Senseible

How does a CBAM verifier test our fuel invoices and purchase records?

By picking samples and following them from the invoice to the emissions report and back. The rules name five tests: trace to the primary source, cross-check with other records, reconcile, check thresholds and recalculate. The verifier also walks through your purchase, stock and fuel systems and tests who checks the data before it moves on.

The five tests, at a coal-fired plant

The systems the verifier walks through

Why invoices in accounts payable carry weight

The Commission's guidance says trend and ratio checks work best on data from well-controlled sources. Its example: fuel quantities on invoices entered into accounts payable the same way as every other invoice line. Coal that is invoiced, received, booked and paid through one controlled process is easier to trust than a tonnage typed into a spreadsheet by the boiler house.

Controls the verifier tests, not just figures

Method points that trip plants up

The coal reconciliation a verifier reruns

Example tonnages. Which figure is used for emissions depends on what your monitoring plan names as the primary source.

What Senseible does here

Senseible reads each coal, gas and power invoice into a dated record tied to the original file. Before the verifier arrives, Senseible's in-house review in its CBAM Suite checks fuel quantities against purchases and stock changes, and every figure carries its formula so it can be rerun; the sign-off stays with an accredited verifier, Senseible's partner or yours.

Sources: European Commission, Guidance on CBAM verification and accreditation (24 August 2026), sections 4.7.1 to 4.7.4 and 4.8, quoting section 2.9 of Annex II to the CBAM accreditation and verification act

Last reviewed 2026-10-30.