Guidance on CBAM verification and accreditation for verifiers and National Accreditation Bodies

Guidance on CBAM verification and accreditation for verifiers and National Accreditation Bodies / 24 August 2026

ID 27001 | 01.09.2026 / Attached

This document aims to support stakeholders by explaining the requirements of the CBAM Regulation in a simple, non-legislative, language. This guidance focuses on the requirements for third-party verifiers who intend to verify emission reports of operators of installations producing CBAM goods outside of the EU for the definitive period, from 1 January 2026 onwards.

It also explains the requirements for national accreditation bodies who perform accreditation and surveillance of these verifiers.

1.1. Legal context

The Carbon Border Adjustment Mechanism (CBAM) is an environmental policy instrument designed to mitigate the risk of carbon leakage for installations under the EU Emission Trading System (EU ETS). Its legal basis is the “CBAM Regulation” (Regulation (EU) 2023/956).

In order to reflect the carbon price faced by EU operators as closely as possible, the implementing legislation of the CBAM follows very closely the rules for MRV (Monitoring, Reporting and Verification) of the EU ETS:

- The rules for monitoring of emissions, calculating the embedded emissions of CBAM goods and for reporting these emissions to importers of these goods are laid down in an implementing act pursuant to Article 7 of the CBAM Regulation, the “Methodology Act” (Regulation (EU) 2025/2547).

The rules build on the “MRR” (Monitoring and Reporting Regulation) of the EU ETS with regards to installation-level emissions. For determining embedded emissions of goods, also elements of the “FAR” (Free Allocation Rules Regulation) for the EU ETS are taken into account. Compared to the EU ETS, the methodology is extended by including embedded emissions of “precursors”, which is inspired by the approach to the Carbon Footprint of Products (CFP).

- An implementing act (pursuant to Article 8 of the CBAM Regulation) provides verification principles and the content of the verification report. That implementing act is called the “Verification Principles Act” (Regulation (EU) 2025/2546) throughout this guidance document.

- Furthermore, a delegated act (pursuant to Article 18 of the CBAM Regulation) contains the rules on accreditation of verifiers and requirements for verifiers. The delegated act is referred to in this document as the “Accreditation and Verification Requirements Delegated Act” (“AVR-DA”, Regulation (EU) 2025/2551). Both the Verification Principles act and the AVR-DA mirror the respective provisions of the EU ETS as laid down in the “AVR” (Accreditation and Verification Regulation). Verifiers furthermore need to understand the rules for calculating the “free allocation adjustment”, which have been put in place pursuant to Article 31 of the CBAM Regulation, in the “Free Allocation Adjustment Act” (Implementing Regulation (EU) 2025/2620).
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