On 24 August 2026, the European Commission published new guidance for CBAM verifiers and accreditation bodies. Under the same regulation’s timeline, verifier access to the CBAM registry opened from 1 September 2026. It looks like a technical administrative step, but it directly concerns any Turkish manufacturer selling iron and steel, aluminium, cement or fertiliser into the EU: on the other end of this system, the bodies that will verify your facility’s actual emissions data are now lining up.
This article lays out plainly what changed, which dates are binding, and what an exporter should have on hand while this process matures.
The topic sounds bureaucratic at first glance, but the practical consequence is concrete: as the verification infrastructure matures, EU buyers will increasingly ask their suppliers for actual, verified emissions data rather than default estimates. Today, meeting that request with default values is still workable; within a few years, verified data will stop being optional for a manufacturer that wants to stay competitive.
CBAM’s definitive period: a quick recap
The EU Carbon Border Adjustment Mechanism (CBAM) has been in its definitive period since 1 January 2026. Scope is limited to six sectors: cement, iron and steel, aluminium, fertiliser, electricity and hydrogen. Importers bringing these goods into the EU must declare the embedded emissions from the production process and, over time, purchase certificates against them.
The simplification package that entered into force at the end of 2025 — the Commission’s so-called “Omnibus” package, formally Regulation (EU) 2025/2083 — eased this burden for smaller-volume importers: businesses importing under 50 tonnes a year of CBAM-covered goods are fully exempt from declaration. The declaration cycle also moved from quarterly to annual; the first annual declaration, covering 2026 imports, is due 30 September 2027, and the obligation to purchase certificates starts from February 2027.
Why the verifier process was overdue
CBAM’s system runs on two kinds of data: the Commission’s default values, or your own facility’s actual, verified emissions data. Default values generally reflect a sector average and often come out higher than your real performance — if your facility runs more energy-efficiently than average, using your own verified data works in your favour.
But the right to use your own data depends on an independent body confirming it. The CBAM Regulation defines these bodies as accredited verifiers — an adaptation of the verification logic already used in the EU’s emissions trading system (ETS). A verifier isn’t a specific major audit firm or a single company; it can be any body accredited by a national accreditation authority under the EU’s accreditation framework in any member state. Until now, the problem was that the official registration and operating infrastructure for these verifiers simply wasn’t ready — even exporters who wanted to declare with real data had to wait for it.
What September 2026 changed
The Commission’s 24 August 2026 guidance, together with its accompanying timeline, clarified the following:
| Step | Date |
|---|---|
| Accredited verifiers gain access to the CBAM registry | From 1 September 2026 |
| First verifiers expected to receive accreditation | Autumn 2026 |
| Verifiers begin publishing verification reports in the registry | From January 2027 |
| Importers can declare using actual verified data | From the 2027 declaration cycle |
The practical takeaway: a Turkish manufacturer can start preparing for verification today, but actually working with a verifier and obtaining a verified report will only become viable from autumn 2026 onward, maturing into a properly functioning mechanism closer to 2027. Dates and the list of accredited bodies are updated regularly, so confirm the current accreditation list from the official EU source before selecting a verifier.
The 50-tonne threshold and the annual declaration deadline
Before the verifier question even comes up, every exporter needs to be clear on where they stand:
- If your annual volume of CBAM-covered goods sold into the EU is under 50 tonnes — you fall under the exemption; no declaration or verification obligation arises. Your buyer may still ask for emissions data as a matter of internal policy, but that is a commercial request, not a legal one.
- If you’re above 50 tonnes — your EU buyer (the authorised declarant) files the declaration, not you; but the emissions figure inside that declaration comes from your facility. Whether it’s a default value or verified actual data is usually a decision the buyer and manufacturer make together.
- The first annual declaration is due 30 September 2027, covering 2026 imports. That means a manufacturer needs to start keeping emissions records for goods produced throughout 2026 now — reconstructing that data retroactively once the deadline arrives is far harder.
What exporters and manufacturers should prepare now
While the verification infrastructure is still maturing, the core data set you need doesn’t change:
- Product-level, in-facility emissions records — which production line, which energy source, how much emissions per unit of output (direct plus specific input emissions).
- Energy consumption data — electricity, gas and fuel consumption linked to production volume; supporting this with metering and machine-to-machine (M2M) data shortens the verification process later.
- Methodology documentation — a written record of which calculation method you use (GHG Protocol, ISO 14064-aligned). A verifier examines the method, not just the result.
- Supply chain data — if your input materials carry their own emissions load (e.g. primary raw material in aluminium), that data needs to be traceable too.
Keeping this in scattered spreadsheets gets you by in the short term, but once an accredited verifier is involved, traceability and consistency are what’s actually checked. Building an unbroken chain from the data source (meter, PLC, ERP) to the verification report both speeds up the process and reduces risk in future audits.
Timing matters too: finding a verifier and getting a report isn’t something that closes in a day. Site visits, data sampling and report writing can take weeks. Given the first annual declaration lands on 30 September 2027, starting to look for a verifier in the first quarter of 2027 means starting late — the more ready your data infrastructure is, the shorter the verification itself takes.
How İkiz Eksen approaches this
İkiz Eksen works exactly at this intersection: measuring energy and production data on the shop floor, moving it into your ERP and automation layer on the digital transition side, and building CBAM-aligned emissions calculation and reporting infrastructure on the green transition side. The goal is that when a verifier gets involved, you already have a consistent, traceable data set — not a last-minute scramble.
You can see the scope and working model on our dedicated CBAM service page, or reach out through the contact form to discuss your product codes and export profile.
Frequently asked questions
Do I need to choose a verifier right now?
No. The working registry infrastructure for accredited verifiers opens from September 2026, and a properly functioning process settles in closer to 2027. But keeping your facility data consistent now shortens the process once you do engage a verifier.
If I’m under 50 tonnes, can I ignore CBAM entirely?
You have no legal declaration obligation. But your export volume may grow over time, or your buyer may still request data for their own internal reporting — being under the threshold doesn’t mean the topic disappears entirely.
Is verified actual data always better than the default value?
It depends. If your facility runs more efficiently than the sector average, verified actual data typically produces a lower emissions figure — and therefore a lower cost for the buyer. If your efficiency is below average, the default value may be more favourable in the short term.
Who pays for the verification process?
That depends on the commercial agreement between the parties; the CBAM Regulation doesn’t set this. In practice, cost-sharing arrangements between manufacturer, exporter and EU buyer vary.
Could these dates change again?
Yes — CBAM’s implementation timeline has been revised more than once over the past two years. Confirm current dates on the European Commission’s official CBAM page before making an application or a decision.