CBAM Verification: Accredited Verifiers Register From September 2026

ByRegReportingDesk

On 24 August 2026 the European Commission published guidance on CBAM verification and accreditation for verifiers and National Accreditation Bodies, and on the same day it released the procedure that lets verifiers into the CBAM Registry from 1 September 2026. The guidance is written for the people who accredit and perform verification, but the calendar it confirms is what matters to an authorised CBAM declarant. From January 2027 verifiers start issuing verification reports in the Registry, and any CBAM declaration that reports actual embedded emissions has to rest on one of those reports.

That timing is the hinge of the definitive period. CBAM goods imported from 1 January 2026 fall within the first definitive-regime compliance year where the importer is subject to the Regulation’s obligations, including after application of the Article 2a de minimis exemption, yet the Commission’s operational timeline places the start of NAB CBAM accreditation activity in April 2026, while accredited verifiers cannot request registration in the CBAM Registry before 1 September 2026. Whether a declarant can plan on verified actual values, or has to fall back on the Commission’s default values, depends on where each of these dates sits against its own supply chain.

Related reading: CBAM Definitive Period Importer Reporting Guidance

The dates now driving CBAM verification

Deadline pressure is why the guidance landed when it did. The sequence to map against a supply chain is short but strict.

  • 1 January 2026: the CBAM definitive period began; imports subject to the Regulation’s definitive-regime obligations from this date fall within the 2026 compliance year.
  • April 2026: the Commission’s CBAM verification timeline states that National Accreditation Bodies begin CBAM accreditation.
  • 24 July 2026: the Commission published a state-of-play note on CBAM accreditation.
  • 24 August 2026: the Commission published the verification and accreditation guidance and the CBAM Registry access procedure.
  • 1 September 2026: verifiers can obtain access to the CBAM Registry; a verifier must register within two months of receiving its CBAM accreditation, and in no case before this date.
  • January 2027: verifiers begin issuing verification reports in the CBAM Registry, allowing declarants to complete declarations with verified actual emissions.
  • 1 February 2027: authorised CBAM declarants can begin purchasing CBAM certificates.
  • 30 September 2027: the first annual CBAM declaration is due, covering 2026 imports, after Regulation (EU) 2025/2083 moved the deadline from 31 May.

What the guidance actually settles

The guidance is explanatory. It restates, in plain language, requirements that already sit in the CBAM Regulation and the relevant 2025 implementing and delegated acts, with a focus on verifiers who check the emissions reports of installations outside the EU. It creates no fresh obligation and moves no deadline. The duty to have emissions verified comes from Article 8 of Regulation (EU) 2023/956, which requires the declarant to ensure that total embedded emissions declared on actual values are verified by an accredited verifier against the principles in Annex VI to that Regulation.

Three acts adopted in late 2025 give that framework its operational detail. Commission Implementing Regulation (EU) 2025/2546 of 10 December 2025 sets out the principles for verifying declared embedded emissions, including the risk-based method a verifier follows, the materiality threshold it applies, and the prescribed content of the verification report. Commission Delegated Regulation (EU) 2025/2551 supplements the Regulation on accreditation of verifiers. Commission Implementing Regulation (EU) 2025/2547 sets the methods for calculating the embedded emissions the verifier is checking. The guidance summarises these instruments; it does not reproduce them, which is where teams reading the guidance alone lose the detail.

How a verifier becomes accredited

Accreditation is the first gate, and it runs through the national accreditation system rather than through the Commission. Under Article 18 of the CBAM Regulation, verifiers are accredited by a National Accreditation Body appointed under Regulation (EC) No 765/2008, the same accreditation infrastructure the EU already uses for conformity assessment. A verifier established under the law of a Member State normally applies to that Member State’s National Accreditation Body. Article 3(1) of Delegated Regulation (EU) 2025/2551 permits application to another Member State’s NAB in specified cases, including where the home Member State has not established a NAB and has not had recourse to another Member State’s NAB, where the home NAB does not perform the relevant CBAM accreditation, or where it has not successfully undergone peer evaluation for the activity groups sought. An applicant not established under the law of a Member State may apply to any Member State NAB that provides CBAM accreditation. The NAB also performs ongoing surveillance of the verifiers it has accredited.

Accreditation is granted for one or more of the CBAM activity groups listed in Annex I to Delegated Regulation (EU) 2025/2551, rather than simply by the six headline CBAM sectors. The scope comprises groups I to VIII for specified aggregated goods categories plus L for carbon capture, utilisation and storage, LI for imported electricity and LII for indirect emissions, and a verifier may issue verification reports only within its accredited scope. One verifier does not automatically span every sector an importer sources from.

The point most easily misread concerns verifiers already active under the EU Emissions Trading System. Being accredited for an activity group under EU ETS Implementing Regulation (EU) 2018/2067 does not make a verifier accredited for CBAM. Article 18(2) of Regulation (EU) 2023/956 requires the NAB to take relevant EU ETS accreditation into account. Article 4 and Annex I of Delegated Regulation (EU) 2025/2551 allow an applicant accredited under Implementing Regulation (EU) 2018/2067 to seek an extension of scope to the corresponding CBAM activity groups and provide the mapping between those scopes. That pathway is streamlined, and it still needs an application and a decision by the NAB.

Accreditation and Registry access are separate gates

Accreditation lets a verifier work; it does not by itself put the verifier into the system where reports are filed. The Commission’s separate access procedure, published alongside the guidance, sets out how an accredited verifier obtains access to the CBAM Registry from 1 September 2026 and how roles split between verifiers, accreditation bodies, the Commission and National Competent Authorities. Accreditation by the NAB comes first, then the verifier applies for Registry access, and the National Competent Authority grants that access only after confirming the verifier is duly accredited.

The two-month registration window matters for anyone tracking whether a chosen verifier will actually be usable. A verifier must register in the CBAM Registry within two months of receiving its CBAM accreditation, and never before 1 September 2026. A verifier accredited in, say, May 2026 therefore still waits for the September window before it can register.

What this changes for importers and declarants

The verification obligation lands on the authorised CBAM declarant, even though the emissions data and its verification originate at the third-country installation. Article 8 makes the declarant responsible for ensuring declared actual emissions are verified, so a declarant that wants to report actual values has to be sure the installation operator has engaged an accredited verifier and that a verification report will exist in time. Where that chain is absent, the fallback is the Commission’s default values, available in the circumstances the CBAM rules define, and default values can carry a higher implied emissions figure.

This is where calculation and verification meet. The verifier checks emissions monitored under Article 7 of the CBAM Regulation and calculated under Implementing Regulation (EU) 2025/2547, so a declarant relying on a supplier’s data has an interest in that data being monitored to the prescribed method from the start of 2026. Our guide to how embedded and indirect emissions are calculated covers what the verifier is testing, and for firms still confirming which goods are caught, the Commission’s proposed extension of CBAM scope to downstream goods remains under the legislative process and does not yet change which product codes require verified data.

My reading is that the binding constraint for the 2026 compliance year is timing rather than availability of verifiers. Accreditation opened in April 2026 and registration in September 2026, leaving a narrow window before verification reports are expected from January 2027. A declarant that has not yet identified an accredited verifier for each of its activity groups is the one most exposed when the 30 September 2027 declaration date arrives.

Frequently Asked Questions

Does every CBAM importer need an accredited verifier?

Only where the declaration reports actual embedded emissions. A declarant using the Commission’s default values in the circumstances the CBAM rules allow does not itself commission verification. Once a declarant claims actual values, Article 8 requires those values to be verified by an accredited verifier against the Annex VI principles.

Can a verifier accredited under the EU ETS start CBAM verification straight away?

No. An EU ETS accreditation under Implementing Regulation (EU) 2018/2067 is taken into account by the National Accreditation Body under Delegated Regulation (EU) 2025/2551, but the verifier still applies to extend its scope to the relevant CBAM activity groups and then registers in the CBAM Registry before it can issue CBAM verification reports.

Which body accredits a verifier based outside the EU?

A verifier established in a third country requests accreditation from an EU National Accreditation Body that offers CBAM accreditation. Accreditation under CBAM is anchored in Regulation (EC) No 765/2008, an EU and EEA framework, so there is no separate third-country accreditation route inside the mechanism itself.

What happens if no verification report exists by the declaration deadline?

The declarant cannot report those emissions as verified actual values and would rely on default values for the goods concerned. Default values are designed conservatively, and prescribed mark-ups apply to specified goods; depending on the product and installation, relying on default values may result in a higher certificate liability than verified actual emissions.

Key Takeaways

  • The 24 August 2026 guidance explains CBAM verification and accreditation for verifiers and National Accreditation Bodies; it clarifies existing rules and adds no obligation.
  • Verified actual embedded emissions are required under Article 8 of Regulation (EU) 2023/956 whenever a declarant reports actual values; the principles sit in Annex VI and in Implementing Regulation (EU) 2025/2546.
  • Accreditation runs through National Accreditation Bodies under Regulation (EC) No 765/2008, is granted per activity group (Annex I to Delegated Regulation (EU) 2025/2551), and the Commission’s timeline places NAB accreditation activity starting April 2026.
  • An EU ETS verifier under Implementing Regulation (EU) 2018/2067 extends its scope to CBAM under Delegated Regulation (EU) 2025/2551; it is not accredited for CBAM by default.
  • Verifiers access the CBAM Registry from 1 September 2026 and must register within two months of accreditation; verification reports are expected from January 2027.
  • The first annual CBAM declaration is due 30 September 2027 for 2026 imports, with certificate purchases opening 1 February 2027, under Regulation (EU) 2025/2083.

Sources and References

What to confirm before the 2027 declaration

The task the guidance leaves on a declarant’s desk is concrete. For each activity group it imports, it needs a verifier that is accredited by a National Accreditation Body, registered in the CBAM Registry from the September 2026 window, and able to issue a verification report from January 2027 for the actual emissions it wants to declare. Where that verifier is not yet identified, default values remain the fallback until a report exists, and the working date to plan against is 30 September 2027.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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