EU Emissions Trading System (EU ETS)

The CBAM verification process follows a structured, risk-based approach. The summary below reflects the verification activities in Section 2.2 to Section 2.20 of Annex II to Commission Delegated Regulation (EU) 2025/2551, together with the verification principles in Commission Implementing Regulation (EU) 2025/2546.

1. Pre-contractual review and time allocation

   Before accepting an engagement, SCS reviews the available information to understand the operator’s installation, determine the proposed verification scope, confirm that the engagement falls within the accredited scope, assess competence and resource availability, evaluate verification risks, and allocate sufficient time for the work. The contract must allow for additional time if needed for strategic analysis, risk analysis, or other verification activities.

2. Information request from the operator

   Before the strategic analysis and throughout the verification, the operator must provide the information needed to plan and perform the verification. This may include the latest monitoring plan, installation descriptions, process flow information, change records, sampling plans, operator emissions report, previous verification reports, information on unresolved findings, precursor verification reports, production-period evidence, electricity evidence, databases, data sources, and other relevant records.

3. Strategic analysis

   SCS performs a strategic analysis to assess the likely nature, scale, and complexity of the verification. This includes reviewing the installation, goods produced, production processes and routes, source streams, emission sources, technical connections, monitoring methodology, measurement equipment, calculation factors, precursor inputs, electricity data, data flow activities, and the operator’s control system.

4. Risk analysis

   SCS identifies and analyses inherent risks, control activities, and control risks that may affect the reliability of the emissions report. The risk analysis considers the strategic analysis, operator information, relevant source streams and data flows, and applicable materiality levels. If new information becomes available during verification, the risk analysis and planned verification activities are updated.

5. Verification plan

   Based on the strategic and risk analyses, SCS prepares a verification plan proportionate to the risks identified. The plan includes a verification programme, a test plan for control activities and procedures, and a data sampling plan. The plan is designed to reduce verification risk to an acceptable level and support a reasonable assurance opinion.

6. Verification activities

   SCS implements the verification plan and checks whether the monitoring plan has been properly applied. Verification activities include substantive testing, analytical procedures, data verification, and checks on the correct application of the monitoring methodology. SCS reviews data flow activities, IT systems, control activities, procedures, documentation, and implementation effectiveness.

7. Analytical procedures

   SCS uses analytical procedures to assess plausibility and completeness of reported data. This includes assessing fluctuations and trends, identifying outliers, unexpected data and data gaps, performing preliminary and substantive analytical procedures, and carrying out final analytical procedures to confirm that identified errors have been resolved.

8. Data verification

   SCS performs detailed testing of the data in the operator’s emissions report. This includes tracing data back to primary source records, cross-checking with external or corroborating sources where available, performing reconciliations, checking thresholds, recalculating reported values, and verifying the boundaries of the installation, production processes, production routes, source streams, emission sources, technical connections, activity levels, and data reliability.

9. Verification of monitoring methodology

   SCS checks whether the monitoring methodology in the monitoring plan has been correctly applied. This includes evaluating completeness of data, data gaps, double counting, sampling plans, attribution of emissions and energy flows, activity-level definitions, energy consumption, precursor treatment, use of verified actual emissions for precursors where applicable, default-factor use, electricity emission factors, biomass sustainability evidence, and treatment of transferred CO2 or N2O, carbon capture and storage, and permanent carbon capture and use.

10. Reliance on other verification reports

    Where the operator relies on verified data from other installations, such as precursor-producing installations or electricity-producing installations, SCS checks whether the related verification report was issued by an appropriately accredited verifier, whether the opinion was satisfactory, and whether the report covers the relevant production period.

11. Sampling

    SCS may use sampling methods where justified by the risk analysis. If a misstatement or non-conformity is identified through sampling, SCS requests the operator to explain the cause, assesses the impact on reported data, determines whether additional verification work is needed, and decides whether the sample size or corrected data population must be expanded.

12. Physical site visit

    SCS conducts a physical site visit at the installation where the goods are produced, unless a virtual site visit or waiver is permitted under the applicable CBAM verification rules. The site visit is used to assess measuring devices and monitoring systems, interview personnel, assess installation and production-process boundaries, confirm the completeness of source streams and emission sources, review technical connections, and gather sufficient evidence for the verification conclusion.

13. Addressing misstatements, non-conformities, and non-compliance

    Where SCS identifies misstatements, non-conformities, or non-compliance during verification, SCS informs the operator without delay and requests correction. Corrected issues are documented as resolved. For uncorrected issues, SCS requests explanations, assesses materiality, evaluates impacts on reported embedded emissions and free allocation adjustment information where relevant, and determines the effect on the verification opinion.

14. Independent technical review

    Before the verification report is issued, the internal verification documentation and draft verification report are reviewed by an independent reviewer who was not part of the verification team. The review covers the complete verification process, confirms that procedures were correctly followed, assesses whether due professional care and judgement were applied, and evaluates whether the evidence supports a reasonable assurance opinion.

15. Authentication of the verification report

    The verification report is authenticated based on the conclusions of the independent reviewer and the evidence in the internal verification documentation. Authentication is performed by a person duly authorized by the verifier.

16. Internal verification documentation

    SCS compiles internal verification documentation sufficient to demonstrate that the verification was performed in accordance with the applicable CBAM requirements. The documentation includes the results of verification activities, information received from the operator, strategic analysis, risk analysis, verification plan, justification for any site-visit waiver or virtual site visit, evidence supporting the verification opinion, and the results of the independent review.

17. Verification report and opinion statement

    SCS issues the verification report only for activity groups within its accredited scope. The verification report includes a verification opinion. The report may be verified as satisfactory only where the operator’s emissions report is free from material misstatements. The report is verified as unsatisfactory where material misstatements, material non-conformities, insufficient clarity, or limitations of scope prevent a satisfactory reasonable assurance conclusion.

18. Limitation of scope

    SCS may conclude that the scope of verification is too limited where data are missing, the monitoring plan does not provide sufficient scope or clarity, or the operator has not made sufficient information available. A limitation of scope may prevent SCS from obtaining sufficient evidence to issue a reasonable assurance opinion.

19. Outstanding non-material non-conformities

    SCS assesses whether non-material non-conformities identified in the previous reporting period have been corrected. If they have not been corrected, SCS assesses whether the failure increases, or may increase, the risk of misstatements and documents the status and resolution of findings.

20. Recommendations for improvement — without consultancy

    Where SCS identifies areas for improvement, the verification report may include recommendations related to the operator’s risk assessment, data flow activities, control activities, procedures, and monitoring and reporting process. These recommendations are limited to verification findings and do not constitute consultancy. SCS remains impartial and does not advise on, design, or develop the operator’s monitoring and reporting process.

21. Facts discovered after issuance of the verification statement

    If SCS becomes aware of facts after issuance of the verification statement that could have materially affected the verification opinion, SCS assesses the significance of the information, determines whether additional verification activities are required, and takes appropriate action. Depending on the circumstances, this may include communication with the client, amendment, withdrawal or reissuance of the verification statement, and notification of relevant authorities or intended users where required.