Senseible

Do I have to update my CBAM monitoring plan every time the plant changes?

Only significant changes force an update, and you must make it without undue delay. Minor changes can go into a change log shared at the next verification. The Commission still advises asking the verifier early, because a wrong method can create material misstatements. Review the plan at least once a year anyway.

Three levels of change

What the guidance recommends

The yearly review

Review the plan at least once a year and whenever the plant changes significantly. Record every change, and keep it objectively justifiable. Check each year whether a more accurate data source has become available; if so, put it in the plan and use it from the earliest date possible.

Records

Keep monitoring records and supporting documents for at least six years after the reporting period. The transitional period rule was four years.

What Senseible does here

Senseible reads fuel bills, electricity bills and purchase invoices into dated, fingerprinted records, so the source documents your plan points to are easy to find. It does not write your monitoring plan or file anything in the CBAM Registry.

Sources: European Commission, CBAM Guidance No. 3, methods for calculating embedded emissions (14 August 2026), sections 4.5.2 and 4.5.7, and Table 2-1 on the data retention period

Last reviewed 2026-10-25.