The Carbon Border Adjustment Mechanism (CBAM) will enter its definitive taxation phase on January 1, 2026. The verification process is now a critical component, directly impacting importers' carbon costs and compliance risks. This article provides a systematic overview of the CBAM verification mechanism based on the latest information.

Ⅰ. Key Players: Verification Bodies and the Accreditation System
CBAM verification must be conducted by third-party Validation and Verification Bodies (VVBs) accredited by national Accreditating Bodies of EU member states. These VVBs are responsible for reviewing emission data submitted by non-EU producers to ensure compliance with EU regulations.

As of January 10, 2026, 75 VVBs across 15 EU countries have been authorized to perform CBAM-related verification. Germany and Italy host the highest number, with 10 authorized bodies each, followed by Poland. Notably, all authorized bodies are currently located within the EU; no non-EU institutions have been included on the list.

This implies that, in principle, CBAM verification must be performed by entities registered in the EU. However, industry insights suggest a potential alternative model: EU-based bodies may authorize qualified individual verifiers to conduct on-site checks in third countries, effectively prioritizing personal qualifications over the verifier's physical location. This also indicates that future CBAM-qualified verifiers will be in high demand.

 

Ⅱ. Core Content and Requirements of CBAM Verification
According to the latest EU implementing rules, CBAM verification primarily consists of two aspects:

Data Verification: This encompasses reviewing production processes, equipment, emission sources, data collection procedures, monitoring plans, reports, emission calculations, activity data, emission factors, and precursor emissions (where applicable). VVBs must ensure data is authentic, complete, and traceable through document review and cross-checking.

Verification Report: VVBs must issue a report using the EU standard template, stating the verification conclusion and level of assurance, recording any material misstatements or non-conformities, and providing recommendations for improvement.

Important Note: For the first reporting period in 2026, on-site visits are mandatory for all facilities. Starting in 2027, audits may be conducted remotely or, under specific conditions, exempted from on-site visits, but physical inspections must occur at least every two years.

 

Ⅲ. Verification Timeline and Scheduling
The duration of verification depends on several factors: the complexity of the enterprise, data quality, number of production processes, the verifier's workload, and necessary corrective actions. Typically, the process takes no less than two months.

Verification for 2026 emissions reports must be completed several months before the final tax payment deadline in September 2027. Given the tight schedule and process complexity, enterprises must plan ahead to avoid delays.

 

Ⅳ. Preparing for Verification: A Forward-Looking Approach
Although verification for 2026 reports begins in 2027, preparation must start immediately:

Establish a routine monitoring mechanism, preferably with quarterly emission monitoring, ledger management, and reporting—avoid last-minute data scrambling.

Ensure traceable and authentic data sources, particularly for upstream raw materials or precursor emissions. Strengthen communication with supply chain partners.

Adopt compliant accounting methodologies, transitioning early to the actual emissions calculation required by CBAM, moving away from transitional estimation methods.

Conduct continuous gap analysis and improvement against verification requirements to refine monitoring plans and internal management processes.

A crucial compliance point: The verification body must be independent of the reporting preparer; the same entity cannot perform both tasks.

 

Ⅴ. Conclusion
The implementation of the CBAM verification mechanism marks a shift towards a more granular, data-driven phase in EU carbon border management. For exporting enterprises, the ability to systematically and continuously monitor emissions, manage data, and prepare for verification will directly impact future cost competitiveness and market access in the EU. With the 2026 taxation phase approaching, companies must initiate their compliance strategy early to secure a proactive position.