EU CBAM Verifiers: Complete Guide and Checklist for Indian Exporters (2026 Ready)

EU CBAM verifiers

EU CBAM verifiers are a critical part of the Carbon Border Adjustment Mechanism (CBAM) ‘s definitive phase, which starts on January 1, 2026. Recent published regulations also point to one non-negotiable: verified emissions data. EU CBAM verifiers are approved third-party organisations that review and confirm the accuracy of emissions data reported by producers outside the EU. In the CBAM process, verification comes after emissions are calculated at the factory level and before EU importers submit their annual CBAM declarations, making it a mandatory step once the definitive phase begins on 1 January 2026.

For Indian exporters in sectors such as steel, aluminium, cement, fertilisers, hydrogen, and electricity, and other critical sectors, CBAM verification is not just a compliance formality; it directly affects market competitiveness. If verified emissions data is not available, EU importers are required to use default emission values, which are typically much higher than actual emissions. This leads to higher carbon costs at the border, making Indian products more expensive and less attractive compared to suppliers with verified data. In practical terms, the absence of CBAM verification can result in lost price advantage, reduced buyer confidence, and increased risk of losing access to the EU market.

This comprehensive guide breaks down everything you need to know about CBAM verifiers, from accreditation requirements to selecting the right verification partner.

EU CBAM Verifiers: Why does CBAM verification matters?

From 2026 onwards, EU importers can only use actual emissions data in their CBAM declarations if it has been verified by an accredited third-party verifier commonly called EU CBAM verifiers. Without verified data, importers are forced to rely on default values, which are typically set at the higher end of the emissions spectrum and will significantly increase your buyers’ CBAM certificate costs.

The bottom line: Unverified data = Higher costs for your EU buyers = Lost competitiveness = Potential loss of contracts.

Recent analysis suggests that CBAM could increase the cost of Indian steel exports to the EU by approximately 15% in 2026, rising to 51% by 2034. Having verified, accurate emissions data helps minimize these cost impacts.

What is CBAM Verification and Who Can Be a CBAM Verifier?

CBAM verification is an independent assessment process that confirms whether your reported emissions data:

  • Is free from material misstatements
  • Complies with EU methodology requirements
  • Meets materiality thresholds (5% of total specific embedded emissions per tonne)
  • Follows your approved monitoring plan

According to the recent Commission Delegated Regulation C(2025)7845, verifiers must be:

  1. Accredited by National Accreditation Bodies (NABs) under Annex I of Regulation (EU) 2018/2067 (EU ETS standards)
  2. Legal entities (not individuals)
  3. Granted access to the CBAM Registry by their national Competent Authority (within two months of accreditation, but not before September 30, 2026)
  4. For EU ETS verifiers: Extended accreditation scope to CBAM activity groups (Annex I); new verifiers apply directly (Articles 3-4)

Verifiers can operate globally, they don’t need to be based in the EU to verify installations outside the EU.

A comprehensive list of CBAM verification companies:

While the official list of CBAM-accredited verifiers is still being finalised, several established certification bodies are preparing for CBAM verification services. Here is the list of entities that give EU ETS verifiers eligibility for CBAM extension: 

1. SGS (Société Générale de Surveillance)

  • Headquarters: Geneva, Switzerland
  • Global Presence: 2,500+ laboratories across 115 countries
  • Key Certifications: ISO 14064-1, ISO 14067, EU ETS accreditation experience
  • CBAM Readiness: Offering pre-verification services, gap assessments, and training
  • Website: www.sgs.com

2. Bureau Veritas

  • Headquarters: Neuilly-sur-Seine, France
  • Established: 1828 (197 years of experience)
  • Key Certifications: ISO 9001, ISO 14001, ISO 45001, EU ETS verification
  • CBAM Services: Strategic training, emissions calculation, reporting support, independent verification
  • Website: www.bureauveritas.com

3. DNV (Det Norske Veritas)

  • Headquarters: Høvik, Norway
  • Specialization: Marine, oil & gas, renewable energy
  • Key Certifications: ISO 14064, ISO 14065, EU ETS verification
  • Website: www.dnv.com 

4. TÜV SÜD

  • Headquarters: Munich, Germany
  • Focus Areas: Engineering, transport, industrial manufacturing
  • Key Certifications: ISO 14064-1, ISO 14065, Greenhouse Gas verification
  • Website: www.tuvsud.com

5. TÜV Rheinland

  • Headquarters: Cologne, Germany
  • Global Reach: Operations in 69 countries
  • Key Certifications: ISO 14001, ISO 50001, Carbon footprint verification
  • Website: www.tuv.com

6. TÜV Nord

  • Headquarters: Hanover, Germany
  • Specialization: Large-scale industrial operations
  • Key Certifications: ISO 14064, CDM/JI project verification
  • Website: www.tuv-nord.com

7. RINA (Registro Italiano Navale)

  • Headquarters: Genoa, Italy
  • Key Certifications: ACCREDIA accreditation for EU ETS, MRV, ISO 14064-1, ISO 14067
  • CBAM Services: Full verification services including physical site visits
  • Recognition: UNFCCC recognized for CDM/JI, VERRA for VCS program
  • Website: www.rina.org

9. Lloyd’s Register Quality Assurance (LRQA)

  • Headquarters: London, UK
  • Legacy: First registrar to hold accreditation in Britain
  • Key Certifications: ISO 14001, ISO 14064, Greenhouse Gas verification
  • Website: www.lrqa.com 

Essential Verifier Qualifications Checklist:

When selecting EU CBAM verifiers, ensure they meet these criteria:

  1. Mandatory Accreditations
  •  Accredited by a National Accreditation Body (NAB) under EU Regulation 2018/2067
  • Scope of accreditation covers CBAM-relevant sectors (your specific goods)
  • Valid accreditation with clear expiration date
  • Access granted to CBAM Registry by national Competent Authority
  1. Technical Competencies
  • ISO 14064-1 (Greenhouse gas accounting and verification)
  • ISO 14065 (Greenhouse gas validation and verification body requirements)
  • ISO 14067 (Carbon footprint of products)
  • EU ETS verification experience (highly valuable)
  • Sector-specific expertise (e.g., steel production, cement manufacturing)
  1. Verification Team Requirements
  • CBAM Lead Auditor qualified
  • CBAM Auditors with relevant industry experience
  • Technical experts for specific production processes
  • Professional indemnity insurance coverage
  • Independence from your operations (no conflict of interest)
  1. Operational Capabilities
  • Ability to conduct physical site visits (mandatory in Year 1)
  • Experience with complex production processes
  • Understanding of precursor materials and supply chains
  • Capacity to verify both direct and indirect emissions
  • Knowledge of default values and when they apply

The Verification Process: What to Expect:

Based on the new implementing regulation, here’s what the CBAM verification process entails:

Phase 1: Strategic Analysis:

  • Verifier reviews your monitoring plan
  • Assessment of your production processes and emission sources
  • Identification of verification scope and materiality thresholds

Phase 2: Risk Analysis:

  • Evaluation of inherent risks (complexity of processes)
  • Assessment of control risks (quality of your monitoring system)
  • Development of verification approach

Phase 3: Physical Site Visit (Mandatory in 2026):

  • On-site inspection of your installation
  • Review of production equipment and measurement instruments
  • Verification of data collection processes
  • Interviews with operational staff
  • Assessment of control systems

Phase 4: Data Verification

  • Review of emissions calculations
  • Verification of activity data and emission factors
  • Cross-checking against supporting documentation
  • Assessment of precursor emissions (if applicable)
  • Evaluation of free allocation adjustments

Phase 5: Reporting

  • Preparation of verification report using EU standardized template
  • Verification statement indicating reasonable assurance
  • Documentation of any material misstatements or non-conformities
  • Recommendations for improvement

Key Pain Points for Indian Exporters (And How to Overcome Them):

Challenge 1: Limited Local Verifier Availability

Impact: As of late 2025, many verifiers are still obtaining CBAM-specific accreditation.

Solution:

  • Engage early with global verifiers who have India operations
  • Consider verifiers with EU ETS experience who are transitioning to CBAM
  • Join industry associations to leverage collective bargaining power

Challenge 2: High Verification Costs

Impact: Verification can cost between ₹5-15 lakhs depending on installation complexity.

Solution:

  • Start with gap assessments to identify and fix issues early
  • Invest in robust monitoring systems to reduce verification time
  • Consider multi-year verification agreements for better rates
  • Group verifications with industry peers where possible

Challenge 3: Data Availability and Quality

Impact: Many Indian installations lack granular, process-level emissions data.

Solution:

  • Implement digital emissions tracking tools now (like those offered by The Sustainability Cloud)
  • Conduct internal audits before engaging verifiers
  • Invest in measurement instruments for key emission sources
  • Train staff on data collection and documentation

Challenge 4: Complex Supply Chains

Impact: Difficulty obtaining verified data from precursor suppliers.

Solution:

  • Map your entire supply chain early
  • Work with suppliers to establish data-sharing protocols
  • Use the CBAM Operator Portal for streamlined data exchange
  • Consider verified precursor data as a supplier selection criterion

Challenge 5: Understanding EU Methodology

Impact: EU calculation methods differ from other standards (ISO 14067, GHG Protocol).

Solution:

  • Engage CBAM consultants for methodology training
  • Participate in webinars and workshops
  • Use CBAM-specific software tools that encode EU methodologies
  • Request pre-verification reviews from potential verifiers

Challenge 6: Timeline Pressures

Impact: Verification must be completed for each reporting period (annual from 2026).

Solution:

  • Start verification preparation in Q1 2025
  • Establish year-round monitoring, not just pre-verification scramble
  • Build buffer time into your compliance calendar
  • Maintain continuous improvement of your monitoring plan

As CBAM moves into its definitive phase, verification readiness will increasingly depend on how well exporters can operationalise emissions monitoring, documentation, and audit trails on a continuous basis. Given the scale, frequency, and technical rigor of CBAM verification, relying on manual data collection or fragmented spreadsheets significantly increases the risk of delays, inconsistencies, and adverse verification outcomes. This is where digital, audit-ready CBAM systems designed to align with EU methodologies and verifier workflows become critical enablers, helping exporters move from reactive compliance to structured, verifiable, and cost-efficient CBAM reporting.

The TSC Netzero: CBAM solution tool, we’ve pioneered a consultant-led software approach that combines the best of both worlds: human expertise and digital efficiency. It helps in automating data collection for each input and output of every process in a CBAM product’s production route. 

TSC NetZero’s CBAM reporting software ensures accurate product-embedded emission calculations at every level. It also assists in quarterly emission report generation by digitising the entire process. It also supports the tracking of carbon taxes paid along the supply chain.
In addition to these, our platform ensures digital auditing of reports with accurate trails. There is also an integrated facility for third-party and first-party verification, as well as digitising the third-party audits by inviting EU-accredited auditors via TSC Netzero’s assurance modules.

FAQs

No. A single accredited verifier can verify multiple installations, even across different countries. However, they must have the appropriate scope of accreditation for each type of good produced.

Yes, but the verifier must be independent from both you and the importer. There should be no conflicts of interest or business relationships that could compromise independence.

You can still get verification for your installation’s actual emissions. The verification report will document which precursors used default values. This doesn’t invalidate your verification, but you should minimize default value usage where possible.

Though not specified in regs, duration varies by verifier (typically 4-8 weeks atleast), depending on:

  • Installation complexity
  • Data quality and completeness
  • Number of production processes
  • Verifier’s workload
  • Any corrective actions needed

For 2026 emissions, plan verification for Q1 2027 (after your full year of data). However, engage verifiers in Q1-Q2 2026 to:

  • Conduct gap assessments
  • Ensure your monitoring plan is approved
  • Establish reporting processes
  • Avoid the year-end rush

The verifier cannot issue a positive verification statement if material misstatements or non-conformities remain uncorrected. You’ll need to:

  • Address identified issues
  • Conduct corrective actions
  • Undergo re-verification
  • Your EU importer may need to use default values temporarily

In India, CBAM verification costs are typically deductible as business expenses. Consult your tax advisor for specific guidance.

No. To maintain independence, verifiers cannot provide consulting or advisory services to installations they verify. Keep verification and consulting separate.

No, verification is not mandatory until 2026. However, voluntary pre-verification is highly recommended to:

  • Identify gaps in your monitoring system
  • Practice the process before it becomes mandatory
  • Build relationships with verifiers
  • Demonstrate readiness to EU buyers

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Picture of Dhriti Jain
Dhriti Jain
As a Climate Content Specialist, Dhriti writes on carbon accounting, ESG, and the impacts of evolving climate policies on businessness.

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