The European Commission has issued dedicated guidance on verification and accreditation under the Carbon Border Adjustment Mechanism (CBAM), published on August 24, with additional Registry manuals for accredited verifiers released on August 27–28. The documents do not amend the CBAM Regulation. They outline how accredited verifiers will assess claims for imported electricity qualifying for 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.
The Commission said the operating standard extends beyond providing a power purchase agreement or a guarantee of origin. Each claimed megawatt-hour must be traced through a named generating installation, a qualifying contractual arrangement, hourly production records, accepted cross-border nominations, the EU importer and independently verified allocation. The Commission also stated that proposed changes to electricity provisions, including possible retroactive adjustments, remained under legislative consideration and were not included in the new guidance. For electricity imported during 2026, five conditions in Section 5 of Annex IV remain the working basis.
PPA evidence requirements for CBAM declarants
The guidance specifies what verifiers must check when assessing evidence linked to a power purchase agreement. A verifier is expected to confirm the authorised CBAM declarant’s Economic Operators Registration and Identification number (EORI) and the producer’s unique CBAM Installation ID. It also covers the reporting period, contracted electricity quantity and supporting invoices or delivery records. Verification must include controls demonstrating that the same electricity is not claimed more than once.
This affects how parties use contract documentation in practice. A commercial agreement between a producer and trader is not sufficient by itself to support actual-emissions treatment. The contract and supporting records must identify the relevant EU declarant, generating installation, reporting period and allocated quantity. They must also connect the commercial transaction to physical electricity flows and to the records used in the CBAM declaration.
Where intermediaries such as aggregators or suppliers sit between the generating plant and the EU importer, the verifier’s assessment becomes more detailed. The Commission’s guidance indicates that verifiers should determine whether parties are covered by a single contractual arrangement. It says chains of unrelated back-to-back contracts may be insufficient if they do not provide an auditable link between the installation, intermediary and authorised declarant. Producers and suppliers may need contract amendments covering CBAM-specific installation references, data-access rights, allocation rules, audit provisions and protections against double counting.
Hourly network congestion and nomination checks
The guidance also tightens requirements tied to physical delivery conditions. For ensuring no physical network congestion existed between the generating installation and the EU destination, written evidence from transmission system operators should demonstrate on an hourly basis that network conditions permitted the claimed transfer. Where available evidence is unclear, a verifier may seek confirmation directly from the relevant TSO and obtain a timestamped congestion report where possible. For routes crossing multiple systems before entering the EU, equivalent evidence may be required from TSOs of transit countries.
This point is described as material for electricity traded from the Western Balkans because contractual routes can involve multiple bidding zones, borders and market participants. The nomination requirement is also described as demanding: accepted interconnector 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 result is an hourly reconciliation chain covering plant metering, production data, cross-border capacity, accepted nominations, transit arrangements and quantities imported by an authorised EU declarant.
The guidance states that metering and commercial records complete only at monthly or annual level may still fail if they cannot be reconciled for each relevant hour. It notes this will require closer coordination among producers, balance-responsible parties, traders, TSOs and EU importers. It also increases emphasis on timestamp consistency, meter hierarchy, missing-data procedures and controls governing corrections to schedules or production records. It further states that guarantees of origin can support an evidence package but cannot replace accepted nominations, border records or installation-level metering.
Monthly interim reporting and declarant-specific addenda
The Commission clarified interim reporting expectations under CBAM verification for electricity imports. 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 conduct a controlled monthly close covering changes to installations, 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 after the end of the reporting year could leave gaps that are difficult to reconstruct and may lead verifiers to reject part of claimed electricity.
The guidance requires each authorised CBAM declarant to receive a declarant-specific addendum identifying that declarant’s EORI, confirming relevant eligibility conditions and stating the precise quantity imported from each installation . Verifiers must assess each addendum separately and provide individual confirmation for each declarant-specific addendum in their verification report . The Commission says this requirement effectively rules out reliance on a single pooled annual certificate where one producer or aggregator supplies multiple EU traders.
Independence rules for advisory versus assurance work
The guidance also addresses how responsibilities are split within CBAM verification workstreams. Unlike an EU Emissions Trading System model where roles differ by design, it states that the CBAM 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.
In particular, it says an accredited verifier cannot have supported preparation of the monitoring plan or emissions report that it later verifies . Companies therefore need to separate readiness and advisory work from final accredited verification activities . It describes that a pre-verification provider may help design monitoring plans, evidence repositories, contractual controls, reporting procedures and corrective-action programmes while leaving independent assessment to the accredited verifier without having created underlying systems.
Accreditation scope for imported electricity
The Commission guidance 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.” It states activity group LII is separate scope for indirect emissions . The distinction matters when selecting verifiers because general CBAM accreditation does not automatically establish qualification for imported electricity assessments.
The guidance notes an apparent wording inconsistency in one example referring to LI in connection with indirect emissions but points to a controlling Delegated Regulation identifying 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 advised to check whether prospective verifiers have technical competence and geographic capacity to assess cross-border electricity evidence obtained from non-EU producers, traders and transmission operators.
CBAM Registry access timeline starting September 2026
The Commission has begun operationalising verifier access to the CBAM Registry. Accredited verifiers can start registering from September 1, 2026 and must complete registration within two months of accreditation . They need to submit an accreditation certificate plus corporate and representative documentation through the EU’s O3CI access system . Applications are handled through the national competent authority of the EU member state where each verifier was accredited.
Verification reports are expected to be issued through the Registry from January 2027 . For operators and declarants appointing verifiers, this involves more than checking an accreditation certificate; they also need confirmation that registry registration is completed with necessary digital access established. The readiness process described includes testing verifier accreditation scope, O3CI registration status, Registry connection capability, installation data availability, monitoring documentation readiness, monthly reports delivery flow, declarant-specific addenda handling and issuance of verification reports .
Western Balkan exporters face higher proof requirements
For Serbian and other Western Balkan exporters using actual emissions treatment under CBAM electricity rules, the guidance raises both evidentiary value expectations and operational costs of proof . Renewable producers may have commercial advantage if they can demonstrate low embedded emissions for electricity physically imported into the EU. However it depends on evidence linking individual generation intervals to contractual allocation and cross-border delivery .
The guidance states that renewable status alone is not enough. It also says annual guarantees of origin are insufficient by themselves when used as substitutes for required interval-level tracing through contractual allocation chains . It describes qualifying units as claimed megawatt-hours within controlled chains covering installation identity, production scheduling arrangements transmission flows import steps allocation processes and verification outcomes .
It says companies seeking actual emissions treatment should start with a gap assessment across five areas: contractual architecture; hourly metering; cross-border evidence; declarant-level allocation; and verifier readiness . It further states compliance cannot be assembled solely by a sustainability department because it requires an integrated operating model covering plant operations including SCADA and metering; trading; balancing; legal agreements; customs records; carbon reporting; plus independent assurance . The standard described remains that every claimed megawatt-hour must resolve to one named installation; one qualifying contractual chain; one accepted physical schedule; one EU importer or declarant; one controlled allocation; and one independent verification conclusion .
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