Who must be on a UK CBAM verification team?

HM Revenue and Customs (HMRC) policy on the UK Carbon Border Adjustment Mechanism (CBAM) says the team has at least a lead auditor, plus as many auditors and technical experts as the job needs. A separate independent reviewer, who is not on the team, reviews the verification work and the verification opinion.

Who is on the team

• At least one lead auditor.
• An appropriate number of auditors and technical experts for your plant and goods.
• Competent people: the verifier must have processes to ensure the competence of everyone it appoints.

The independent reviewer

The verifier must also appoint an independent reviewer who is not part of the verification team. That person reviews the verification activities and the verification opinion. You will not usually meet the reviewer, but the opinion on your emissions data does not leave the verifier without that second look.

What happens before the team shows up

1. You give the verifier information about your production processes, including any precursor goods, and the monitoring arrangements you have in place.
2. The verifier runs strategic and risk analyses and prepares a verification plan.
3. To carry out the plan it appoints the team and the independent reviewer.
4. The team checks your data is accurate and the right methods were followed, checks any actual precursor data was itself verified, and checks any default values used are the correct ones.
5. A physical site visit happens at one or more suitable points in the monitoring period, with exceptions set in the force of law notices.
6. Misstatements are material at 5% of the good's emissions intensity, alone or added together, and the verifier raises them with you so you can fix them.

What Senseible does here

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. Senseible's own check is not that verification.

• What a UK verifier asks your plant for
• UK verifier site visit rules
• Can a consultant also verify
• CBAM suite

Sources: HM Government, Carbon Border Adjustment Mechanism (CBAM) policy summary, verification activities

Last reviewed 2026-11-04. UK CBAM rules are still being finalised ahead of 2027; re-check the policy summary and the force of law notices for changes.