# Does a solar or hydro plant supplying our cement or fertiliser plant need a CBAM site visit every year?

Canonical: https://senseible.earth/answers/renewable-power-plant-cbam-site-visit-waiver

Not every year. A power plant that makes only electricity and burns nothing, such as solar, wind or hydro, can have its site visit waived if a verifier visited physically at least once in the previous five reporting periods and the usual risk conditions hold. Biomass, waste-fired and carbon capture plants do not qualify.

## Why your solar supplier gets verified at all

Indirect emissions, the emissions from making the electricity you use, count for goods from the cement and fertiliser sectors and for sintered iron ore. A plant making other steel or aluminium goods does not count its own electricity. If your goods are in the first group and you claim a power plant's actual emission factor instead of the default, through a direct line or a power purchase agreement, that factor has to come from the power plant's own verified emissions report, much like a precursor.

For a plant that emits nothing, the monitoring plan is close to empty and the verifier only has to confirm that it does not emit. That is why the rules let its site visits be waived more often than anyone else's.

## The four conditions

1. Electricity is the only CBAM good the installation produces.
2. It uses no materials, fuels or processes that can emit greenhouse gases in normal operation.
3. A verifier made at least one physical site visit in the five reporting periods just before the current one.
4. The general conditions still hold: the plant's risks and complexity do not call for a visit, the risk analysis supports the waiver, it can get all evidence remotely, it can still reach reasonable assurance, and nothing significant has changed since the last physical visit.

## Who qualifies

- Qualifies: plants running only on renewable sources, such as hydro, solar, wind, geothermal or tidal.
- Qualifies: nuclear plants without auxiliary fossil fuel.
- Does not: plants burning biomass or waste, because the verifier has to check how much biomass can be zero-rated.
- Does not: plants that capture carbon, or that send greenhouse gases to other installations or pipelines.

## How this compares with your own plant

Your cement or fertiliser plant gets no such allowance. A virtual visit needs a physical one in the period before, and a full waiver needs physical visits in the two periods before. The two cannot be combined, so at best you alternate physical and virtual years, or have two physical years and then one waived.

## What your own verifier still checks

- The power plant's verifier was accredited for the right activity group plus LII, indirect emissions, when it signed.
- Its report carries a satisfactory statement.
- It covers the year the electricity was produced, which must be the year your goods were made.
- Your link to the plant: a single line diagram for a direct line, or the power purchase agreement, with smart meter data showing production and delivery at least hour by hour.

## Example: a hydro plant first visited for its 2026 report

- 2026 report: physical site visit
- 2027 to 2031 reports: 2026 falls within the five preceding periods each year, so a waiver is possible
- 2032 report: the five preceding periods are 2027 to 2031, with no physical visit, so a physical visit is needed
- One physical visit can cover six reporting years, against a physical visit at least every other year for an ordinary plant

This assumes every other condition holds each year. The verifier decides, and records why, in its own file.

## What Senseible does here

Senseible reads your electricity bills into units by billing period, a monthly cross-check on the consumption your verifier tests. The hourly smart meter data itself comes from your meters and the generator's. 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.

- [Prepare your CBAM file](https://senseible.earth/cbam-suite)
- [Electricity in fertiliser CBAM figures](https://senseible.earth/answers/cbam-fertiliser-indirect-emissions-electricity)
- [Green certificates and virtual PPAs under CBAM](https://senseible.earth/answers/cbam-green-certificates-virtual-ppa-not-allowed)
- [When a site visit can be waived](https://senseible.earth/answers/can-cbam-verifier-waive-site-visit)

Sources: [European Commission, Guidance on CBAM verification and accreditation (24 August 2026), sections 4.9, 7.5 and 9.2.3](https://taxation-customs.ec.europa.eu/document/download/030fe146-38e5-46b8-82b5-5f72da089a7b_en?filename=GUIDANCE%20ON%20CBAM%20VERIFICATION%20AND%20ACCREDITATION%20FOR%20VERIFIERS%20AND%20NATIONAL%20ACCREDITATION%20BODIES.pdf), [European Commission, CBAM Questions and Answers (15 October 2026), question 5.15](https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en?filename=CBAM_Questions%20and%20Answers.pdf)

Last reviewed 2026-11-03.
