A CBAM consultant calculates embedded emissions and prepares the annual declaration. Any actual emissions in it are verified by an independent accredited verifier before it is filed, and default values need no verification. Independence and impartiality are accreditation criteria under Delegated Regulation (EU) 2025/2551, adopted under Article 18 of Regulation (EU) 2023/956. Only a national accreditation body in an EU country, or in an EEA country once CBAM is part of the EEA Agreement, may accredit a CBAM verifier.
Two roles sit either side of a CBAM declaration, and the regulation requires the verifier to be independent of the operator. The two are easy to confuse, 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 verifies the declared actual emissions |
| Accreditation | Not accredited for CBAM | Accredited by an EU national accreditation body (EEA bodies once CBAM is part of the EEA Agreement) |
| Governing instrument | No CBAM accreditation instrument applies | Delegated Regulation (EU) 2025/2551; Annex I of that act maps its scopes to the activity groups 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 an authorised CBAM declarant may import CBAM goods into the Union from 2026. The exception is an importer at or below 50 tonnes net mass a year, which does not apply to electricity or hydrogen. Responsibility for the annual declaration rests with the declarant under Articles 5(7a) and 6 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 country, or in an EEA country once CBAM is part of the EEA Agreement, are competent to grant CBAM verifier accreditation. A body established outside that territory cannot accredit a CBAM verifier at all. The verifier itself can be established inside or outside the EU, and one outside the EU may apply to any national accreditation body that offers the service. The consultant that prepared the figures cannot act as verifier on the same file. 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.