Our UK CBAM verifier noted small non-conformities last year. Will they check them again?
Yes. HMRC's technical guidance says the verifier must check whether non-conformities from the previous monitoring period were corrected, even non-material ones. If they were not, and that raises the risk of material misstatement so far that it cannot conclude with reasonable assurance, it must reflect that in its opinion. The outcome is recorded in the verification report.
What the verifier must do
- Assess whether each non-conformity identified for the previous monitoring period has been corrected, material or not.
- Where one was not, consider whether leaving it has increased the risk of misstatements, and whether those could be material.
- If that risk means it cannot conclude with reasonable assurance that your data is free of material misstatement, reflect it in the verification opinion.
- Document whether each was corrected, in the verification report and in its own working papers.
Last year's recommendations count too
If last year's report recommended improvements, the verifier must investigate how you addressed them. Where you took no action, it must assess the effect on misstatements and non-conformities. It can point out what to improve, but it must not advise you or help design your monitoring, to stay impartial.
How it can end
- Verified as satisfactory: free of material misstatement. Your importer can report the data.
- Verified as satisfactory with comments: free of material misstatement, but with uncorrected non-material issues or recommendations. Still reportable.
- Negative statement: uncorrected material misstatements or non-conformities, or not enough evidence for reasonable assurance. Your importer cannot report the data to HMRC.
Close them before the visit
Keep a findings log: each item from last year, what you changed, the date and the evidence. Update the monitoring plan where the fix changed a method. If you have changed verifier, give the new one last year's report; it will ask for it.
Example: a findings log for a steel plant
- Finding 1: diesel for DG sets missing from the monitoring plan. Fix: added as a source stream in plan version 2; purchase invoices filed by month
- Finding 2: weighbridge calibration certificate expired. Fix: recalibrated; new certificate filed
- Recommendation: second person to check the monthly fuel spreadsheet. Fix: sign-off column added from April
Findings shown are examples of the kind a verifier records.
What Senseible does here
Senseible ties every fuel and electricity figure to its invoice or bill, so any figure the verifier samples leads straight to its document. 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.
- CBAM report from your records
- What the verifier asks the plant
- Spreadsheet errors verifiers check
- The 5% materiality level
Last reviewed 2026-11-03. HMRC is taking feedback on this guidance until 13 November 2026 and may update it before 1 January 2027.