competent authority normally approves an installation's monitoring plan. CBAM places this assessment within the verifier's work, so an incomplete plan can limit the audit scope and prevent a positive verification opinion.

The guidance also clarifies the 5% materiality threshold. It applies to specific embedded emissions (SEE) and specific embedded free allocation (SEFA) for each good identified by its CN code. The operator must correct identified misstatements where possible. A data gap must be closed with surrogate data or a conservative estimate even when it falls below the threshold.

Actual Values Depend On The Upstream Production Chain

For complex goods, actual emissions from a precursor require a verified report from the installation that produced that precursor. The downstream verifier checks that the precursor report is valid, covers the correct installation and production year, and supports the amount consumed in the downstream process.

A steel producer using externally produced pig iron or direct reduced iron may need the precursor producer's verified report before completing its own calculation. If the report does not arrive by the operator's internal deadline, the guidance recommends using the applicable default value and proceeding with verification.

The Commission recommends starting verification during the reporting year rather than waiting until production data are closed. For 2026 imports, authorised declarants must submit their first annual declaration by 30 September 2027. The guidance suggests that verified reports should reach declarants by mid-August, allowing time to assemble the declaration and purchase certificates.

An importer expecting to use actual values should therefore ask when the supplier will contract a CBAM-accredited verifier and schedule the first site visit. Where precursors are material to the calculation, the supplier also needs a timetable for the upstream verification reports. A certificate issued under another carbon programme does not replace the CBAM verification report.

Accreditation And Registry Access Set The Available Capacity

The Commission expects the first CBAM verifiers to receive accreditation around September 2026. Accredited verifiers can register in the CBAM Registry from 1 September and must do so within two months of receiving accreditation. The first verification reports can be issued through the Registry from January 2027.

As of 24 July, 24 national accreditation bodies had agreed to provide CBAM accreditation and 13 were ready to accept applications. Seven had agreed to accredit verification companies established outside the European Union, while four were already accepting those applications.

The July table records whether national bodies can accept applications; it doesn't report completed accreditations or available audit teams. The new guidance estimates that accreditation for a new verifier normally takes six to twelve months. Existing accreditation under the EU ETS or a comparable greenhouse-gas programme may simplify parts of the assessment, but it does not automatically produce CBAM accreditation.

CBAM accreditation is granted by activity group and the availability will depend on sector, country, language and the ability to travel for first-year physical visits. For this, a verifier accredited for cement cannot automatically verify a steel installation, and indirect-emissions work requires the relevant additional scope.

What Importers And Producers Should Do During 2026

Operator can be: registered in the CBAM Registry, so the accredited verifier transmits the report through the system and the declarant retrieves the verified emissions information there; or not registered (more burdensome and less protective of commercially sensitive data), the verifier exports an electronically signed report and the operator sends it with the full emissions-report spreadsheet to the declarant outside the Registry.

Non-EU operators should complete their monitoring plan before the site visit and test whether annual data can be reconstructed from meters, production records and accounting systems. If the installation produces complex goods, its verification timetable should include the reports needed from precursor suppliers.

EU importers should compare the corrected default value with the supplier's expected actual emissions before committing to verification costs. When the supplier's emissions are below the default, a completed verification can reduce the number of certificates calculated for the import. A negative opinion, insufficient audit scope or a missing precursor report can remove that advantage and return the calculation to default values.

The Commission's verification page provides the guidance, accreditation status and implementation timeline. Suppliers planning to use actual emissions for 2026 goods should secure the relevant verifier and first site visit while the reporting year is still open.