Can the consultant who wrote our monitoring plan verify it for the UK CBAM?
No. HMRC's guidance treats it as an unacceptable risk when the verifier, or anyone in the same legal entity, helped write the monitoring plan or procedures being verified, or built your monitoring system. That would mean verifying its own work. Use separate firms for advice and verification.
What rules a verifier out
- It, or its legal entity, gave consultancy on the CBAM monitoring plan and procedures under review.
- It gave technical help building or running the system used for CBAM monitoring and reporting.
- Common ownership, governance, management, staff, finance or contracts with your plant.
- It is your plant, owns it, or is owned by it.
Rotation rule
If one person has been lead auditor for the same installation for five years in a row with no other lead auditor, that person must take a three-year break from verifying it.
What cannot be outsourced
A verifier may use outside auditors or experts with your consent, but the independent review and the drafting and issuing of the verification report must stay with the accredited verifier.
What Senseible does here
Senseible is not a verifier and does not write your verification. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.
Sources: HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026)
Last reviewed 2026-11-02.