A CBAM verifier visits the installation in person in the first year subject to verification, under Implementing Regulation (EU) 2025/2546. The only exception is a virtual visit forced by serious, unforeseeable circumstances. From the second consecutive year a virtual visit is possible, and a waiver needs physical visits in two earlier reporting periods.
When each option is allowed
| Option | Condition |
|---|---|
| Physical visit | Expected in the first year subject to verification and at least every two years, under recital 3 |
| Virtual visit | A physical visit in the reporting period just before, plus every condition in Article 3(1) |
| Waiver | A physical visit during two reporting periods before the current one, plus the same conditions, so the third year at the earliest |
| Virtual visit for force majeure | Serious, extraordinary and unforeseeable circumstances outside the operator’s control, in any year, under Article 4 |
The Article 3(1) conditions are demanding. The verifier must understand the installation and its control system, judge that the risks do not need a visit and be able to obtain all evidence remotely. The decision must rest on the risk analysis. Significant changes since the last physical visit rule out the option, including:
- new or closed production processes or routes;
- changes in energy supply or in links between processes;
- changes to precursors where actual values are used;
- a change of monitoring methodology.
An installation producing only electricity, with no emitting fuels or processes, can have the visit waived if a physical visit took place in the last five reporting periods. The conditions in Article 3(1)(c) to (f) still apply. The verifier decides alone, without competent authority approval, and tells the operator without delay.
Example: a cement plant’s first two years
Example. A cement plant’s 2026 data are its first to be verified, so the verifier visits in person. The visit can happen during 2026, before the year closes. If the plant adds no new process, fuel line or monitoring method, the verifier may carry out the visit for the 2027 data virtually, provided the other conditions hold.
On a physical visit the verifier compares meters, stockpiles and records on the ground with the monitoring plan. Delegated Regulation (EU) 2025/2551 requires the verifier to make sure the operator gives it access to its sites.
Sources: Commission Implementing Regulation (EU) 2025/2546, Commission Delegated Regulation (EU) 2025/2551, Guidance on CBAM verification and accreditation, 24 August 2026
The documents a verifier asks for are listed in CBAM Monitoring Plan in 2026. An installation can check its readiness through the CBAM discovery, and GreenSutra’s CBAM solutions prepare the plan and records the visit tests.