The European CBAM: how the verification of reports will work

The mechanism and the requirements it imposes are already putting pressure on Ukrainian exporters of steel products

The European Commission has recently published a list of national accreditation bodies (NABs) authorised to accredit agencies to verify reports under the Carbon Border Adjustment Mechanism (CBAM). At present, only seven of these are ready to accredit applicants from third countries; Ukraine has already reached an agreement with Sweden to streamline the procedures.

Granting of accreditation

NABs located in an EU country (or a country of the European Economic Area following the incorporation of the relevant regulation into the EEA Agreement) are the only bodies authorised to grant accreditation under the mechanism.

Any organisation holding the necessary CBAM accreditation, granted by the relevant national authorities of EU Member States, may act as a verifier.

However, a verifier must meet certain requirements:

possess the necessary technical expertise in the relevant industrial sectors;
act independently and impartially;
verification processes must comply with established EU ETS methodologies.

The first CBAM verifiers are expected to receive accreditation around September 2026 — DG TAXUD will publish the relevant list.

Currently, authorisation to grant accreditation under the CBAM, according to the current list (as at 10 July), has been granted to 24 NABs.

Austria – Akkreditierung Austria (AA)
Belgium – Belgian Accreditation Council (BELAC)
Bulgaria – Bulgarian Accreditation Service (BAS)
Croatia – Croatian Accreditation Agency (HAA)
Cyprus – Cyprus Organisation for the Promotion of Quality (CYS-CYSAB)
Czech Republic – Czech Accreditation Institute (CAI)
Denmark – Danak Den Danske Akkrediteringsfond (DANAK)
Estonia – Estonian Accreditation Centre (EAC)
Finland – Finnish Accreditation Service (FINAS)
France – Comité français d’accréditation (COFRAC)
Germany – Deutsche Akkreditierungsstelle GmbH (DAkkS)
Greece – Hellenic Accreditation System (ESYD)
Hungary – National Accreditation Authority (NAH)
Ireland – Irish National Accreditation Board (INAB)
Italy – Ente Italiano di Accreditamento (Accredia)
Latvia – Latvian National Accreditation Bureau (LATAK)
Lithuania – National Accreditation Bureau (NAB)
Luxembourg – Office Luxembourgeois d’Accréditation et de Surveillance (OLAS)
Malta – National Accreditation Board (NAB-Malta)
Netherlands – Dutch Accreditation Council (RvA)
Poland – Polish Centre for Accreditation (PCA)
Portugal – Instituto Português de Acreditação (IPAC)
Romania – Romanian Accreditation Association (RENAR)
Slovakia – Slovak National Accreditation Service (SNAS)
Slovenia – Slovenian Accreditation (SA)
Spain – Entidad Nacional de Acreditación (ENAC)
Sweden – Swedish Board for Accreditation and Conformity Assessment (SWEDAC).

According to the European Commission, only 11 of them are actually ready to accept applications. Seven have agreed to accredit applicants from third countries, and only four national bodies are already accepting such requests — 𝐀𝐜𝐜𝐫𝐞𝐝𝐢𝐚 (Italy), 𝐑𝐯𝐀 (the Netherlands), SWEDAC (Sweden) and PCA (Poland).

Ukraine already has agreements with SWEDAC, whilst the Turkish Accreditation Agency (TÜRKAK) signed a corresponding agreement with the Dutch RvA in June this year.

Verification procedure

The accreditation of verifiers will be valid for 5 years, subject to annual surveillance.

The first site visit must be a physical visit (except in cases of force majeure). From 2027, under certain conditions (low risk, no significant changes), verifiers may carry out virtual site visits or opt not to do so. However, a physical audit must still take place at least once every two years.

What the verifier will analyse:

the methodology for calculating embedded emissions;
the production process;
raw material and energy consumption;
emission factors;
the completeness and accuracy of the data;
documents confirming payment of the carbon tax in the country of production (if applicable).

According to industry portals, the cost of third-party verification under the CBAM can range from €5,000 to €15,000 for small enterprises, €15,000 to €50,000 for medium-sized enterprises, and €50,000 to €150,000 or more for large industrial enterprises. The cost will be influenced by various factors: the number of production lines, the complexity of the sector, the verifier’s travel expenses, the quality of data provided by the manufacturer, and so on.

Main risks

The first declaration under this mechanism must be submitted by 30 September 2027 for imports in the previous year. If suppliers are unable to provide verified emissions data by this deadline, importers will be required to report using default values, which are typically significantly higher than the actual figures, and will be subject to penalty surcharges. This will lead to a significant increase in the cost of products imported from abroad, potentially making such transactions unprofitable.

The main obstacles that may prevent importers from using verified data in their CBAM declarations are the limited number of accredited verification bodies and auditors, the restricted verification period (January–September 2027), the requirement for audits to cover the entire value chain, and, indeed, the low level of preparedness among manufacturers themselves.

As for the audit side, it is not yet entirely clear how many operators will actually request verification. As noted by the Italian organisation Accredia, this makes it difficult to forecast demand for accredited verifiers. Consequently, national agencies may not be able to process all relevant applications.

The Ukrainian experience

As regards Ukrainian exports, in April this year Ukraine and Sweden agreed on approaches to simplifying the accreditation procedures for CBAM verifiers. As noted, the agreement will enable domestic exporters to verify emissions data in accordance with the requirements of the mechanism’s regulation and to use actual data. Furthermore, this decision will make it possible to circumvent logistical obstacles arising from the inability of foreign experts to visit Ukraine under martial law.

The Swedish side has proposed a flexible cooperation mechanism. SWEDAC is prepared to grant accreditation to Ukrainian verification bodies, drawing on the technical infrastructure and expertise of the National Accreditation Agency of Ukraine (NAAU).

SWEDAC noted that, for Ukrainian exporters, access to accredited verification bodies could be crucial to their competitiveness in the European market. Without verification, there is a risk not only of incurring higher costs but also of being excluded from certain segments of EU trade.

“The presence of verification bodies in Ukraine is a de facto prerequisite for continuing exports under the CBAM mechanism. Given the war and security risks, European experts are unlikely to be willing to travel to Ukrainian production sites to carry out audits. At the same time, Ukrainian verifiers accredited under European rules will be able to confirm the carbon intensity of products in accordance with EU standards, which will enable Ukrainian exporters to use actual emissions data,” notes Andriy Glushchenko, an analyst at the GMK Centre.

According to EcoPolitic, at the end of May this year, representatives of the NAAU visited SWEDAC, following which the parties signed a cooperation agreement. However, the cooperation mechanism involves a number of specific features.

Under the terms of the agreement, should a Ukrainian verifier submit an application to SWEDAC, it is the Swedish side that will analyse it and review the necessary documentation. However, certain technical procedures, such as on-site assessments and observations, may be carried out by the NAAU on a subcontracting basis.

It is worth noting that the National Accreditation Agency of Ukraine does not participate in decision-making regarding accreditation. All payments will be made by Ukrainian verifiers directly to SWEDAC, which, in turn, will pay for the work carried out by the NAAU.

However, the involvement of the Ukrainian body is not a mandatory requirement for SWEDAC — this format of cooperation is considered one of several possible options.

The impact of CBAM on Ukraine

According to a study by the GMK Centre, CBAM will reduce exports of ferrous steel products from Ukraine by 2.5 million tonnes by 2030. The overall impact of the mechanism on the country’s economy is estimated at -2.1% of GDP in 2030. This figure stands in stark contrast to the European Commission’s estimate of -0.01%.

Ukrainian iron and steel companies have already seen European customers cancel orders in the first few months of the CBAM’s full implementation — major domestic players such as Metinvest and ArcelorMittal Kryvyi Rih have faced this, for example.

For Metinvest, amongst other things, the negative impact of the mechanism also extends to intra-group cooperation: the suspension of square billet supplies from Kametstal could affect the operations of the Bulgarian plant Promet Steel and pose risks to job security in EU countries.

ArcelorMittal Kryvyi Rih has faced the cancellation of orders from European customers for the first quarter of 2026, forcing the company to reduce production capacity, in particular by shutting down the casting and mechanical plant and the blooming mill.

Furthermore, domestic companies have pointed to consistently inflated figures in the European Commission’s reference guide, particularly for Ukrainian seamless pipes and iron ore pellets, the lack of accredited verifiers (furthermore, not all international auditors are accredited for the full range of products), and the lengthy process of registering production capacity in the CBAM register.

The postponement of the mechanism’s requirements for Ukraine due to the recognition of force majeure – namely, the war in the country – is one of the first decisions affecting the domestic iron and steel sector, which currently lacks the same opportunities as its competitors, in particular European steelmakers who have access to support as part of the energy transition.

With the CBAM now fully in force, it is no longer merely a matter of calculating emissions. To use actual figures, a comprehensive system of accounting, documentation and independent verification is now required. Companies that are able to meet these requirements will avoid the risk of using inflated default values, fines and problems with access to the EU market.