Do not pay for CBAM "pre-verification" in 2026

The CBAM rules do not recognise pre-verification, so compare any offer with the Regulation before you pay. Suppliers, consultants and certification bodies are selling it this autumn under that name.

Some of what they sell is useful. None of it counts as verification, and one version can damage the verification that does count.

What the law recognises

The law recognises only verification by an accredited, independent verifierVerifierAccredited independent third party confirming the SEE is free of material misstatement; any EU or third-country legal person; only values in a verification report count for actuals. Importers receiving "verification reports" from third part. You can use actual emissions in your CBAM declaration only if such a verifier has verified them (Article 8 of the Regulation). The certificates you surrender must match emissions "declared and verified in accordance with Article 8" (Article 22(1)). The verifier works at reasonable assuranceReasonable assuranceThe assurance level of CBAM verification statements (workbook "Engagement type" dropdown also offers "Limited assurance" — CBAM verification itself is reasonable-assurance)., the higher level of assurance. It issues the report through the CBAM RegistryCBAM RegistryEU IT system holding declarant accounts, declarations, verified emissions reports, certificate transactions and (from 2027) the published default carbon prices..

The Commission's verification timeline says accredited verifiers can issue their first reports from January 2027. So nothing produced in 2026 can be a verification reportVerification reportSingle electronic Commission template via the CBAM Registry; minimum content: general identification, verification information (team, visits, materiality applied, data verification incl. FAA per good, precursor verification incl. precursor-, whoever produces it and whatever it is called.

What pre-verification is

Pre-verification is a commercial label with no legal status. A seller needs no accreditation to offer it, and you cannot put its result into your declaration. A "pass" carries no weight with a verifier, a competent authority or the Commission.

What you are buying is a review and, sometimes, advice. A review can be worth paying for as a review. It is not worth paying for as verification.

The impartiality trap

The impartiality rules are the part of this topic that can cost you money. Delegated Regulation (EU) 2025/2551 on accreditation and verification sets them in Annex II. They reach back into any consulting you buy, and three of them apply here.

• Consulting on the core documents is an "unacceptable risk". This covers consulting to develop the monitoring methodology, draft the emissions report or draft the monitoring planMonitoring planOperator's written description of source-stream monitoring, tiers, methods and data-gap procedures; baseline document of the verification.. The risk to impartiality arises when the verifier, or any part of the same legal entity, provides that consulting (Section 1.7.2).
• Related organisations count too. A conflict of interest also arises if the operator received that consulting from an organisation related to the verifier. Common ownership, shared resources, common contracts or marketing, and a commission for referring clients are examples of a relationship (Section 1.7.3).
• A verifier may recommend, not advise. It may give recommendations for improvement. It must not give advice or develop parts of the monitoring and reporting process (Section 2.20).

The consequence is direct. Suppose a supplier pays a body to "fix" its monitoring plan, and that body, or a related one, later verifies the same installation. The verifier may then be barred from the engagement, or its report may be open to challenge.

The supplier can end up having bought the very service that disqualifies its preferred verifier. You carry the risk of a report from a compromised verifier, because you sign the declaration and surrender the certificates.

What to pay for instead

Four things are worth paying for now, and none of them is called verification.

• A readiness or gap review, bought as consulting, from someone who will not verify you. It should state what it is and produce findings. A review may be called a review.
• Your own data work. Reconcile your import records first. Then ask suppliers for the producer, the customs code, the emissions data, and whether a verifier could verify the data.
• An early conversation with the verifier you intend to appoint. Ask what they need to see and when. They may tell you what is missing, but they may not write it for you.
• Verifier capacity. As of 29 September, 24 national accreditation bodies have agreed to offer CBAM accreditation. 16 are listed as ready to accept applications (the Commission's total says 16; its own rows show 17). Book early.

What it means for importers

You may not need verification at all. Default values are valid, and if you use them there is nothing to verify.

Default values carry a mark-up, set at 10% for 2026 (1% for fertilisers). Verified actual values can therefore lower your cost. Before you spend on preparation, work out whether the saving exceeds the cost of verification.

What to do

Before you sign a pre-verification offer, check these five points.

1. Ask whether the body is accredited for CBAM, by whom, and for which activity groups. Ask for the certificate.
2. Ask whether it, or any related company, will be your verifier. If yes, ask how it stays impartial under Sections 1.7.2 and 1.7.3.
3. Check whether the price includes developing or correcting the monitoring plan or the emissions report. That is the risky part.
4. Ask for the output in writing: a findings report, or a "certificate". A certificate of pre-verification means nothing.
5. Check whether it promises that you will "pass" next year. No one can promise that.

Stuck on this in your own import data? Write to us and we will look at it with you.

This article explains the rules. It is not legal, tax or customs advice.