The European Commission has issued dedicated CBAM guidance on verification and accreditation for electricity imports, followed by new Registry manuals for accredited verifiers. The first set of guidance was published on August 24, with the Registry manuals dated August 27–28. The documents do not amend the CBAM Regulation, but they set out how verifiers are expected to assess claims for using actual embedded emissions for imported electricity.
The guidance is aimed at 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 approach will extend beyond providing a power purchase agreement or a guarantee of origin. Instead, each claimed megawatt-hour must be traceable through multiple specified elements.
Traceability requirements for actual embedded emissions claims
The Commission’s guidance describes how accredited verifiers will examine electricity imported into the EU under the actual embedded emissions approach. It 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. The documents also reference that proposed changes to the electricity provisions, including possible retroactive adjustments, remain under legislative consideration.
The Commission said those proposed changes were not incorporated into the new guidance. As a result, the existing five conditions in Section 5 of Annex IV remain the working basis for electricity imported during 2026. The guidance therefore sets out how evidence will be checked against those existing conditions rather than altering them.
Power purchase agreements as evidence under verifier checks
A central clarification concerns what verifiers are expected to check when a power purchase agreement is used as part of the evidence package. The verifier is expected to confirm the authorised CBAM declarant’s EORI, alongside the producer’s unique CBAM Installation ID, the reporting period and contracted quantity. The verification also requires supporting invoices or delivery records.
The verifier must also establish that controls prevent the same electricity from being claimed more than once. The Commission’s guidance indicates that a commercial agreement between a producer and trader does not, by itself, constitute sufficient evidence that the electricity qualifies for actual-emissions treatment. Contractual documentation therefore needs to connect the commercial transaction to physical flows and to records used in the CBAM declaration.
Where intermediaries such as aggregators or suppliers sit between the generating plant and an EU importer, the guidance indicates that verifiers should determine whether parties are covered by a single contractual arrangement. It states 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 may need contract amendments covering CBAM-specific installation references, data-access rights, allocation rules, audit provisions and protections against double counting.
Hourly network and nomination evidence for cross-border delivery
The guidance specifies additional detail on physical-delivery conditions relevant to whether network congestion existed between a generating installation and an EU destination. For this requirement, 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 notes that equivalent evidence may be required from TSOs of transit countries when electricity crosses several systems before entering the EU. This is described as material for electricity traded from the Western Balkans because routes may involve multiple bidding zones, borders and market participants. In addition to congestion evidence, interconnector nominations must document origin, destination and any transit systems.
The nomination requirement includes smart-meter production recorded at the generating installation corresponding to the nominated delivery period. The delivery period may not exceed one hour. The guidance describes this as producing an hourly reconciliation chain covering plant metering, production data, cross-border capacity, accepted nominations, transit arrangements and the quantity imported by the authorised EU declarant.
It further 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. The approach increases coordination among producers, balance-responsible parties, traders, TSOs and EU importers while placing weight on timestamp consistency, meter hierarchy, missing-data procedures and controls governing corrections to schedules or production records. It also clarifies that guarantees of origin may support evidence but cannot replace accepted nominations, border records or installation-level metering.
Monthly interim reporting and declarant-specific addenda
The Commission has clarified interim reporting expectations for verifiers assessing eligibility criteria for imported electricity. It states that verifiers should receive 12 monthly interim reports covering principal eligibility criteria. Where there has been no relevant change during a month, a short report confirming “no change” may be accepted.
The guidance describes this as creating continuous compliance rather than relying on year-end document collection. Producers and intermediaries are expected to maintain controlled monthly close procedures covering changes to installations, contractual arrangements, generation data, cross-border schedules, congestion evidence and allocated import quantities while TSO and trading records remain accessible. It also states that waiting until end of year could leave gaps difficult to reconstruct and could lead a verifier to reject part of claimed electricity.
Each authorised CBAM declarant must receive a declarant-specific addendum identifying the declarant’s EORI, confirming relevant eligibility conditions and stating precise quantity imported from each installation. The verifier must assess each addendum separately and provide individual confirmation for each declarant-specific addendum in its verification report. The guidance indicates this requirement limits reliance on pooled annual certificates where one producer or aggregator supplies several EU traders.
Separation of advisory work from independent assurance
The guidance addresses how responsibilities should be structured within verification arrangements. It states that unlike the EU Emissions Trading System model, 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, it requires accredited verifiers to 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 are therefore expected 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 while leaving independent assessment to the accredited verifier without having created underlying systems.
Accreditation scope for imported electricity in activity group LI
The Commission’s 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 that activity group LII is separate scope for indirect emissions. This distinction affects how producers and EU declarants select verifiers because general CBAM accreditation does not automatically establish qualification for assessing imported electricity.
The guidance notes an example wording inconsistency referring to LI in connection with indirect emissions while citing that controlling delegated regulation identifies LI as imported electricity and LII as indirect emissions. Verifier-selection procedures should therefore follow legal text and confirm precise activity scope shown on accreditation certificates. Companies are also expected to examine prospective verifiers’ technical competence and geographic capacity to assess cross-border evidence including records obtained from non-EU producers, traders and transmission operators.
Registry access timeline for accredited verifiers
The Commission has begun operationalising verifier access to the CBAM Registry with registration opening from September 1, 2026. Accredited verifiers can start registering from that date and must complete registration within two months of accreditation completion. They are required to submit an accreditation certificate plus corporate and representative documentation through the EU’s O3CI access system.
Applications are handled through national competent authorities 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, appointment involves more than checking an accreditation certificate because confirmation is needed that Registry registration is completed and digital access is established for connections to relevant installation and declarant records.
Implementation requirements highlighted for Western Balkan exporters
The guidance raises both value and operational cost of proving actual embedded emissions for Serbian and other Western Balkan exporters seeking actual-emissions treatment in CBAM declarations. It states that renewable producers may have commercial advantage if they can demonstrate low embedded emissions for electricity physically imported into the EU. However it links any advantage to evidence connecting individual generation intervals with contractual allocation and cross-border delivery.
A plant’s renewable status alone is not presented as sufficient evidence under this approach in place of interval-level traceability requirements described in the guidance. Nor does it treat annual guarantees of origin or portfolio-level claims as replacements for interval-based traceability elements such as accepted nominations or installation-level metering. It describes qualifying units as claimed megawatt-hours within a controlled chain covering installation identity, production scheduling transmission import allocation and verification.
The Commission indicates companies seeking actual-emissions treatment should begin with gap assessment across five areas: contractual architecture; hourly metering; cross-border evidence; declarant-level allocation; and verifier readiness. It also states that 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; and independent assurance.
The standard described in the guidance requires each claimed megawatt-hour to resolve into 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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