Who Needs CBAM Verifier Accreditation?
Importers, verifiers, and national authorities explained
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Article Section
Introduction
A compliance officer at an EU trading company recently spent two weeks researching "CBAM accreditation," assuming her firm needed to apply for it directly. Her company was a declarant, not a verifier, and did not need accreditation at all.
This confusion is common. Verifier access to the CBAM Registry opened in September 2026, and the word "accreditation" now appears throughout CBAM guidance, often without explaining who it actually applies to.
This article breaks down exactly which entities in the CBAM chain need accreditation, which simply need to comply, and how the two obligations differ.
Article Section
The Three Roles in CBAM
CBAM involves three distinct roles, and each carries a different obligation. A declarant is the EU-based importer of record who reports embedded emissions and, from 2027, purchases CBAM certificates; this obligation is defined under Regulation (EU) 2023/956. A verifier is an independent body that checks the accuracy of a declarant's emissions data before it is submitted; verifiers operate under accreditation rules set out in Regulation (EU) 2025/2083. A National Competent Authority, or NCA, is the government body in each EU member state responsible for enforcing CBAM obligations and overseeing accreditation within its jurisdiction.
Accreditation, specifically, is a formal status granted to an organisation confirming it is competent to perform CBAM emissions verification. It is not a status that applies to declarants or to NCAs, only to verifiers. Understanding this distinction early prevents companies from pursuing a process that does not apply to them.
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Who Needs Accreditation, and Who Doesn't?
Who Needs Accreditation?
Only organisations intending to operate as CBAM verifiers need accreditation. This typically means specialised auditing and certification bodies that already perform similar verification work under schemes such as the EU Emissions Trading System. Accreditation, granted by a national accreditation body under Regulation (EU) 2025/2083, confirms that the verifier meets the technical competence and independence standards required to check embedded emissions data. Without it, a verifier's sign-off carries no standing under CBAM.
Who Complies Without Being Accredited?
Declarants, the EU importers bringing CBAM goods into the bloc, never seek accreditation themselves. Their obligation is different: report embedded emissions accurately, using data checked by an accredited verifier, and from 2027 hold enough CBAM certificates to cover those emissions. A declarant's task is to select a verifier that already holds accreditation, not to become one.
Where National Competent Authorities Fit?
NCAs sit above both roles. Each EU member state designates an NCA responsible for enforcing declarant obligations and, working with the national accreditation body, overseeing which verifiers hold valid accreditation. NCAs do not perform verification themselves; they authorise declarants, monitor compliance, and can act against a declarant working with an unaccredited verifier.
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What This Means in Practice?
The Most Common Mistake
The most frequent error is a declarant assuming CBAM accreditation is something its own company must pursue. It is not. If a company's role is importing CBAM goods into the EU, its task is selecting a properly accredited verifier, not applying for accreditation itself.
How to Confirm a Verifier Is Accredited?
Before engaging a verifier, declarants should confirm the verifier's accreditation status with the relevant national accreditation body rather than relying on the verifier's own claims. Accreditation is jurisdiction-specific, so a verifier accredited in one member state is not automatically valid EU-wide unless recognised accordingly.
What This Clarity Should Shape Next?
Once a declarant understands it needs to select rather than become a verifier, the next practical step is identifying and engaging an accredited verifier ahead of upcoming reporting obligations.
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Conclusion
The core distinction in CBAM verification is simple even though the terminology is not: accreditation is a verifier obligation, not a universal one. Declarants, NCAs, and verifiers each carry separate responsibilities, and conflating them leads to wasted effort on the wrong process.
For most companies reading this because they import CBAM goods, the practical next step is not seeking accreditation. It is engaging a verifier who already holds it.
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Frequently Asked Questions
Who needs CBAM verifier accreditation?
Only organisations that intend to operate as CBAM verifiers need accreditation, not declarants or importers.
What is the difference between a CBAM declarant and a CBAM verifier?
A declarant is the EU importer reporting and paying for embedded emissions, while a verifier is the independent body that checks the accuracy of that emissions data.
Do importers need to be accredited under CBAM?
No, importers acting as declarants engage an accredited verifier rather than seeking accreditation themselves.
Who grants CBAM verifier accreditation?
National accreditation bodies grant verifier accreditation under Regulation (EU) 2025/2083.
What role do National Competent Authorities play in CBAM verification?
National Competent Authorities enforce declarant obligations and oversee accreditation within their jurisdiction, without performing verification themselves.
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