For Malaysian producers whose EU customers intend to use actual emissions values under CBAM, preparing a calculation is only part of the task. Those values must also be verified by an independent verifier accredited for CBAM by an EU national accreditation body.
The European Commission explains why these two concepts: verification and accreditation, are connected but different. Understanding the distinction helps producers select the right support, prepare evidence and avoid leaving an essential step until the annual deadline.
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Verification checks the data; accreditation checks the verifier
Verification is the independent assessment of emissions information supplied by the producer. Accreditation is the formal authorisation that allows the verifier to perform that work under the CBAM framework.
The Commission explains that accredited verifiers assess the monitoring approach, emissions calculations and supporting evidence. Their role is to provide reasonable assurance that the calculation of embedded emissions is correct. National accreditation bodies oversee the verifiers’ competence and performance.
The distinction matters commercially. A service provider may offer emissions calculations, advisory work or other forms of assurance without necessarily holding the relevant CBAM accreditation. Producers should verify the provider’s status and scope instead of relying on a general sustainability credential.
When is verification required?
Actual emissions values require verification, while default values do not require that verification of actual emissions. Businesses must still apply the correct reporting and calculation rules for their particular goods, including any special conditions for electricity.
Actual values may be commercially advantageous where they accurately reflect a producer’s performance, but they are not a guarantee of lower costs in every case. A business should compare the applicable default approach with the effort, evidence and verification needed for actual values before deciding with its EU customer.
Who does what?
- The non-EU producer monitors and calculates embedded emissions under the CBAM methodology and supplies the information and evidence needed for assessment.
- The accredited verifier independently reviews the monitoring approach, calculations and evidence, then issues a verification report.
- The authorised CBAM declarant uses the relevant verified information for its annual declaration and remains responsible for its compliance obligations.
- The national accreditation body assesses and oversees the verifier; it is not the producer’s outsourced emissions-calculation team.
These roles form the Commission’s verification framework. CBAM verification applies at production-installation level, so businesses with multiple sites should establish which installation and report relate to each set of goods.
Prepare a traceable evidence package
Producers need emissions data and supporting evidence. The Commission’s guidance further identifies the monitoring approach and emissions calculations as part of the verifier’s review.
A practical preparation file should bring together the relevant calculation methodology, production information, source records, assumptions, data responsibilities and version history. The exact evidence will depend on the installation, goods and applicable methodology; this is not a universal statutory checklist.
Check whether a reviewer can follow a reported figure back to its source. Where information has been estimated, corrected or allocated between processes, document the basis and ask the verifier what additional evidence is needed.
Select the verifier carefully
The Commission states that CBAM verifiers must be accredited by EU national accreditation bodies. A verification company established outside the EU may apply to a national accreditation body offering the relevant service; the verifier’s location alone is therefore not the test of eligibility.
Before appointment, request confirmation of current CBAM accreditation, relevant scope, independence, timetable, fees and deliverables. Clarify the installation coverage and any site-visit arrangements directly with the verifier under the applicable rules.
Budget time as well as money
Verification is not free of charge. The Commission warns businesses not to wait until the last minute, noting expected pressure on verifier availability ahead of the 30 September deadline.
For the first declaration covering 2026 imports, agree a timetable that allows data preparation, review, any required visits, correction of findings and delivery to the EU customer before 30 September 2027. The Commission’s published implementation timeline envisages first verification reports being issued from January 2027.
If availability is a problem, the Commission recommends seeking guidance from the relevant competent authority or national accreditation body. Malaysian producers should coordinate this with their EU customer to identify the appropriate EU contacts; unavailable capacity should not be treated as an automatic exemption.
Make verification part of readiness from the start
The most effective preparation is to decide the reporting approach with the customer early, establish a traceable evidence base and confirm a suitable verifier. Accreditation establishes who can assess the data; good records make that assessment possible. Both are necessary when actual emissions values are intended for the declaration.
Move forward with a clearer plan
Whether your business is beginning its CBAM assessment or reviewing an existing approach, take the opportunity to clarify responsibilities, identify outstanding questions and set your preparation priorities.
Reach out to Bernard Business Consulting Sdn. Bhd. to discuss where your business stands and what you want to achieve. Let’s explore how we can support a more structured approach to your CBAM preparation.
