The European Commission has issued dedicated guidance on verification and accreditation under the Carbon Border Adjustment Mechanism (CBAM) on August 24, followed by new Registry manuals for accredited verifiers on August 27–28. The documents do not amend the CBAM Regulation. They set out how accredited verifiers are expected to examine claims that electricity imported into the EU can use 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 the verification standard extends beyond presenting a power purchase agreement or a guarantee of origin. Each claimed megawatt-hour must be traced through named and documented elements covering generation, contracting, delivery scheduling and allocation.
The Commission stated that proposed changes to the electricity provisions, including possible retroactive adjustments, remain under legislative consideration and are not included in the new guidance. For electricity imported during 2026, the working basis remains the existing five conditions in Section 5 of Annex IV. The guidance therefore describes how verifiers will apply those conditions when assessing actual-emissions claims.
Power purchase agreements as evidence tied to declarants and installations
A key clarification concerns the evidence required for a power purchase agreement used in CBAM electricity claims. A verifier is expected to confirm the authorised CBAM declarant’s Economic Operators Registration and Identification number (EORI), along with the producer’s unique CBAM Installation ID. The verification also covers the reporting period, contracted electricity quantity and supporting invoices or delivery records.
The verifier must also establish that controls prevent the same electricity from being claimed more than once. As a result, a commercial agreement between a producer and trader is not sufficient on its own to demonstrate eligibility for actual-emissions treatment. The contract and supporting records must identify the relevant EU declarant, generating installation, reporting period and allocated quantity.
The contract documentation must connect the commercial transaction to physical electricity flow and to the records used in the CBAM declaration. Where intermediaries such as aggregators or suppliers sit between the generating plant and EU importer, the verifier is expected to determine whether parties are covered by a single contractual arrangement. A chain of unrelated back-to-back contracts may be insufficient if it does not provide an auditable connection between installation, intermediary and authorised declarant.
Producers and suppliers may need to review trading contracts to preserve that chain for audit purposes. Contract amendments may be required to introduce CBAM-specific installation references, data-access rights, allocation rules, audit provisions and protections against double counting. This requirement applies when existing arrangements do not provide an auditable link from installation-level evidence to declarant-level allocation.
Hourly network congestion checks and cross-border nomination matching
The guidance specifies requirements for physical-delivery conditions used in electricity eligibility assessment. For the condition that no physical network congestion existed 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.
When electricity crosses multiple systems before entering the EU, equivalent evidence may be required from TSOs of transit countries. This is relevant for electricity traded from the Western Balkans where contractual routes can involve multiple bidding zones, borders and market participants. The approach therefore extends congestion evidence beyond single-system transfers.
The nomination requirement is also described as demanding for accepted interconnector nominations. Accepted nominations must document origin, destination and any transit systems. Smart-meter production recorded at the generating installation must correspond to the nominated delivery period, which may not exceed one hour.
The guidance results in an hourly reconciliation chain spanning plant metering, production data, cross-border capacity, accepted nominations, transit arrangements and quantity imported by the authorised EU declarant. Metering and commercial records complete only at monthly or annual level may still fail if they cannot be reconciled for each relevant hour. The process increases emphasis on timestamp consistency, meter hierarchy, missing-data procedures and controls governing corrections to schedules or production records.
Interim reporting cadence and declarant-specific addenda
The Commission clarified interim reporting expectations for verifiers assessing principal electricity eligibility criteria. Verifiers should receive 12 monthly interim reports covering those criteria across each reporting year window. Where there has been no relevant change during a month, a short report confirming “no change” may be accepted.
This approach creates continuous compliance rather than relying on year-end document collection. Producers and intermediaries are expected to run a controlled monthly close covering changes to installation details, contractual arrangements, generation data, cross-border schedules, congestion evidence and allocated import quantities. Exceptions should be identified and resolved while TSO and trading records remain accessible.
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 that declarant’s EORI, confirming relevant eligibility conditions and stating precise quantity imported from the installation. The verifier must assess each addendum separately.
The verification report must include individual confirmation for each declarant-specific addendum. This requirement limits reliance on pooled annual certificate approaches where one producer or aggregator supplies several EU traders. Operators are expected to maintain separate declarant sub-ledgers and controls ensuring that production is not allocated across multiple customers.
Independence between advisory work and accredited assurance
The guidance affects how verification services are structured in practice for CBAM electricity assessments. Unlike models used under the EU Emissions Trading System framework, the CBAM verifier is responsible for assessing 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 from preparatory work they later verify.
In particular, an accredited verifier cannot have supported preparation of the monitoring plan or emissions report that it later verifies under CBAM requirements. Companies therefore need separation between readiness or advisory work and 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 then conducts independent assessment without having created underlying systems used in monitoring and reporting. The guidance notes that using an intended final verifier to design monitoring architecture could create an independence conflict affecting acceptance of verification outcomes. This distinction is especially relevant for companies entering CBAM verification for the first time where they may not yet maintain a single evidence repository connecting technical, contractual, customs and carbon records.
Accreditation scope for activity group LI and Registry access timeline
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 described as separate scope for indirect emissions under CBAM structures. When selecting verifiers, producers and EU declarants need to ensure accreditation scope matches imported-electricity assessment needs rather than relying on general CBAM accreditation or accreditation tied only to other industrial activities.
The Commission guidance highlights an apparent wording inconsistency in one example referencing LI in connection with indirect emissions while identifying LI as imported electricity and LII as indirect emissions in controlling legal text via Delegated Regulation references. Verifier-selection procedures should follow legal text requirements confirming precise activity scope shown on accreditation certificates. Companies should also assess whether prospective verifiers have technical competence and geographic capacity to evaluate 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 for accredited verifiers. 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 of member states where verifiers were accredited.
Verification reports are expected through the Registry from January 2027. For operators and declarants appointing verifiers involves more than checking an accreditation certificate since confirmation is needed that registry registration is completed, digital access is established and connections can be made to relevant installation and declarant records. Readiness testing should cover verifier accreditation scope, O3CI registration status, Registry connection status, installation data flows, monitoring documentation processes, monthly reports handling, declarant-specific addenda preparation and issuance of verification reports.
Implementation considerations for Western Balkan exporters using actual emissions
For Serbian and other Western Balkan exporters seeking actual-emissions treatment under CBAM electricity rules, guidance raises both evidentiary value expectations and operational cost of proving embedded emissions claims. Renewable producers may have commercial advantage if low embedded emissions can be demonstrated for electricity physically imported into the EU through documented interval-level linkage between generation intervals, contractual allocation and cross-border delivery records.
A plant’s renewable status alone does not establish eligibility under these requirements. Guarantees of origin can support parts of an evidence package but cannot replace accepted nominations, border records or installation-level metering used in eligibility assessment chains. The qualifying unit is described as each claimed megawatt-hour within a controlled chain covering installation identity, production data capture timing requirements including hourly production records where applicable scheduling arrangements transmission import allocation processes and independent verification conclusions.
Companies seeking actual emissions are directed toward gap assessments covering five areas: contractual architecture; hourly metering; cross-border evidence; declarant-level allocation; and verifier readiness aligned with activity-group scope requirements for imported electricity verification under LI accreditation rules.
The guidance states that compliance cannot be assembled solely within sustainability functions because it requires integrated operating models covering plant operations including SCADA and metering systems; trading; balancing; legal agreements; customs records; carbon reporting; plus independent assurance activities performed by accredited verifiers meeting independence constraints described in advisory versus assurance separation rules.
The standard described in the guidance requires each claimed megawatt-hour resolve through one named generating installation; one qualifying contractual chain; one accepted physical schedule; one EU importer or declarant; one controlled allocation mechanism; and one independent verification conclusion based on traceable hourly reconciliation elements where required by network congestion evidence conditions nomination matching rules smart-meter correspondence constraints across delivery periods up to one hour.
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