Can a UK ETS verifier extend its accreditation to the UK CBAM?

Yes. HMRC's UK CBAM technical guidance lets a verifier already accredited for the UK ETS apply to extend its scope of accreditation to the UK CBAM. The accreditation body treats each CBAM activity group as equal to set UK ETS groups; iron or steel and aluminium products (group VIII) match ETS groups 1a, 1b, 4 and 98.

How the CBAM groups line up with UK ETS groups

• I, calcined clay, cement clinker, cement, aluminous cement: ETS groups 1a, 1b, 6, 98.
• II, hydrogen, ammonia: 1a, 1b, 8, 98.
• III, nitric acid: 1a, 1b, 9, 98.
• IV, urea, mixed fertilisers: 1a, 1b, 98.
• V, sintered ore, pig iron, DRI, crude steel: 1a, 1b, 3, 98.
• VI, ferro alloys (FeMn, FeCr, FeNi): 1a, 1b, 4, 98.
• VII, unwrought aluminium: 1a, 1b, 4, 5, 98.
• VIII, iron or steel products, aluminium products: 1a, 1b, 4, 98.

What the extension still involves

The verifier applies under its existing UK ETS accreditation, granted under Implementing Regulation (EU) 2018/2067 as it forms part of UK law. The accreditation body still assesses the application and grants CBAM accreditation only when satisfied the verifier meets the UK CBAM rules. There is no fixed time for that assessment, so a verifier that has applied is not yet accredited.

Before you sign a verifier

1. Ask for its UK CBAM accreditation, not only its UK ETS one.
2. Check the CBAM activity group on it matches your product. A rolling mill selling bars needs group VIII; if you also make crude steel, group V too.
3. Ask which accreditation body granted it. HMRC requires a full member of the Global Accreditation Cooperation.

A forging unit that also melts

• Products shipped to the UK: steel forgings, made from ingots melted in your own induction furnace.
• Forgings are iron or steel products: CBAM group VIII.
• Your own melting makes crude steel: CBAM group V.
• A verifier accredited only for group VIII is not accredited for the melt shop. Ask for both groups in one engagement.

Group assignment follows HMRC's table; confirm your goods against the System Boundaries Document.

What Senseible does here

Senseible builds a per-product figure from your fuel and input invoices, ready for whichever verifier you appoint. 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.

• Who can verify an Indian plant
• CBAM Suite

Sources: HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026), HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026)

Last reviewed 2026-11-03.