Verification under CBAM – Key learnings and guidance for effective preparation (Part 2)

Using actual CBAM data can substantially reduce CBAM‑related costs for importers. However, essential data points — such as direct specific embedded emissions or specific embedded free allocation — must be available in verified form to be eligible for use in a CBAM declaration.

In this series (find part 1 here) we cover the key processes and requirements for verification under CBAM along with our experiences in preparing CBAM declarants, suppliers and non-EU producers. This second part provides guidance on how operators of installation can prepare for verification under CBAM.

Preparation for verification: Requirements

During the transitional period of the CBAM implementation (2023-2025), operators of installations in third countries were able to provide CBAM data to their EU-based customers through the official CBAM communication template for installations (the EU Commission is currently working on an updated version), the O3CI-portal of the CBAM registry (verification reports will only be issued here) or other means such as the carboneer developed EFDA template. While all such documentation of calculated CBAM data is considered an emissions report under the CBAM framework, it only represents the final output of a complete CBAM data monitoring, collection and calculation processe.

From the start of the definitive period of CBAM on 1 January 2026, any CBAM data for the calendar year 2026 intended for verification must be substantiated. Operators thus require a structured and compliant approach to data monitoring and calculation (see Figure 1), including:

• Developing a monitoring plan and implementing the described methods and procedures in accordance with the monitoring and calculation rules in Implementing Regulation 2025/2547,

• Preparing an emissions report incorporating relevant data from precursor suppliers and the operator’s own production processes, resulting in the final calculated CBAM data,

• Compiling documentation and evidence supporting reported information from internal and/or external sources.

The missing foundation: The monitoring plan

Without a monitoring plan that describes and documents the systems and methods for generating CBAM relevant data at the installation level, verification cannot take place. Such monitoring system must conform to the new calculation rules under Implementing Regulations 2025/2547, 2025/2620 (free allocation adjustment) and 2025/2621 (default emissions values). Specifically, the monitoring plan must be prepared in English and include among other elements:

• Description and diagram of the installation defining production processes, products and the system boundary,

• List and description of emissions sources and activity data, calculation rules and precursors information,

• Description of data management, control procedures and quality systems that ensure reliable and accurate CBAM data.

According to current information from the EU Commission, no official monitoring plan template will be provided. Instead, operators of installations in third countries must therefore design and implement installation-specific monitoring plans and systems themselves. At carboneer, we have developed a monitoring plan template aligned with the up-to-date CBAM calculation rules and requirements to support our work with producers of CBAM goods worldwide (see excerpts in Figure 2).

Figure 2: Excerpts of the carboneer CBAM monitoring plan template (source: carboneer)

CBAM preparedness: Insights from practical experience

Working on CBAM data calculation over the past years, we have repeatedly observed that many producers are insufficiently prepared for the regulatory and methodological complexity of CBAM‑specific rules. The increased use of the CBAM communication template or carboneer’s EFDA template has improved the availability of basic emissions and activity data. However, the plausibility and internal consistency of that data often remain weak or even dubious. Common issues include:

• Fragmented data sets

• Inconsistent or incompatible units

• Unexplained changes over time and wrong monitoring periods

• Missing or incomplete underlying monitoring systems

While forthcoming EU guidance documents and webinars may clarify certain aspects and expectations, they will not replace the need for producers to establish robust inhouse monitoring systems to become “verification ready”.

A fundamental challenge is that many producers still lack formal CBAM monitoring plans and documented data‑collection procedures, which are essential prerequisites for any meaningful third‑party verification. In absence of clear descriptions of system boundaries, allocation rules, and data sources, verifiers cannot reliably assess whether reported values are complete and accurate. Such shortcomings might result in negative verification statement or a prolonged verification process with potential implications for availability of verified data for the CBAM declaration deadline on 30 September 2027.

Beyond structural issues, we frequently notice that producers either do not calculate all required CBAM data points under the new CBAM calculation rules or are lulled into complacency by relying on outsourcing crucial CBAM-related tasks. Critical data points such as specific embedded free allocations (SEFA) are often missing, misinterpreted, or calculated using inconsistent assumptions. Likewise, many operators lack actual CBAM‑compliant data from their precursor suppliers and therefore depend on default factors or rough estimates. These gaps can result in financial risk and reputational exposure, as EU importers rely on this information in their commercial decision-making already now.

Turning CBAM data into competitive advantage: Step-by-step guidance

During support for importers and producers, our projects on CBAM verification preparation typically follow a structured sequence of phases (see Figure 3):

1. CBAM gap assessment: Identification of methodological weaknesses, data gaps, and potential risk analysis
2. Development of monitoring plan: Establishing a systematic and installation-specific approach to data collection
3. CBAM data calculation: Implementation of the monitoring plan, collection of primary data, and calculation of embedded emissions and embedded free allocations
4. Workshops and trainings for staff: Building long-term CBAM capacity within the organisation to ensure inhouse data collection, calculation and verification readiness

Figure 3: Step-by-step project structure for CBAM verification preparation by carboneer (source: carboneer)

Through early identification of data gaps, streamlined data collection, and implementation of scalable processes, suppliers and importers can thus ensure that their processes are aligned with CBAM methodology and verification standards.

Preparing for CBAM verification during 2026 will be crucial for importers and producers — particularly where commercial viability of products may be at risks if importers are forced to revert to high default values.