Preparing for CBAM verification
What is CBAM verification and why does it matter?
From 2026, the reported embedded emissions of products imported into the European Union market are subject to independent CBAM verification. Its purpose is for the verifier to confirm, with reasonable assurance, that the reported specific embedded emissions of goods produced at the operator (producer) installation — which the EU importer declares in the CBAM declaration for 2026 — were determined in line with the CBAM regulations, and to issue a corresponding verification opinion.
CBAM verification of an installation operator embedded emissions is carried out by an independent accredited verifier — a legal entity accredited by the national accreditation body of an EU member state. Verification covers the specific embedded emissions of products reported for the 2026 reporting period. The first verified data is used for the annual CBAM declaration, which the authorised CBAM declarant submits by 30 September 2027.
The road to CBAM verification — key phases
The installation operator annual cycle for the 2026 reporting year.
Establishing and testing the CBAM MRV system
- Producing the Monitoring Plan
- Establishing data collection processes
- Testing calculations and internal controls
- Securing data traceability and quality
Annual emissions calculation for 2026 and the OER
- Collecting and consolidating 2026 data
- Calculating embedded emissions under the applicable methodology
- Producing the OER in line with CBAM requirements
Verification of embedded emissions and the OER
- Independent verification by an accredited verifier
- Review of data, methods and systems (OER and MRV)
- Issuing the verification report
O3CI / CBAM Registry and delivery of data to buyers
- Entering and sharing verified data through O3CI / CBAM Registry
- Delivering verified data to EU buyers and authorised CBAM declarants
The CBAM regulations and verification rules require the verifier to gather sufficient appropriate evidence to conclude, with reasonable assurance, that the reported embedded emissions are free from material misstatement and were determined in line with the CBAM methodology.
To that end the verifier examines not only the embedded emissions calculation but also the Monitoring Plan, allocation rules, activity monitoring, data management, data traceability, the application of emission factors, data quality control, the assessment of the risk of material misstatement, and other documentation and evidence forming the basis for calculating embedded emissions.
If a producer actual embedded emissions are not verified, or are not accepted in the verification procedure, the EU importer will not be able to use them in the CBAM declaration. In that case the CBAM obligation will be calculated under the rules on applying available or default values, which may lead to a greater number of CBAM certificates and higher costs of acquiring them. In commercial practice such additional costs are expected to be built into the commercial terms between the EU importer and the producer, meaning the producer bears the economic consequences of being unable to prove its actual embedded emissions.
How do you prepare for the CBAM verification procedure?
Preparing for CBAM verification means establishing a verifiable system for activity monitoring, data management and calculation of embedded emissions. In practice it consists of the following steps:
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CBAM GAP analysis
analysis of the existing data system, identification of gaps against CBAM verification requirements, and preparation of an improvement plan
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Creating the Monitoring Plan
defining the monitoring methodology, data sources, responsibilities and controls as the basis for establishing the CBAM system
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CBAM system modelling
defining system boundaries, allocation rules, activity monitoring and the methodology for calculating embedded emissions
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Implementing the monitoring system
establishing activity monitoring, data management and documentation in line with the Monitoring Plan
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Establishing traceability and the audit trail
ensuring provable traceability of data, precursors, emission factors and embedded emissions calculations
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Data quality control
identification of non-conformities, assessment of the risk of material misstatement, and definition of measures to improve the system
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Test calculation and CBAM reporting
calculation of specific embedded emissions, preparation of test CBAM reports and documentation for the verification procedure
How does IntCO2 support preparing for CBAM verification?
IntCO2 is CBAM software designed as a verifiable CBAM Data Management System that supports every key activity needed to prepare for and carry out CBAM verification — from analysing the existing system and creating the Monitoring Plan through to automated calculation of embedded emissions, CBAM reporting and support for the verifier during the verification procedure.
| Activity | IntCO2 support |
|---|---|
| CBAM GAP analysis | Identification of gaps in the existing data system and documentation against CBAM verification requirements. |
| Creating the Monitoring Plan | Expert support in producing the Monitoring Plan in line with CBAM regulations and verification principles. |
| CBAM system modelling | Digital modelling of system boundaries, allocations, activity monitoring, the supply chain and the calculation methodology. |
| Implementing the monitoring system | Automated collection, validation and management of data and documentation. |
| Traceability and audit trail | Provable traceability of data, precursors, emission factors and calculations from procurement through to the CBAM report. |
| Data quality control | Automated data quality controls, identification of non-conformities and assessment of the risk of material misstatement. |
| CBAM reporting | Automated calculation of specific embedded emissions and production of OER and O3CI reports. |
| CBAM verification | A Verification Data Room giving the verifier controlled access to the complete CBAM system, including the Monitoring Plan, data, calculations, reports, audit trail and supporting evidence needed to carry out independent CBAM verification. |
Get ready for CBAM verification
Book a working session with our specialists. Based on your products, production processes, existing information systems and regulatory requirements, we will together define the optimal model for establishing a verifiable CBAM system. We present the implementation methodology and the IntCO2 platform functionality, and propose a solution adapted to your organisation.