Can the same CBAM lead auditor verify our plant every year?
For five consecutive years at most. After a lead auditor has verified the same installation five years running, the CBAM accreditation rules require a three-year break from that installation. You can keep the same verification firm; the person leading the team changes. A lead auditor who verified your 2026 to 2030 reports can return for 2034.
The rule
Section 1.7.6 of Annex II to the CBAM accreditation and verification rules makes the lead auditor rotate after five consecutive years on the same installation, followed by three consecutive years away from it. It is a person rule, not a firm rule. Nothing in it stops you using the same verification firm for ten years.
Your timeline, in the Commission's own example
- 2026 report, verified in 2027: year one for lead auditor A.
- 2027, 2028 and 2029 reports: years two to four.
- 2030 report, verified in 2031: year five, the last one allowed.
- 2031, 2032 and 2033 reports: a different lead auditor.
- 2034 report, verified in 2035: lead auditor A may come back.
If the firm rotates earlier
A verifier may change lead auditors sooner: someone leaves, falls ill, or its own impartiality checks call for it. The five-year rule then does not apply, but a break still does. The firm sets its length in its own impartiality procedures, and its accreditation body checks them.
Small firms with two lead auditors
They can swap between themselves. The guidance allows a lead auditor to rotate with the independent reviewer, even one who has reviewed your installation for five consecutive years, as long as the firm manages the familiarity risk. A CBAM auditor cannot step up as your lead unless they have become a qualified lead auditor.
What the change costs you
A new lead auditor knows your plant less well and needs time to learn your processes and risks, so year six can run longer than year five. The verifier's internal file is supposed to carry a clear record of past issues and decisions for exactly this handover. Help it along on your side: keep the monitoring plan current, log every change with its date, and keep last year's findings with how you closed each one.
What Senseible does here
A handover is easier when the evidence does not live in one person's head. Senseible keeps each figure in your CBAM file tied to its source record, so a new lead auditor can trace it from the first day. 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
- Who is on a CBAM verification team
- Changing verifiers for a voluntary inventory
- Updating the plan after plant changes
Last reviewed 2026-11-03.