What should an Indian plant's UK CBAM verifier contract say about extra time?

The technical guide from HM Revenue and Customs (HMRC) says a verifier should make sure its contract lets it charge time beyond the agreed time when the work needs it, for example when data flows are more complex than expected or errors are found. You may see that clause in a UK Carbon Border Adjustment Mechanism (CBAM) quote.

What sets the verifier's time

• The complexity of your installation.
• The complexity of your monitoring plan and its procedures.
• The materiality level.
• How complex and complete your data flow system is.
• Where the information and data behind your calculated emissions are kept.

The clause HMRC tells verifiers to include

The guide says the verifier should ensure the contract provides for time to be charged in addition to the agreed time where more is found to be needed for the strategic analysis, risk analysis or other verification activities. At least two situations should be covered.

First, where your data flow activities, control activities or logistics turn out to be more than first expected. Second, where the verifier finds misstatements, non-conformities, insufficient data or errors in your data sets.

What that means for you

• Our reading: a clear monitoring plan, one data flow diagram and a single reconciled workbook are the plant's side of avoiding extra time.
• Ask what the quote assumes about the number of production processes and site locations, so you can see what would trigger extra time.
• Before it starts, the guide says the verifier should assess whether it can finish within the specified timeframe and whether any conflict of interest exists. It also says the verifier should record the time allocated in its internal verification documentation.

Example: how a quote can grow

• Quote assumes one production process and one meter room: 6 verifier days
• The verifier finds meter readings typed twice into two workbooks and one fuel analysis missing
• Extra time under the clause: 2 days. Total: 6 + 2 = 8 days

The days are an example; HMRC gives no standard number of days.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. Senseible does not act as the verifier. It builds the verifier-ready file from your bills; an accredited verifier signs it off.

• Errors verifiers look for
• What the verifier asks a plant
• Verification team members
• UK CBAM for Indian exporters

Sources: HMRC, Carbon Border Adjustment Mechanism (CBAM): technical guide for monitoring, reporting and verification

Last reviewed 2026-11-06. Read from technical guide sections F6.7 and F6.7.1 on 6 November 2026. HMRC is taking feedback on the guide until 13 November 2026 and may change it before 1 January 2027.