What must an Indian plant do so its UK buyer can use actual CBAM data?

Monitor your plant emissions for a full calendar year under HMRC's UK CBAM technical guidance, have them checked by an independent accredited verifier, then give your UK buyer the verification report or the summary for their product. Without that, the buyer must use HMRC's default values from 1 January 2027.

The three things HMRC expects

1. Monitor emissions for one calendar year, 1 January to 31 December, following the UK CBAM technical guidance.
2. Appoint an independent verifier accredited for UK CBAM. The verifier checks the data and writes a verification report, which can carry a summary for each CBAM good you make.
3. Send your UK buyer either the full verification report or the summary for the good they imported. The buyer keeps it as evidence for the actual figure on their CBAM tax return.

What happens if you do nothing

The UK importer is the one who pays. If you have not monitored to the UK rules, HMRC says the importer must use its default values. Defaults are the same for every country, so a cleaner plant gets no credit for being cleaner.

Your plant files nothing with HMRC

The technical guidance says an overseas operator is not required to report to HMRC. Your job ends at a verified emissions intensity, in tonnes of CO2e per tonne of product, handed to customers who need it.

Where to start this month

• List the products you ship to the UK by 8-digit commodity code.
• Collect a year of fuel, power, raw material and production records for each line.
• Write a monitoring plan before the year starts, so the verifier can follow how each number was made.

What Senseible does here

Senseible reads your fuel, power and freight invoices into dated records per site and builds embedded emissions by product. Its CBAM tools are built for the EU scheme, whose monitoring rules the UK broadly follows. 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 for Indian exporters
• Mixing defaults and actual data
• Documents a verifier needs

Sources: HMRC, Monitoring emissions as an overseas installation producing CBAM goods exported to the UK, HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026)

Last reviewed 2026-11-02.