Verification

What verification does

Regulation 10 of SI 2026/995 defines verified emissions data as data about the relevant emissions of an installation in a monitoring period that meet the Commissioners' requirements and for which a verifier has given a verification opinion statement that the data are sufficiently accurate. Step 2 of regulation 5 uses verified data and nothing else, and regulation 10(1)(f) of SI 2026/802 requires the intensity on the return to be verified. Without the opinion statement there is no actual-data route.

Who may verify

Regulation 12(1) sets three conditions. The verifier must be independent of the importer, of the installation and its operator, and of any installation that made a precursor for the good. The verifier must be accredited by an accreditation body to verify relevant emissions for the type of CBAM good concerned, with type defined by commodity code, so a verifier accredited for fertilisers is not by that fact eligible for steel. And the verifier must meet the further standards in a Commissioners' notice. Independence is about relationship: a verifier in the supplier's group or the importer's group is not independent, while one accredited verifier may verify both a works and the slab works it buys from. The draft notice of 9 September 2026 fills in what independence means, including common ownership, governance, personnel, resources, finances and contracts, and allows the same verifier in consecutive years subject to a risk assessment; the draft does not currently have force of law.

The accreditation body

Regulation 15 requires the accreditation body to be a full member of the Global Accreditation Cooperation Incorporated, described in the regulation as a New Zealand incorporated society with the incorporation number 50223540, and to meet a Commissioners' notice. HMRC's policy summary, as guidance, names ISO/IEC 17029:2019 and ISO 14065:2020 as the standards for verifiers and ISO 17011:2017 for the body; the draft notice names the same two standards for verifiers in its section J.6.1. As at 13 September 2026 the final notices under regulations 12, 13 and 15 had not been published.

The report

Regulation 14, which is law, requires the verifier to give the operator a verification report for each monitoring period containing the name and address of the installation, the operator and the verifier, the verifier's accreditation number, the monitoring period and a verification opinion statement. The report goes to the operator, and the importer receives it, or a good-specific verification summary once the Commissioners define one, from the supplier at one remove. The importer should check the report against regulation 14(2), check that the figure on it is the figure the supplier quoted, and, where anything raises a doubt, ask the verifier named in it to confirm.

What remains the importer's

The importer does not verify, accredit or audit the verifier. What remains the importer's responsibility is the weight of the imported good, its classification, its origin, the choice of monitoring period under regulation 9, the arithmetic of step 8 and the declaration that the return is true and accurate. A verified intensity applied to the wrong weight, to goods of a different code, or for a period regulation 9 does not permit produces an inaccurate return, and the verifier's opinion covers none of those. The Act gives the importer no statutory remedy against a verifier whose report proves wrong.

Carbon pricing data

Carbon pricing data is verified under regulations 7 to 9 of SI 2026/809 by a verifier who is independent of the installation, the importer and the authorities that administer the scheme, and the result is form CarbonVP1. The relief guide covers the form.

The six-line test

Before a report's figure goes on a return, check that it names the installation, the operator and the verifier with addresses; states the accreditation number and body, and that the body is a full member of the Global Accreditation Cooperation Incorporated; states a scope of accreditation that covers the type of good; states a monitoring period that regulation 9 permits for the date of import; contains an opinion statement that the data are sufficiently accurate; and comes from a verifier independent of the importer, the installation and every precursor installation. A report that fails any line is not usable, and the good goes on the return at the default value.