What is the difference between a misstatement and a non-conformity in CBAM verification?

A non-conformity is something you did differently from your monitoring plan or the Methodology Act, such as weighing fuel on a scale the plan does not list. A misstatement is a wrong number in your reported data, such as a typo or a formula error. One can cause the other, and you must correct both, whatever their size.

Non-conformity: the method broke the rules

The Verification Principles Act defines it as any act or omission by the operator that does not meet the monitoring plan or the Methodology Act. It covers a plan that breaks the Act, and a report or day-to-day monitoring that does not follow the plan. The Commission's examples:

• Fuel quantities taken from different instruments, or by other methods, than the plan lists.
• Emission factors other than those in the plan, used without justification.
• Meters not maintained or calibrated as the plan requires, or used outside the maker's specifications.
• A fuel in the emissions report that the plan does not list.
• A default value for the wrong country of origin.
• Actual figures for a precursor with no verification report from the plant that made it.

Misstatement: the number is wrong

The same Act defines a misstatement as an omission, misrepresentation or error in your reported data, leaving aside the normal uncertainty of meters and lab analyses. Typical ones: a typo when copying from the shift log to the spreadsheet, a broken formula, a missing day of readings, or the diesel factor applied to furnace oil.

When one becomes the other

If a non-conformity puts a wrong figure into your report, it is also a misstatement. Using the default value for the wrong country is a non-conformity in method, and the wrong figure it produces is a misstatement as well.

Material or not

Misstatements are material when, alone or added together, they exceed 5% of the specific embedded emissions per tonne for a good's CN code, or of its specific embedded free allocation. The verifier can also judge a smaller one material because of its nature. For both misstatements and non-conformities it weighs:

• Can it be corrected, and do you refuse to correct it?
• How likely is it to happen again, and how long has it gone on?
• Was it deliberate?
• Does it breach the Methodology Act itself?

Errors that cancel out still count

The verifier converts every error into emissions before adding them up, so a fuel error and a factor error are compared in the same unit. Where some errors overstate and others understate, it also adds them as absolute values, because a near-zero net can hide a report full of mistakes.

How they end up in your report

• Corrected during the verification: nothing left to report on that point. You are expected to correct every one, not only the large ones.
• Left open but not material: the statement can still be positive, listed as verified with comments, and you fix them before next year.
• Non-conformities left uncorrected year after year: can be escalated to material later.
• Material misstatements not corrected before the report is issued: a negative statement, and your buyers fall back to default values.

Two errors that nearly cancel, on a reported 2.000 t CO2e per tonne

• Error 1, furnace oil quantity overstated: +0.060 t CO2e per tonne
• Error 2, emission factor understated: minus 0.050 t CO2e per tonne
• Net: 0.060 minus 0.050 = 0.010, or 0.010 / 2.000 = 0.5%
• Absolute: 0.060 + 0.050 = 0.110, or 0.110 / 2.000 = 5.5%
• The net looks small; the absolute total shows the report holds sizeable errors, and both must be corrected

Example figures. The verifier decides materiality using both the 5% level and its own judgement.

What Senseible does here

Senseible ties each figure to its invoice, bill or log, so a misstatement can be traced to its source line and fixed during the verification rather than after it. 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 5% materiality level
• What the verification report contains
• If the statement is negative

Sources: European Commission, Guidance on CBAM verification and accreditation (24 August 2026), sections 4.15 (Table 6), 6.1, 6.2 and 6.4

Last reviewed 2026-10-31.