What is the materiality level in CBAM verification?
5% of the specific embedded emissions per tonne, for each good by CN code, and 5% of the specific embedded free allocation. Misstatements above that, alone or together, are material. Every misstatement found still has to be corrected; materiality is not a tolerance band.
How verifiers use it
- To plan how much data to sample.
- To judge whether the report can get a positive verification statement.
- For other parameters, the verifier uses expert judgement.
Smaller errors can still matter
A verifier can treat a smaller error as material for qualitative reasons, for example if it points to a weak control system.
What Senseible does here
Senseible keeps the invoices behind each fuel and electricity figure in one fingerprinted record, so a verifier can sample them without a hunt through files. Senseible is not a CBAM verifier and does not issue verification reports.
- Materiality in GHG verification
- Why a verifier will not quote a fixed fee
- Importer rejected emissions data
Sources: European Commission, guidance on CBAM verification and accreditation (24 August 2026)
Last reviewed 2026-10-23.