The European Commission has issued dedicated guidance on verification and accreditation under the Carbon Border Adjustment Mechanism (CBAM), with a first set published on August 24. New Registry manuals for accredited verifiers followed on August 27–28. The documents do not amend the CBAM Regulation, but they outline how claims for electricity imported into the EU will be checked when using actual embedded emissions rather than a default value.
The guidance is relevant for electricity producers, traders, aggregators and industrial buyers in Serbia, Montenegro and other neighbouring markets supplying identifiable renewable electricity to EU customers. It indicates that verification will extend beyond providing a power purchase agreement or a guarantee of origin. Instead, each claimed megawatt-hour must be traceable through multiple defined elements.
Traceability requirements for actual embedded emissions claims
The Commission’s guidance states that every claimed megawatt-hour must be traced through a named generating installation, a qualifying contractual arrangement, an hourly production record, an accepted cross-border nomination, the EU importer and independently verified allocation. It also specifies that proposed changes to the electricity provisions, including possible retroactive adjustments, remained under legislative consideration and were not included. As a result, the existing five conditions in Section 5 of Annex IV remain the working basis for electricity imported during 2026.
A key clarification concerns the evidence expected for a power purchase agreement. A verifier is expected to confirm the authorised CBAM declarant’s Economic Operators Registration and Identification number (EORI) alongside the producer’s unique CBAM Installation ID. The verifier is also expected to check the reporting period, contracted quantity and supporting invoices or delivery records.
The verification must also establish that controls prevent the same electricity from being claimed more than once. The guidance says this changes how power purchase agreements function as evidence: a commercial agreement between a producer and trader alone is not sufficient to support actual-emissions treatment. Contractual documentation and supporting records must identify the EU declarant, generating installation, reporting period and allocated quantity.
Contract chains, intermediaries and double-counting controls
The Commission’s guidance addresses cases where aggregators, suppliers or other intermediaries sit between the generating plant and the EU importer. It indicates that verifiers should determine whether parties are covered by a single contractual arrangement. It also notes that a chain of unrelated back-to-back contracts may be insufficient if it does not provide an auditable connection between the installation, intermediary and authorised declarant.
Producers and suppliers are expected to review trading contracts to ensure the chain remains intact. The guidance says contract amendments may be needed to introduce CBAM-specific installation references, data-access rights, allocation rules, audit provisions and protections against double counting. Where such changes are required, they are intended to connect commercial transactions to physical electricity flow and records used in CBAM declarations.
Hourly network congestion and interconnector nomination evidence
The guidance provides more detail on physical-delivery conditions tied to electricity eligibility. For requirements relating to absence of physical network congestion between the generating installation and EU destination, written transmission system operator evidence should demonstrate on an hourly basis that network conditions permitted the claimed transfer. If available evidence is unclear, a verifier may seek confirmation directly from the relevant TSO and obtain a timestamped congestion report where possible.
It also states that equivalent evidence may be required from TSOs of transit countries when electricity crosses several systems before entering the EU. The Commission says this is material for electricity traded from the Western Balkans because contractual routes may involve multiple bidding zones, borders and market participants. Accepted interconnector nominations must document origin, destination and any transit systems.
The nomination requirement is linked to production metering at installation level. Smart-meter production recorded at the generating installation must correspond to the nominated delivery period, which may not exceed one hour. The overall approach results in an hourly reconciliation chain covering plant metering, production data, cross-border capacity, accepted nominations, transit arrangements and quantity imported by the authorised EU declarant.
The guidance adds that metering and commercial records complete at monthly or annual level may still fail if they cannot be reconciled for each relevant hour. It points to coordination needs among producers, balance-responsible parties, traders, TSOs and EU importers. It also highlights operational details such as timestamp consistency, meter hierarchy, missing-data procedures and controls governing corrections to schedules or production records.
Monthly interim reporting and declarant-specific addenda
The Commission has clarified interim reporting expectations for verifiers. It says verifiers should receive 12 monthly interim reports covering principal electricity eligibility criteria. Where there has been no relevant change during a month, a short report confirming “no change” may be accepted.
This approach is described as creating continuous compliance rather than relying on year-end document collection. Producers and intermediaries are expected to run a controlled monthly close covering changes to installations, contractual arrangements, generation data, cross-border schedules, congestion evidence and allocated import quantities. The guidance warns that waiting until end of year could leave gaps difficult to reconstruct and may lead verifiers to reject part of claimed electricity.
Each authorised CBAM declarant must also receive a declarant-specific addendum identifying the declarant’s EORI, confirming relevant eligibility conditions and stating precise quantity imported from the installation. The verifier must assess each addendum separately and provide individual confirmation for each declarant-specific addendum in its verification report.
The guidance says this requirement effectively rules out reliance on a single pooled annual certificate where one producer or aggregator supplies several EU traders. It indicates operators will need separate declarant sub-ledgers and controls ensuring that the same production is not allocated across multiple customers. The sub-ledger should track available generation, quantities reserved under each contract, accepted nominations, confirmed border deliveries, rejected hours, reallocations and final verified quantity for each declarant.
Independence between advisory work and accredited verification
The documents also address how responsibilities should be structured within verification services. Unlike an EU Emissions Trading System model where roles differ by design, under CBAM the verifier assesses whether an operator’s monitoring plan complies with applicable methodology and whether it has been correctly implemented. At the same time, accredited verifiers must remain independent.
The Commission states that accredited verifiers cannot have supported preparation of the monitoring plan or emissions report that they later verify. Companies therefore need to separate readiness and advisory work from final accredited verification activities. A pre-verification provider may help design monitoring plans, evidence repositories, contractual controls, reporting procedures and corrective-action programmes.
The accredited verifier must then perform independent assessment without having created underlying systems used for monitoring or reporting. The guidance warns that using an intended final verifier to design monitoring architecture could create an independence conflict and complicate acceptance of verification reports. It says this distinction is especially relevant for companies entering CBAM verification for the first time where evidence repositories connecting technical records with customs and carbon records may not yet exist.
Accreditation scope for imported electricity and Registry access timeline
The Commission confirms that verification of electricity physically imported into the EU requires accreditation for activity group LI covering “electricity imported into the customs territory of the Union”. Activity group LII is identified as a separate scope for indirect emissions. The distinction matters when selecting verifiers because general CBAM accreditation or accreditation for another covered industrial activity does not automatically qualify them for imported electricity assessment.
The guidance notes an apparent wording inconsistency in one example referring to LI in connection with indirect emissions while stating that controlling Delegated Regulation identifies LI as imported electricity and LII as indirect emissions. It says verifier-selection procedures should follow legal text and confirm precise activity scope shown on accreditation certificates. Companies are also expected to check whether prospective verifiers have technical competence and geographic capacity to assess cross-border evidence including records obtained from non-EU producers, traders and transmission operators.
The Commission has begun operationalising verifier access to the CBAM Registry with registration opening from September 1, 2026. Accredited verifiers must complete registration within two months of accreditation by submitting an accreditation certificate plus corporate and representative documentation through the EU’s O3CI access system. Applications are handled through national competent authorities in member states where verifiers were accredited.
Verification reports are expected to be issued through the Registry from January 2027. For operators and declarants appointing verifiers involves more than checking accreditation certificates; it includes confirmation that Registry registration is completed with necessary digital access established so verifiers can connect to relevant installation and declarant records. The final readiness process described includes testing accreditation scope coverage alongside O3CI registration status.
Western Balkan exporters: linking intervals to allocation under actual emissions
For Serbian and other Western Balkan exporters seeking actual-emissions treatment, the guidance raises both evidentiary value and operational cost of proving embedded emissions claims. Renewable producers may have commercial advantage if they can demonstrate low embedded emissions for electricity physically imported into the EU based on evidence linking individual generation intervals to contractual allocation and cross-border delivery.
The documents state that renewable status alone is not sufficient evidence for qualification under actual embedded emissions treatment. They similarly state that annual guarantees of origin do not replace requirements tied to accepted nominations, border records or installation-level metering when establishing eligibility per claimed quantity.
The qualifying unit is described as each claimed megawatt-hour within a controlled chain covering installation identity, production scheduling transmission import allocation and verification. Companies seeking actual emissions treatment are directed toward gap assessments covering five areas: contractual architecture hourly metering cross-border evidence declarant-level allocation and verifier readiness.
The guidance states CBAM electricity compliance cannot be assembled solely by a sustainability department because it requires an integrated operating model covering plant operations including SCADA and metering plus trading balancing legal agreements customs records carbon reporting and independent assurance. It reiterates that execution depends on resolving every claimed megawatt-hour through one named installation one qualifying contractual chain one accepted physical schedule one EU importer or declarant one controlled allocation process element and one independent verification conclusion.
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