A CBAM consultant calculates embedded emissions and prepares the annual declaration, while an independent accredited verifier checks that declaration before it is filed. Independence and impartiality are explicit accreditation criteria under Article 18 of Regulation (EU) 2023/956, and only an EU or EEA national accreditation body may accredit a CBAM verifier.
Two roles sit either side of a CBAM declaration and the regulation keeps them apart. Conflating them is the most common scoping error made when an exporter first arranges compliance support, because both are described loosely as “CBAM help” in the market.
What each mandate covers
| Aspect | CBAM consultant | Accredited CBAM verifier |
|---|---|---|
| Function | Calculates embedded emissions, assembles the evidence, prepares the declaration | Independently checks the declared embedded emissions |
| Accreditation | Not accredited for CBAM | Accredited by an EU or EEA national accreditation body |
| Governing instrument | No CBAM accreditation instrument applies | Delegated Regulation (EU) 2025/2551, accredited under Annex I of Regulation (EU) 2018/2067 |
| Standing | Advisory, engaged by the exporter or the declarant | Independence and impartiality are accreditation criteria |
| Registry | Not registered | Registered in the CBAM registry under Article 10a |
Legal responsibility moves to neither role
Only a party holding authorised CBAM declarant status may import CBAM goods into the Union from 2026, and responsibility for the annual declaration rests with that declarant under Article 5 of Regulation (EU) 2023/956. Appointing a consultant does not transfer it, and neither does a verification opinion. Regulation (EU) 2025/2083 permits a declarant to use operator-submitted data through the registry, but legal responsibility still does not move.
Why the accreditation territory matters
Only national accreditation bodies located in an EU or EEA country are competent to grant CBAM verifier accreditation. A body established outside that territory cannot accredit a CBAM verifier at all. That is the practical reason an exporter in India, Türkiye or the Gulf engages calculation and preparation support locally while verification is performed by an accredited verifier from within the EU or EEA. Verifier registration for the definitive regime opened on 1 September 2026.
Sources: Regulation (EU) 2023/956, Commission Delegated Regulation (EU) 2025/2551, European Commission, CBAM verification
Which mandate an exporter actually needs depends on where the data gaps sit. CBAM solutions covers embedded emissions calculation and declaration preparation, and the CBAM guide sets out where verification falls in the annual cycle. Verification itself is performed by an independent accredited verifier, never by the party that prepared the figures.