Our verifier is EU ETS accredited. Is it automatically a CBAM verifier?
No. An EU ETS accreditation does not let a firm sign CBAM verification reports. Article 4 of the CBAM accreditation rules treats CBAM as an extension of scope of the firm's ETS accreditation, so it skips a full new accreditation, but an EU accreditation body must still grant the CBAM activity group covering your goods.
What the ETS accreditation gives the firm
A shorter route, not a pass. The Commission publishes a table showing which EU ETS scopes count towards each CBAM activity group, and the accreditation body uses it to simplify the assessment. A new CBAM accreditation normally takes 6 to 12 months, and an existing ETS accreditation is one of the things that shortens it.
Two CBAM groups have no ETS equivalent at all: LI, electricity imported into the EU, and LII, indirect emissions. A cement or fertiliser verifier needs LII, and there its ETS record gives it nothing to lean on.
- I, cement and clinker: ETS groups 1a, 1b, 6, 98.
- II, hydrogen and ammonia: 1a, 1b, 8, 98.
- III, nitric acid: 1a, 1b, 9, 98.
- IV, urea and mixed fertilisers: 1a, 1b, 98.
- V, sinter, pig iron, DRI, crude steel: 1a, 1b, 3, 98.
- VI, ferro-alloys: 1a, 1b, 4, 98.
- VII, unwrought aluminium: 1a, 1b, 4, 5, 98.
- VIII, iron, steel and aluminium products: 1a, 1b, 4, 98.
Work an ETS verifier has never had to do
In the EU ETS a government authority approves the monitoring plan and the verifier checks the plant followed it. Under CBAM that split is not possible, so the verifier assesses the plan itself, usually as part of the verification. The Commission lists skills an ETS verifier must add before it can verify for CBAM:
- Assessing a monitoring plan: installation and process boundaries, monitoring approaches, uncertainty assessments, and whether each data source is the best available.
- Indirect emissions on actual values: reading smart meter data, single line diagrams and power purchase agreements.
- Precursor origin and production year, traced through orders, delivery notes, invoices and stock estimates.
- Relying on other verifiers: checking that a supplier's verifier was accredited for the right sector when it signed.
Three things to see before you sign
- The CBAM accreditation certificate itself, not the ETS one, issued by an EU national accreditation body.
- The CBAM activity group for your goods on that certificate, plus LII if your goods count indirect emissions.
- Proof the firm is registered in the CBAM Registry, without which it cannot issue your report.
Example: a sponge iron and billet plant with a rolling mill
- Goods: DRI and crude steel billets (group V), plus rolled bars (group VIII)
- Verifier's ETS certificate shows 1a and 1b only
- Group V can draw on ETS 1a, 1b, 3 and 98: two of the four are on the certificate
- Group VIII can draw on ETS 1a, 1b, 4 and 98: again two of the four
- So only part of the ETS accreditation can be taken into account for either group
- Either way, the firm can verify this plant only once its CBAM certificate lists V and VIII
The certificate contents are an example. Check the real certificate against the Commission's correspondence table.
What Senseible does here
Senseible does not accredit or vet verifiers. What it does is prepare the operator file a CBAM verifier works from, with each figure linked to its source record. 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
- CBAM verifier scopes by sector
- Who approves a CBAM monitoring plan
- Why registration comes before the report
Last reviewed 2026-11-03.