Can a CBAM site visit go virtual because of a flood, curfew or travel ban?

It can, under Article 4 of the Verification Principles Act, if the event is serious, extraordinary, unforeseeable, outside your control and cannot be overcome with reasonable effort. The verifier's risk analysis must support the switch and it must still reach reasonable assurance. Unlike the ordinary virtual option, this can apply even to a first verification.

Two routes to a virtual visit

The ordinary route, Article 3 of the Verification Principles Act, needs a physical visit in the previous reporting period plus a simple, unchanged plant. A first verification can never use it. The force majeure route, Article 4, has its own shorter test and no requirement for an earlier physical visit. The Commission's Questions and Answers says the first site visit is always physical except in serious, extraordinary and unforeseeable circumstances.

The Article 4 test

1. Serious, extraordinary and unforeseeable circumstances, outside your control, stop the verifier visiting, and cannot be overcome after all reasonable efforts.
2. The verifier's decision rests on its risk analysis.
3. The verifier has taken the measures needed to bring verification risk down far enough to reach reasonable assurance that your report is free of material misstatements.

What the Commission counts

Its examples are pandemics, earthquakes, war, terrorism, and other natural or man-made disasters that close the installation to outsiders or make travel to the site impossible. It also says Russia's war against Ukraine would qualify.

A flood that cuts off your plant, or a curfew or travel ban that keeps the team out, can fit that pattern if it meets the test above. Something that happens on a calendar is harder to call unforeseeable. If the road floods every August, the reasonable effort is to fix the visit for another month.

The decision can be checked later

The verifier must record why it went virtual in its internal file and tell you. The Commission's Questions and Answers says the choice can be scrutinised afterwards by the accreditation body, and by the Commission and the national authority when they review your buyer's CBAM declaration. So expect the verifier to ask for proof: a district order, a closure notice, a cancelled flight.

How it runs, and what follows

• A video call plus documents sent electronically. Staff may be asked to walk to a meter or weighbridge and show its reading on camera.
• If the verifier cannot get enough evidence remotely, it has to consider a physical visit after all.
• A virtual visit is not a physical one. The ordinary virtual route next year needs a physical visit in the year before, so unless force majeure still applies, plan for the team on site next time.

What Senseible does here

A remote visit works only if every figure can be shown without walking the plant. Senseible keeps each line of your CBAM file tied to the bill or reading behind it, ready to share on screen. We build it from your records, check every figure in-house, and an accredited verifier we partner with signs it off. Have your own verifier? Send it to them.

• Prepare your CBAM file
• The ordinary virtual visit conditions
• What the verifier checks on site
• When to start CBAM verification

Sources: European Commission, Guidance on CBAM verification and accreditation (24 August 2026), section 4.9, European Commission, CBAM Questions and Answers (15 October 2026), questions 5.15 and 5.16

Last reviewed 2026-11-03.