EU Carbon Border Adjustment Mechanism

CBAM Verification

Carbon Border Adjustment Mechanism (CBAM) verification services supporting organizations exporting to the European Union.

Scroll
CBAM

About CBAM

The Carbon Border Adjustment Mechanism (CBAM) is the EU's tool to put a fair price on carbon emitted during the production of carbon-intensive goods entering the EU, encouraging cleaner industrial production in non-EU countries.

The European Climate Law makes the EU target of reducing greenhouse gas emissions by at least 55% by 2030 legally binding. To achieve this and reach climate neutrality by 2050, the EU introduced several complementary mechanisms.

EU Emissions Trading System (EU ETS)

The EU ETS is the internal carbon market where domestic EU producers pay for their carbon emissions. It serves as the benchmark carbon price inside the European Union.

Carbon Border Adjustment Mechanism (CBAM)

CBAM applies a carbon price to imported goods based on embedded CO₂ emissions, ensuring imported goods face the same carbon costs as EU-produced goods.

Scope

Industries Covered

Cement

Iron & Steel

Aluminium

Fertilisers

Electricity

Hydrogen

The 2025 CBAM Package expands CBAM to downstream finished and semi-finished steel and aluminium products.

Implementation

CBAM Periods

1
Period 1

Transitional Phase (1 October 2023 – 31 December 2025)

On 1 October 2023, the CBAM entered into application in its transitional phase, with the first reporting period for importers ending 31 January 2024. The gradual phasing in of CBAM allows for a careful, predictable and proportionate transition for EU and non-EU businesses, as well as for public authorities.

From 1 October 2023 to 31 December 2025, CBAM operated as a transitional reporting system. Importers of covered goods are required to submit quarterly emissions reports via the CBAM Transitional Registry, with no financial obligations or certificates required.

Quarterly reports must be submitted no later than one month after the end of each quarter.
Between October 2023 and June 2024, companies could rely fully on default values. From July 2024 onwards, reporting is expected to be based on actual emissions data where available, while default values remain permitted under certain conditions and subject to increasing limitations.
No independent verification is required during this phase. The reported data (direct and indirect emissions) is used solely for reporting purposes.

The CBAM definitive period will start on 1 January 2026.

2
Period 2

Definitive / Compliance Phase (1 January 2026 – ongoing)

From 1 January 2026, CBAM enters its definitive phase, introducing full financial and compliance obligations.

Importers must purchase and surrender CBAM certificates annually based on reported embedded emissions. Reporting becomes annual and fully compliance-driven before 30 September.
A structured Carbon Emissions Tracking & Reporting Framework is required, defining how emissions data is generated, controlled, and validated within the organization.
Roadmap

CBAM Verification Timeline

Apply
Application Review
Verification Activities
CBAM Registry Submission & Certificate Surrender
Step 1 of 4

Apply

Before 15 November 2026
Step 2 of 4

Application Review

Within 15 Days
Step 3 of 4

Verification Activities

Starting from 1 January 2027
Step 4 of 4

CBAM Registry Submission & Certificate Surrender

Before 30 September 2027
Status

ISSC Accreditation Status

Regulatory Notice
CBAM Verification Accreditation
Application In Progress
1

ISSC is currently applying for CBAM verification accreditation with RvA.

2

All updates will be published in due course.

3

Until full accreditation has been obtained, ISSC shall not claim that it provides CBAM verification services.

4

Any references to accreditation shall be limited solely to the scopes for which ISSC is officially accredited.

Scopes

CBAM Scopes

Calcined clayCement clinkerCementAluminous cement
HydrogenAmmonia
Nitric Acid
UreaMixed fertilizers
Sintered orePig ironDRICrude Steel
Unwrought aluminum
Iron or steel productsAluminum products
Preparation

Before You Apply

Required Documents

Documents req.
01

The latest version of the Monitoring Plan as mentioned in – A.5 – Annex II – (EU) 2025/2547

02

Relevant documentation describing the installation, procedures, processes, or process flowcharts.

03

The Operator Sampling Plan (where applicable).

04

The Operator Emissions Report to be verified.

05

Verification reports relating to precursors used but not produced at the installation.

06

Evidence of the actual production time of precursors (where applicable).

07

Information on embedded direct and indirect emissions for precursors obtained from multiple installations (where applicable).

08

Information on databases and data sources used for monitoring and reporting.

Our Process

Verification Process

1
Pre-Engagement
2
Contract Agreement
3
Monitoring Plan Validation
4
Strategic and Risk Analysis
5
Verification Plan
6
Physical Site Visit
7
Findings and Corrective Actions
8
Independent Review
9
Issue Verification Report
Step 1 of 9

Pre-Engagement

Receive and review the Monitoring Plan.
Receive and review the Emissions Report.
Receive and review the Installation Information.
Receive and review all supporting documents.
Confirm that the verification engagement falls within ISSC's accredited scope.
Confirm that ISSC has the required competence, qualified personnel, resources, and availability to perform the verification.
Based on the pre-engagement review, ISSC will either accept or decline the verification engagement.
Step 2 of 9

Contract Agreement

A contract agreement shall be established between ISSC and the client before commencing the verification activities. The contract defines:

Scope of the verification engagement.
Verification timeline.
Responsibilities of ISSC and the client.
Commercial terms.
Confidentiality requirements.

The contract shall be signed by both ISSC and the client before the verification activities commence.

Step 3 of 9

Monitoring Plan Validation

For operators engaging with ISSC for the first time, the Monitoring Plan shall be validated in accordance with Point A.5 of Annex II to Commission Implementing Regulation (EU) 2025/2547.

The Monitoring Plan shall be re-validated by ISSC in the following cases:

Any nonconformities or recommendations for improvement identified in the previous verification report.
Any modifications to the installation or the Monitoring Plan during the reporting period.

Acceptance of the Monitoring Plan Validation is mandatory before commencing the verification activities.

Step 4 of 9

Strategic and Risk Analysis

Review the verification activities.
Collect and review all relevant information related to the installation and the reported emissions.
Perform a strategic analysis to understand the installation, its processes, and the emission sources.
Assess the inherent risk, control risk, and detection risk associated with the verification activities.
Step 5 of 9

Verification Plan

The ISSC verification team shall develop a Verification Plan that describes:

The test plan, including the methods for testing the effectiveness of control activities.
The data sampling plan, including the data sampling methods and sample selection.
The verification activities to be performed, including their objectives, timing, and estimated time frame.
Step 6 of 9

Physical Site Visit

Following the verification planning, the ISSC verification team will coordinate with the operator to schedule a site visit for conducting the verification activities.

During the site visit, the ISSC verification team may perform the following activities:

Review the implementation of the Monitoring Plan.
Verify activity data and supporting records.
Assess the application of the monitoring methodology.
Perform data sampling and sample testing.
Conduct analytical procedures.
Interview relevant personnel.
Review the operation of control activities.
Perform any additional verification procedures necessary to obtain sufficient and appropriate verification evidence.

In accordance with Regulation (EU) 2025/2546 and Regulation (EU) 2023/956 (CBAM), a physical site visit is generally required as part of the verification process. A physical site visit is mandatory during the first verification year. In subsequent verification years, a virtual site visit or a waiver of the site visit may be applied where permitted by the applicable regulations and where the reliability of the verification is not compromised. Physical site visits shall be conducted at least once every two years.

Step 7 of 9

Findings and Corrective Actions

If the ISSC verification team identifies any misstatements, nonconformities, or non-compliance with Implementing Regulation (EU) 2025/2547 or Implementing Regulation (EU) 2025/2620 during the verification activities, the operator will be informed and requested to implement the necessary corrective actions.

The operator shall submit the corrected information and supporting evidence for review before the verification report is issued.

If the identified findings are not corrected before the verification report is issued, the ISSC verification team shall assess their impact on the reported data and determine whether they result in a material misstatement in accordance with the applicable regulations.

Failure to address findings that result in a material misstatement, or that prevent ISSC from obtaining reasonable assurance, may lead to the issuance of an Unsatisfactory Verification Opinion in accordance with Delegated Regulation (EU) 2025/2551.

Step 8 of 9

Independent Review

Before issuing the Verification Report, ISSC shall assign an independent reviewer who has not participated in the verification activities.

The independent reviewer shall review the verification documentation, verification evidence, and the draft Verification Report to confirm that:

The verification has been performed in accordance with the applicable requirements.
Sufficient and appropriate verification evidence has been obtained.
The verification conclusions are supported by the evidence.
The Verification Report is suitable for issuing a Reasonable Assurance Opinion.

Only after the independent review has been successfully completed shall the Verification Report be issued.

Step 9 of 9

Issue Verification Report

Upon completion of the verification process and the independent review, ISSC shall issue a Verification Report with either a Satisfactory or Unsatisfactory Verification Opinion.

Where the operator is registered in the CBAM Registry in accordance with Regulation (EU) 2023/956, the Verification Report shall be submitted through the CBAM Registry.
Where the operator is not registered in the CBAM Registry, ISSC shall provide the Verification Report to the operator in its original electronic format and a copy in a standard electronic document format for information purposes.
Download Pre-Engagement Form

Ready for CBAM Verification?

Contact ISSC to discuss your CBAM verification requirements and prepare for EU compliance.

Contact Us
Documentation

ISSC Policies

Official governing policies for ISSC's validation and verification activities.

ISSC undertakes its validation and verification activities with impartiality.

ISSC is responsible for the impartiality of its validation and verification activities and does not allow commercial, financial, or other pressures to compromise impartiality. ISSC monitors its activities and relationships to identify threats to impartiality and eliminates or minimizes their effect.

Support

Appeal & Complaints

Formal procedures for raising and resolving concerns about ISSC's verification decisions.

Process

Complaint and Appeal Process

Complaints and appeals can be submitted in writing (a formal letter, email, or through the website) or verbally (a phone call, feedback during a sales visit, or during an audit). Complaints are managed at the contracting entity level within ISSC; where needed, an audit may be scheduled to investigate, and the client will be informed of the reason for any additional audit.

Timeframe

Response & Resolution

An initial response is sent within five working days of receiving the complaint or appeal, with full closure within 90 days of receipt. If the client is not satisfied with the outcome, or the issue remains unresolved, they may contact the Accreditation Body for further action.

Contact Us

Get In Touch With Our Team

Have a question about certification or verification? Reach out and our Egypt team will get back to you.

Contact Information

Reach our Egypt office directly, or send a message and we'll respond promptly.

Office Address
Block H6, Ibn Melka St, First Settlement, Cairo, Egypt
Email
Egypt@theissc.com
Phone
+20 150 599 9929
Working Hours
Sunday – Thursday, 9:00 AM – 5:00 PM