Facts checked on 11 October 2026 against EUR-Lex and the European Commission’s CBAM pages.
A CBAM monitoring plan is the written rule book an installation outside the EU keeps for working out the emissions embedded in the goods it sells into the EU. Commission Implementing Regulation (EU) 2025/2547 requires a plan from every operator that reports actual emissions. The plan holds at least the 22 elements listed in point A.5 of its Annex II and is submitted in English. No authority approves the plan. The accredited verifier assesses it, usually during the annual verification, and then checks the operator’s emissions report against it.
The plan matters now because 2026 is the first year that needs verification. Accredited verifiers have been able to apply for registration in the CBAM Registry since 1 September 2026 and can issue the first verification reports from January 2027. EU importers file the first CBAM declaration, covering goods imported in 2026, by 30 September 2027. An importer without verified actual data uses default values, which carry a mark-up of 10% for 2026 on iron and steel, aluminium, cement and hydrogen.
Key takeaways
- Any installation whose actual emissions an EU importer wants to use needs a monitoring plan. Without one, the importer falls back on default values.
- The plan holds at least 22 elements, from the goods and production processes to a control system for data quality, and is written in English.
- The Commission offers no ready-made electronic template. Its Guidance No. 3 reproduces the legal list as a template that operators may adapt.
- The verifier assesses the plan and judges the year’s emissions report against it. A verifier that helped draft the plan may not verify it.
- Records stay at the installation for at least six years after the reporting period, up from four years in the transitional period.
- On 7 October 2026, seven EU national accreditation bodies were accepting verifier applications from outside the EU. The Commission’s list of accredited verifiers was not yet published on 11 October 2026.
What is a CBAM monitoring plan?
The monitoring plan sets down, for one installation, how each figure behind its embedded emissions is measured or calculated, who handles the data and how errors are caught. Article 5 of the regulation makes it the basis of monitoring in CBAM’s definitive period, which began on 1 January 2026. The Commission’s Guidance No. 3 calls the plan a “rule book” for the operator’s staff and advises keeping it as a single document, comparable to the monitoring plan of the EU Emissions Trading System. It also calls the plan a living document, to be reviewed at least once a year and whenever the installation changes significantly.
The duty falls on the operator of the installation that makes the goods, such as a steel mill, an aluminium smelter, a cement works or a fertiliser plant. Guidance No. 1 states that operators outside the EU “are not obliged to carry out any activities under the CBAM”. An operator that wants its EU customers to use its own figures instead of default values has to monitor under these rules, starting with the plan.
| Document | What it holds | Prepared by | When |
|---|---|---|---|
| Monitoring plan | The installation’s monitoring methods, data flows and controls. At least the 22 elements of Annex II, point A.5 | Operator | Before monitoring starts, then kept up to date |
| Operator’s emissions report | The year’s embedded emissions per good. A summary for declarants and, for imported electricity, an addendum per declarant | Operator | After the calendar year ends |
| Verification report | The verifier’s opinion on whether the emissions report is free of material misstatement | Accredited verifier | From January of the following year |
The Commission’s Excel file is a template for the emissions report, not for the monitoring plan. Its CBAM Questions and Answers say that using the Excel file “is not compulsory but recommended”. What the law fixes is the content. The report must hold at least the information listed in points 1.1 and 1.2 of Annex IV, and point 1.1 includes a summary of the monitoring plan.
What must a CBAM monitoring plan contain?
A CBAM monitoring plan must contain at least the 22 elements listed in point A.5 of Annex II to Regulation 2025/2547. The regulation introduces the list as a “template containing the minimum elements to be contained in the monitoring plan”. The elements run from the date and version number through goods, production processes, monitoring methods and system boundaries to a control system for data quality. They fall into four groups.
| Group | Elements | What the plan sets out |
|---|---|---|
| Identity and scope | 1 to 6 | Date and version number. A description of the installation and its production processes. The goods made, by CN code and functional unit, with clinker or nitrogen content where relevant. The production processes and routes, and the goods from each. Any non-CBAM goods per process. The CBAM benchmarks used for the free allocation adjustment. |
| Monitoring methods | 7 to 12 | The method for each production process: the calculation formulae and input data, or the measurement systems and where each instrument sits. How calculation factors are found, with the sampling plan. The source streams and emission sources of each process. The source streams under the standard or mass balance method. The emission sources measured directly. Perfluorocarbons from primary aluminium. |
| Boundaries and flows | 13 to 21 | A diagram of the installation and its process boundaries that shows neither double counting nor data gaps. Precursors per process, with the name and country of each outside supplier. Zero-rated fuels. Measurable heat imported or exported. Electricity made on site. The evidence for actual indirect emissions and for imported electricity. Waste gases. CO2 capture, storage or use. |
| Control system | 22 | Calibration of measuring equipment. A risk assessment of the data flow. Quality assurance of IT systems. Segregation of duties and staff competence. Internal review, corrections and control of outsourced work. Records with document versions. |
Other parts of Annex II add to the list. The plan also records the chosen data sources and any corroborating sources, the standard values used and the methods for precursor data. Wherever a better method is technically not feasible or would cost too much, the plan carries a written justification.
Element 6 feeds the free allocation adjustment, explained in CBAM Free Allocation Adjustment in 2026, Explained.
What changes by sector
| Sector | Functional unit | What the plan adds | Indirect emissions |
|---|---|---|---|
| Cement | Tonnes of clinker contained, for cement and clinker | Carbonate emissions by whichever of the two methods is more accurate | Included |
| Fertilisers | Kilograms of nitrogen contained, for nitric acid, ammonia and CN 3105 | Nitrous oxide from nitric acid production measured continuously; goods differing only in concentration grouped in one process | Included |
| Iron and steel | Tonnes per CN code | Mass balance for pig iron, direct reduced iron, crude steel and ferro-alloys; goods differing only in size or shape grouped in one process | Not included, except for sintered ore |
| Aluminium | Tonnes per CN code | Perfluorocarbons from primary aluminium (element 12), by one of two methods; the same grouping rule as steel | Not included |
| Hydrogen | Tonnes of hydrogen | The production route, such as steam reforming | Not included |
| Electricity | Kilowatt hours | The evidence for actual emissions of the electricity imported; the reporting period is the year of import | Not applicable |
The cost test, with an example
Annex II sets a cost test for keeping a less accurate method. A better method costs too much only where its cost exceeds its benefit. The benefit is an improvement factor multiplied by a reference price of EUR 80 per tonne of CO2e. The improvement factor is the gain in measurement uncertainty, in %, multiplied by the related emissions over the reporting period. Where accuracy does not change, it is 1% of the related emissions. Spending on better monitoring up to EUR 4,000 a year in total never counts as unreasonable.
Example. A fuel line accounts for 50,000 t CO2e a year. A new flow meter would cut its measurement uncertainty from 2.5% to 1.5%, a gain of 1 percentage point. The improvement factor is 1% of 50,000 t, which is 500 t, and the benefit is 500 t multiplied by EUR 80, or EUR 40,000 a year. The meter costs EUR 60,000 spread over ten years, plus EUR 2,000 a year in upkeep, so EUR 8,000 a year. The cost is below the benefit, so it is not unreasonable, and Annex II says the better method is then applied without undue delay. Where the cost does exceed the benefit, Guidance No. 3 says the calculation must be attached to the plan.
Is there a CBAM monitoring plan template?
Yes, in two forms. Annex II, point A.5 of the regulation is the legal template, and Guidance No. 3 of 14 August 2026 reproduces it as a table that operators may adapt “providing the minimum elements are retained”. The Commission had published no standard electronic template as of 11 October 2026.
A working template keeps the 22 elements in the legal order, so a verifier can check them one by one. The template then adds the other content the regulation places in the plan.
CBAM monitoring plan example: five entries for a steel rolling mill
Example. Five elements filled in for a fictional hot rolling mill outside the EU that buys steel slabs and sells coil to EU importers.
| Element | Example entry |
|---|---|
| 1. Date and version | Version 1.1, 2 February 2026. Change from version 1.0: a second gas meter on the reheating furnace line. Methods unchanged. |
| 3. Goods by CN code and functional unit | Hot-rolled flat products of non-alloy steel in coils, CN 7208. Functional unit: tonnes of goods. Aggregated goods category: iron or steel products. |
| 9. Source streams and emission sources | Natural gas burned in the reheating furnace and the annealing line, one source stream on the standard method. Emission sources: the reheating furnace stack and the annealing line stack. |
| 14. Precursors and suppliers | Crude steel slabs, CN 7207, from Supplier A in India and Supplier B in Türkiye. Actual data used only with the supplier’s verification report for the year the slabs were made; otherwise the default value for the country of origin. |
| 22(e). Internal review | Each month a second engineer checks the gas meter totals against the gas supplier’s invoices, and coil output against dispatch records. Differences above 2% are investigated and the outcome recorded. |
Each entry names a data source and the person who checks it. The verifier tests those points on the site visit. The Commission’s sector guides, Guidance Nos. 5a to 5e, add worked examples for their sectors.
What changed from the transitional period
The transitional period ran from October 2023 to the end of 2025 with reporting only. Guidance No. 3 lists what the definitive rules change. The wider picture of the definitive period is in CBAM in 2026: All You Need to Know.
| Point | Transitional period | Definitive period |
|---|---|---|
| Reporting period | Operator could choose, for example a fiscal year | The calendar year; goods imported in 2026 take the 2026 period |
| Monitoring plan | Written documentation of the monitoring method, with no language requirement | A monitoring plan with at least the 22 elements of Annex II, point A.5, in English |
| Record keeping | Four years | At least six years after the reporting period |
| Cost test | EUR 20 per tonne; EUR 2,000 a year | EUR 80 per tonne; EUR 4,000 a year |
| Reports | One optional electronic template | Full emissions report, a summary for declarants and a declarant-specific addendum for electricity |
| Bought precursors | Supplier data, with no verification needed | Actual data only with a qualifying verification report for the right period, otherwise default values. EU precursors count as zero, but their quantity is still reported |
| Verification | Not required | Required wherever actual emissions are declared |
How long must CBAM monitoring records be kept?
Records must be kept at the installation for at least six years after the reporting period. Annex II to the regulation requires complete and transparent records of all data behind the embedded emissions, with supporting documents. An operator registered in the CBAM Registry also keeps the verification report and its records for four years after the verification, under Article 10(5), point (c), of the CBAM Regulation.
How does the verifier use the monitoring plan?
Under CBAM, no authority approves a monitoring plan. In the EU Emissions Trading System the competent authority approves the plan. The Commission’s verification guidance of 24 August 2026 says that separation of roles “is not possible for the CBAM”. The assessment “has to be done by verifiers themselves, usually as part of the verification activity”. The same guidance calls the plan “the corner stone (or starting point) of every verification”. Delegated Regulation (EU) 2025/2551 lists the documents the operator hands over. The list starts with the latest version of the plan and also includes:
- a record of changes to the installation and the plan since the last verification;
- the sampling plan, where one is used;
- the emissions report to be verified;
- the verification reports for precursors bought from other installations;
- how findings from the previous year’s verification were dealt with.
The accredited verifier checks that the plan is properly carried out, traces figures back to primary data and visits the site. Implementing Regulation (EU) 2025/2546 requires a physical site visit in the first year subject to verification, and the operator must give the verifier access to its sites. In later years a virtual visit, or no visit, is allowed only under strict conditions, one of them a physical visit in the year before.
Errors are judged against a materiality level of 5% per tonne of each good, by CN code. The level applies to both the specific embedded emissions and the specific embedded free allocation. The Commission’s guidance adds that “materiality is not a tolerance band”: the operator should in principle correct every error found before the verification ends.
A report can be “verified as satisfactory” only where it is free of material misstatement. Uncorrected material errors make it unsatisfactory. The verifier may also find the scope too limited where the monitoring plan “does not provide sufficient scope or clarity to reach a conclusion on the verification”.
Where an operator outside the EU finds a verifier
CBAM accreditation comes only from national accreditation bodies in EU countries, and in EEA countries once the CBAM Regulation is part of the EEA Agreement. The Commission’s verification page says verification companies established outside the EU “may apply in any national accreditation body offering this service”. On 7 October 2026 seven bodies were accepting such applications, and the Dutch body records an agreement with Türkiye’s national accreditation body. The Commission will publish the list of accredited verifiers on its verification page.
The verifier cannot have written the plan
Delegated Regulation (EU) 2025/2551 bars a verifier from checking a plan it helped to write. Its section 1.7.2 sees an unacceptable risk to impartiality where the verifier or its own legal entity developed the methodology or drafted the plan or the emissions report. Section 1.7.3 adds a conflict of interest where a consultancy linked to the verifier did that work. An operator therefore writes the plan in house or with an unrelated adviser, and engages a separate, accredited firm to verify.
How often the plan is assessed
The verification guidance offers two routes. The verifier can assess the plan within the annual verification, ideally early in the year, or as a separate assignment that later verifiers can rely on. For a stable installation, the guidance suggests assessing the plan once every two to five years, and says this is “a recommendation, not a legal requirement”.
An installation can check where its data stands before a verifier does. GreenSutra’s CBAM work starts with a discovery in five short steps: the company, its CBAM exposure, its exports, the site and the data it already holds. Start the CBAM discovery.
Who does what
The operator writes and runs the plan. The others supply data to it, check it, accredit the checkers or rely on its figures.
| Party | Role |
|---|---|
| Installation operator | Writes, runs and updates the plan, prepares the emissions report, gives the verifier documents and site access, and keeps the records |
| Suppliers of precursors, heat and electricity | Provide their own verified data. Without a valid precursor verification report, default values apply to that precursor |
| Accredited verifier | Assesses the plan, verifies the emissions report and, from 1 January 2027, issues the verification report in the CBAM Registry |
| National accreditation body | Accredits verifiers for CBAM and oversees them |
| Authorised CBAM declarant | The EU importer. Makes sure declared actual emissions are verified, files the declaration and surrenders certificates by 30 September |
| European Commission | Runs the CBAM Registry, publishes guidance and may review declarations |
| Competent authority | Registers accredited verifiers and reviews declarations in its Member State |
What an EU importer needs from a supplier
An EU importer that wants to declare a supplier’s actual emissions needs two documents for each installation and year. One is the summary of the operator’s emissions report, which carries the figures a declarant uses. The other is the verification report from an accredited verifier. Without them, the importer declares default values. The Commission’s verification guidance expects declarants to want the reports by mid-August of the following year at the latest. The data a supplier hands over is set out in What emissions data must a non-EU supplier give its EU importer for CBAM?
Registering the installation in the CBAM Registry is optional. Guidance No. 2 calls it “recommended, but currently voluntary”. A registered operator uploads its data once and shares the verified figures with each declarant. An unregistered operator sends the same report through its own channels.
Key dates and the latest updates
The Commission’s status report of 7 October 2026 shows seven national accreditation bodies accepting applications from outside the EU. They are in France, Greece, Italy, the Netherlands, Poland, Slovakia and Sweden. On 28 September 2026 the Commission published resources for verifiers, including how verifiers and operators connect in the Registry. The Commission’s list of accredited verifiers had not appeared by 11 October 2026.
The English text of Regulation 2025/2547 has not been amended; its two 2026 corrections fix the German and Dutch versions only. Guidance Nos. 1 to 5f of 14 August 2026 and the Questions and Answers last updated on 27 May 2026 are still the current versions. The Commission’s proposal to extend CBAM to downstream goods is still a proposal.
Already happened
- Monitoring, verification and accreditation rules published in the Official Journal
- Definitive period starts; monitoring for the 2026 reporting period begins Action for operators
- National accreditation bodies begin CBAM accreditation
- Commission publishes Guidance Nos. 1 to 5f for operators outside the EU
- Commission publishes its guidance on verification and accreditation
- Accredited verifiers can apply for registration in the CBAM Registry
- Seven accreditation bodies accept verifier applications from outside the EU
Status checked on 11 October 2026
Coming up
- First reporting period ends
- First verification reports can be issued and shared with declarants Action for operators
- Sale of CBAM certificates begins
- The latest that declarants want verification reports, in the Commission’s guidance Action for operators
- First CBAM declaration and certificate surrender, for 2026
- Commission reviews the default values
How to prepare a CBAM monitoring plan
Guidance No. 2, the Commission’s quick guide for operators outside the EU, sets out seven steps before the plan is written.
- Define the installation’s boundaries, its production processes (one per functional unit) and its production routes.
- Fix the reporting period: the calendar year in which the goods are made.
- List what to monitor: direct emissions, flows between processes, measurable heat, electricity where indirect emissions count, and precursors with their verification reports.
- Choose a method for each parameter, from meters, purchase records, analyses or standard values. Default values come in only as the last resort.
- Gather the data for the free allocation adjustment.
- Record any carbon price paid in the country of production, by process and good.
- Set up the data flow and controls: assess the risks, add controls and repeat until no high or medium risks remain.
The operator then compiles one written plan in English, clear enough for an outsider to follow, and checks it against the contents of the emissions report in Annex IV. Guidance No. 2 advises a local-language version for the installation’s staff and a review of the plan at least once per reporting period. A method may change only where the change is objectively justified, and every change goes on record. Guidance No. 1 advises contracting a verifier early in the year, because much of the work, such as assessing the plan, can happen before the year ends.
Questions a verifier may ask about the plan
The Commission’s verification guidance includes an example checklist for assessing a plan, with questions such as these:
- Is there a site plan and a flow diagram showing which flows and meters belong to the installation?
- Does every CN code produced sit in exactly one production process?
- For each source stream, how are quantities measured, and how are the calorific value, emission factor and biomass fraction found?
- Are stockpiles and tanks of fuels, materials and goods taken into account?
- Is there a procedure to collect suppliers’ verification reports and, where one is missing, to apply the right default value by CN code, country of origin and year?
- Does the control system answer the risks found, with written procedures for equipment, IT, review, corrections, outsourcing and records?
Download the CBAM monitoring plan template
Template · 7 parts · sent by email
Built on Annex II, point A.5 of Regulation 2025/2547. Each of the 22 elements comes with the legal text, what to document, tables to fill in and what the verifier looks at.
- The 22 elements, in the legal order
- Other content the regulation places in the plan
- Justifications for infeasibility and unreasonable costs
- Written procedures
- Sector modules for all six sectors
- A verification readiness checklist
Get the template by emailThe template is attached to a confirmation email. There is no public download link.
CBAM monitoring plans, answered
What is a CBAM monitoring plan?
A CBAM monitoring plan is an installation's written description of how it measures or calculates the emissions embedded in its goods, how the data flows and how errors are caught. Implementing Regulation (EU) 2025/2547 requires one, with at least the 22 elements of Annex II, point A.5, wherever actual emissions are reported.
Is a CBAM monitoring plan mandatory?
It is mandatory for any operator whose actual emissions go into a CBAM declaration. Operators outside the EU have no direct duty under CBAM, but without a plan and a verified emissions report their EU customers must use default values, which carry a mark-up.
Who approves a CBAM monitoring plan?
No authority approves it. The accredited verifier assesses the plan, usually as part of the annual verification, and the operator corrects any findings without undue delay.
Is there a CBAM monitoring plan example?
Yes. This article fills in five of the 22 elements for a fictional hot rolling mill: date and version, goods by CN code, source streams, precursors and internal review. The Commission's sector guides, Guidance Nos. 5a to 5e, add worked examples for their sectors.
Is there an official CBAM monitoring plan template?
The minimum content in Annex II, point A.5 of Implementing Regulation (EU) 2025/2547 is the template in law, and Guidance No. 3 reproduces it as a table operators may adapt. As of 11 October 2026 the Commission had not published a standard electronic template for the plan.
What language must a CBAM monitoring plan be in?
English. Article 5(6) of Implementing Regulation (EU) 2025/2547 requires the plan to be submitted in English, and Guidance No. 2 advises a local-language version for the installation's staff.
How long must CBAM monitoring records be kept?
At least six years after the reporting period, at the installation. An operator registered in the CBAM Registry also keeps the verification report and its records for four years after the verification.
Can the verifier help write the monitoring plan?
No. Section 1.7.2 of Delegated Regulation (EU) 2025/2551 rules this out. It sees an unacceptable risk to impartiality where the verifier or its own legal entity drafts the plan, develops the methodology or drafts the emissions report. Section 1.7.3 adds a conflict of interest where a consultancy linked to the verifier did that work. The plan is written in house or with an unrelated adviser.
When does a CBAM monitoring plan need updating?
Guidance No. 2 asks for a review at least once per reporting period, and Guidance No. 3 adds a review whenever the installation changes significantly. A method may change only where the change is objectively justified, and every change is recorded.
When is 2026 CBAM data verified?
Verifiers can review documents and visit sites during 2026, but verification cannot finish before January 2027 because it needs the full year's data. Reports are issued in the CBAM Registry from 1 January 2027, and the Commission's guidance expects declarants to want them by mid-August 2027 at the latest.
What happens if an exporter has no verified CBAM data?
The EU importer uses default values set by Implementing Regulation (EU) 2025/2621, as corrected in July 2026. For cement, iron and steel, aluminium and hydrogen they carry a mark-up of 10% for 2026, 20% for 2027 and 30% from 2028. For fertilisers the mark-up is 1%.
An installation with its plan written and its verifier booked before the year ends can give its EU customers verified figures in time for the first declaration. Work with GreenSutra starts with the CBAM discovery. The CBAM consulting service covers the monitoring plan, the emissions calculations and an emissions report prepared for verification by an accredited verifier.
Related explainers
Primary sources
- Commission Implementing Regulation (EU) 2025/2547 · methods for calculating embedded emissions
- Commission Implementing Regulation (EU) 2025/2546 · verification principles
- Commission Delegated Regulation (EU) 2025/2551 · accreditation and verification
- Regulation (EU) 2023/956 establishing CBAM · consolidated text of 20 October 2025
- Commission Implementing Regulation (EU) 2025/2621 · default values
- Commission Implementing Regulation (EU) 2026/1740 · corrected default values
- European Commission · Guidance No. 1, Introduction to CBAM concepts, 14 August 2026
- European Commission · Guidance No. 2, Quick guide for non-EU operators, 14 August 2026
- European Commission · Guidance No. 3, Methods for the calculation of embedded emissions, 14 August 2026
- European Commission · Guidance on CBAM verification and accreditation, 24 August 2026
- European Commission · State of play of CBAM accreditation, 7 October 2026
- European Commission · CBAM verification page and timeline
- European Commission · CBAM Questions and Answers, last updated 27 May 2026