Your first CBAM verification needs a site visit. Be ready for it.

To use your plant's real figure instead of the EU default, your EU buyer needs it verified. In the first year, the verifier comes to your plant, walks it against your monitoring plan, talks to your people and traces your numbers back to the meter.

What the verifier checks on site

• Weighbridge: The weighbridge in use, and today's slip against the register. Who they ask for: Weighbridge operator. Have ready: Slips for the last three months and the calibration certificate.
• Fuel yard: Every fuel and bought material on site: coal yard, oil tanks, gas line, LPG bank, billets or clinker. Who they ask for: Store keeper. Have ready: Delivery notes, purchase invoices and the stock register with opening and closing stock.
• Furnace and kiln: Each furnace, kiln, boiler and DG set against the process drawing in your monitoring plan. Lines making goods outside CBAM, and how their fuel and power are kept out. Who they ask for: Shift in-charge. Have ready: The monitoring plan, printed, with every change since it was written marked.
• Meter room: Energy and flow meters running, read against the logbook for the same moment. Power from a captive plant, steam shared with a neighbour. Who they ask for: Electrical in-charge. Have ready: Meter logbooks, calibration and maintenance records, and power bills.
• Lab: How fuel and product samples are taken and tested. Who they ask for: Lab chemist. Have ready: Sampling plan and lab reports for fuel carbon content or product composition.
• Records office: One figure traced from the meter reading or delivery note to the report. Who checks each entry, and who covers when they are on leave. Who they ask for: The accounts person who books fuel, and whoever compiles the emissions report. Have ready: Monthly fuel and power sheets, purchase and sales records, and access to your ERP or software.

Year one is always on site

• Visit every year: year 1 on site, year 2 on site, year 3 on site, year 4 on site. Always allowed, and what the verifier will do if your plant or plan changes.
• Video every other year: year 1 on site, year 2 video call, year 3 on site, year 4 video call. Video needs a physical visit the year before, a simple plant, and no big change since.
• Skip every third year: year 1 on site, year 2 on site, year 3 no visit, year 4 on site. Skipping needs physical visits in the two years before, on the same conditions.

A video call also stands in, any year, if something serious and outside your control stops the visit. What brings the verifier back on site:

• A production process or route started or closed
• A change in how the plant gets its energy
• Pipes, lines or connections added or removed between processes
• A change in bought-in materials, where you use their actual figures
• A new fuel, material or meter

Who can sign

• A CBAM verifier accredited by an EU accreditation body: Yes, if it is accredited for the group that covers your goods and registered in the CBAM Registry. Firms outside the EU, Indian ones included, can apply to an EU body that takes them.
• The firm that did your ISO 14064 verification: Not on that statement. The EU does not accept ISO 14064 for CBAM. The same firm can sign only once it holds CBAM accreditation.
• Your consultant or chartered accountant: No. They can help you get ready. Only an accredited CBAM verifier signs.
• Your EU buyer: No. Your plant hires the verifier. Your buyer only uses the report in its declaration.
• Senseible: We build it from your records, check every figure in-house, and an accredited verifier we partner with signs it off. Have your own verifier? Send it to them.

They pick a number and walk it back to the meter

1. Emissions report: Furnace oil burnt in March: 40,000 L
2. March fuel sheet: Opening 18,000 L + bought 36,000 L - closing 14,000 L = 40,000 L
3. Tank dip register: 1 March: 18,000 L. 31 March: 14,000 L
4. Delivery notes and invoices: 3 tankers of 12,000 L = 36,000 L
5. Calibration certificate: The dip scale and flow meter were checked in date

If the March sheet says 36,000 L, the invoices were booked as fuel burnt and the stock change is missing. That is the error a verifier finds. An error above 5% of the emissions per tonne of a good, alone or added to others, is material.

The site-visit checklist

24 things the verifier will ask for. Tick what you have on the page and download it as a one-page PDF for the team. No sign-up.

Papers to hand over

• Latest monitoring plan, with changes since it was written marked
• Plot plan and process drawing that match the plant today
• A record of changes to the plant and the plan
• Sampling plan, if you sample fuels or products
• The emissions report to be verified
• Verification reports for bought-in materials, or a note that you use EU default values
• How bought-in materials are split across production processes
• Electricity: grid, your own plant, or the supplier's verification report with the direct line or PPA papers
• A list of the software and files that hold your figures

Plant and meters

• A walk route past the fuel yard, tanks, furnaces, kilns, boilers and DG sets
• Connections in and out marked: captive power, shared steam, waste gas
• Lines making goods outside CBAM, and how their fuel and power are kept out
• Calibration and maintenance logs for weighbridges, flow meters and energy meters
• Lab reports for fuel carbon content or product composition
• Safety passes ready for the verification team

People on the day

• Shift in-charge
• Store keeper and weighbridge operator
• Lab chemist
• The accounts person who books fuel
• Whoever compiles the emissions report, and who covers when they are away

Records within reach

• Three months of delivery notes, invoices and meter logs
• Monthly fuel and power sheets with opening and closing stock
• Purchase and sales records, stock registers and ERP access
• Who checks each figure, written down

Work back from 30 September 2027

• Sep 2026: Accredited verifiers can register and start first verifications: papers, then the site visit.
• 31 Dec 2026: Your 2026 reporting year closes.
• Jan 2027: Verifiers can issue the first verification reports.
• 1 Feb 2027: Certificates go on sale to your buyer.
• Mid-Aug 2027: The Commission expects your buyer to want your verification report by now.
• 30 Sep 2027: Your buyer's first annual declaration, for everything imported in 2026.

The CBAM 2026 to 2027 calendar

Add these dates to your own calendar (.ics, with a reminder a week before each) or download them as a one-page PDF:

• 31 Dec 2026: Your 2026 CBAM reporting year closes. Verifiers can finish your 2026 verification once the full year's data is in, from January 2027.
• 1 Feb 2027: CBAM certificates go on sale. Your EU buyer can start buying certificates for goods imported in 2026.
• 31 Mar 2027: First quarterly CBAM certificate check. From 2027, your buyer must hold certificates for at least half the emissions in goods imported since 1 January, at the end of every quarter.
• 30 Jun 2027: Quarterly CBAM certificate check. Certificates for at least half the emissions imported since 1 January.
• 30 Sep 2027: First annual CBAM declaration and certificate surrender. Your buyer declares everything imported in 2026 and surrenders the certificates. It is also a quarterly certificate check.
• 31 Oct 2027: Last day to sell back extra CBAM certificates. Your buyer can ask to sell back certificates it bought but did not need.
• 31 Dec 2027: Quarterly CBAM certificate check, and your 2027 reporting year closes. Your buyer's last quarterly check of the year. Your 2027 data year ends, and its verification can finish from January 2028.

42 questions plant teams ask about the verifier

Who verifies, and when

• Do actual emissions in a CBAM declaration need to be verified?
• Who arranges and pays for CBAM verification: the Indian exporter or the EU importer?
• When should an Indian exporter start CBAM verification in the year?
• When will CBAM accredited verifiers be available?
• How do I find a CBAM accredited verifier?
• Which EU accreditation bodies accept CBAM verifiers based outside the EU?
• Can any CBAM verifier verify our plant, or does it need our sector?
• Why can't our accredited verifier issue the CBAM report yet?
• Can an EU CBAM verifier send staff from an Indian branch to verify us?
• Can our ISO 14064 verification statement be used for CBAM?
• Why won't a CBAM verifier quote a fixed fee?

Before the visit

• What does a CBAM verifier check before accepting my engagement?
• What documents must I give a CBAM verifier?
• What checklist does a CBAM verifier use on our monitoring plan?
• What does a CBAM verifier do before testing my numbers?
• Can a CBAM verifier tell us how to fix our monitoring?
• We have two plants. Can one CBAM verification cover both?
• We only cut, slit or weld bought steel. Do we still need CBAM verification?

On site

• What does a CBAM verifier check during the site visit?
• When can a CBAM verifier do a virtual site visit?
• Can a CBAM verifier skip the site visit entirely?
• What does a CBAM verifier check at an Indian steel plant?
• What does a CBAM verifier check at an Indian aluminium smelter or extruder?
• What does a CBAM verifier check at an Indian cement or clinker plant?
• What does a CBAM verifier check at an Indian fertiliser plant?
• Our records are in Hindi or Gujarati. Can a CBAM verifier work with them, and in what language is the report?

The numbers they test

• How does a CBAM verifier test our fuel invoices and purchase records?
• How does a CBAM verifier spot unusual figures in my data?
• Does the CBAM verifier check our CN codes?
• Which tonnes count as production in a CBAM verification?
• We burn biomass or rice husk. What does the CBAM verifier need to zero-rate it?
• What does a CBAM verifier check on my supplier's verification report?
• We use default values for bought precursors. Does the CBAM verifier still check them?
• What if my precursor supplier cannot give me a verification report for CBAM?
• What is the materiality level in CBAM verification?
• Does weighbridge or meter uncertainty count against the 5% CBAM materiality level?
• What is the difference between a misstatement and a non-conformity in CBAM verification?

The report, and after

• What does a CBAM verification report contain?
• Which year's verification report does the EU importer use for our goods?
• Our CBAM verification came back negative. What happens to our EU buyers?
• Is the EU importer liable if the CBAM verification report is wrong?
• Can EU authorities see the CBAM verifier's working papers on our plant?

Straight answers

Does the first CBAM verification need a site visit?

Yes. The first year a verifier checks your plant, it must come in person. A video call replaces it only if something serious and unforeseeable, outside your control, stops the visit. From the second year a video visit is possible, and after two years on site the visit can be skipped, if the plant is simple and nothing significant has changed.

Who can verify CBAM emissions?

Only a verifier accredited for CBAM by an EU national accreditation body, for the group that covers your goods, and registered in the CBAM Registry. The Commission publishes the list. Firms outside the EU, Indian ones included, can apply to an EU accreditation body that takes them.

Who hires the verifier, our plant or our EU buyer?

Your plant. The operator of the installation hires the verifier and decides to have its figures verified. No EU rule says who pays, so agree it in your contract with the buyer.

When does the verification report have to be ready?

There is no legal deadline for the report, but the year's data must be complete first, so it cannot be finished before January. Your buyer declares by 30 September, and the Commission expects declarants to want reports by mid-August at the latest. Start in the year you are reporting on.

How big an error fails the verification?

An error above 5% of the emissions per tonne of a good, alone or added to others, is material. The same 5% applies to free allocation per tonne. A verifier can treat a smaller error as material too, and every error found should be corrected.

Is Senseible's check an accredited verification?

No. We build it from your records, check every figure in-house, and an accredited verifier we partner with signs it off. Have your own verifier? Send it to them.

Build your verifier file in the CBAM suite, see the supplier pack or see who files for your buyer.