How to tell a real CBAM verifier: five checks

Verified emissions data can lower your CBAM cost, but only if the verifierVerifierAccredited independent third party confirming the SEE is free of material misstatement; any EU or third-country legal person; only values in a verification report count for actuals. Importers receiving "verification reports" from third part is real. To tell a real CBAM verifier from an empty claim, use the Commission's Registry access procedure as a checklist. A verifier cannot use the CBAM RegistryCBAM RegistryEU IT system holding declarant accounts, declarations, verified emissions reports, certificate transactions and (from 2027) the published default carbon prices. without following it.

The first accredited verifiers are appearing now, and so are announcements that say little. The procedure gives you five concrete items to ask for.

What a verifier has to do to get in

Access takes two steps, and two different bodies handle them.

1. A technical user in EU Access. The Commission handles this step, and it rejects a request from anyone who is not an accredited entity. The applicant uploads one PDF. It contains three documents: the accreditation certificate, the company registration documents, and the identity document of the person acting for the company.
2. Registration as a verifier in the Registry's third-party portal, called O3CI. The request goes to the national competent authorityNational Competent AuthorityMember-State authority that grants declarant status, reviews declarations, ensures compliance and imposes penalties; competence follows establishment. of the country where the verifier was accredited. Only a registered verifier can then start a collaboration request with an operator in the Registry.

After registration, the verifier sends a collaboration request to the operator of the installation. The verifier receives the emissions report through the Registry and issues the verification reportVerification reportSingle electronic Commission template via the CBAM Registry; minimum content: general identification, verification information (team, visits, materiality applied, data verification incl. FAA per good, precursor verification incl. precursor- there. If the operator has not registered, the verifier exports the report as a signed PDF, and the declarant uploads it. That is more work for you, so the Commission recommends that operators register.

Five things to ask for

These five items come straight from what the procedure requires. Any real verifier can answer them in one email.

1. The accreditation certificate. Ask which national accreditation body issued it, and ask for its number and date.
2. The scope. Accreditation is granted per sector. Delegated Regulation (EU) 2025/2551 defines eleven activity groups. Ask which groups the certificate covers, and check that yours is one of them.
3. The legal entity. The name on the certificate must match the entity that will sign your report. It must also be the entity registered in the Registry.
4. Registry registration. Ask the verifier whether it has registered with its national competent authority, or when it will. The Commission's verification page says verifiers must register. The Registry rules give a verifier two months from accreditation, but not before 1 December 2026. You should therefore not expect a Registry entry from a verifier accredited this month. After that window, the verifier should be able to show one.
5. Who does the work. Ask for the names, employers and locations of the lead auditor, the auditors and the independent reviewer. Ask whether any part of the work is outsourced. The Regulation limits what can be outsourced and requires the operator's consent.

The certificate matters more than the brand name

An announcement is not evidence of accreditation. Some verifiers have announced accreditation without saying who accredited them or for which sectors. Such an announcement is a press release, and the certificate is the evidence. Once the registration window has opened, the Registry entry is evidence too. The procedure above shows that both must exist before a verifier can issue a report.

The Commission has not yet published its own list of accredited verifiers on its verification page.

Where accreditation stands

The Commission also states where accreditation stands. As of 29 September, 24 national accreditation bodies have agreed to offer CBAM accreditation, and 16 are ready to accept applications. That is the Commission's own total, although its rows show 17. Hungary's body has agreed but is not yet ready. We will cover the full picture next week.

What it means for importers

Verified emissions data lowers your CBAM cost only if the verifier is real. Treat a verification report as usable only after its verifier has given you the five items above.

What to do

• If you plan to use verified actual emissions for 2026, ask each supplier which verifier they intend to use. Collect the five items above before you rely on any report.
• Check the timing. The Commission's timeline says the first verification reports can be issued from January 2027. A report dated earlier cannot support a 2026 claim.
• Do not accept "accredited" as a description. Ask for the certificate.

Stuck on this in your own import data? Write to us and we will look at it with you.

This article summarises a Commission procedure and related rules. It is not legal, tax or customs advice.