Jerónimo Casas, global product manager for climate change and sustainability solutions at SGS, discussed verifier accreditation, emissions monitoring, data integrity and reporting deadlines in his “Spotlight on CBAM” presentation at the SteelOrbis Fall 2026 Conference & 95th IREPAS Meeting held in Belgrade on September 27-29.
Mr. Casas said SGS had applied for CBAM verifier accreditation through SGS Belgium and SGS Italy. Final decisions on both applications are pending. According to Casas, accreditation granted to either affiliate would allow it to carry out CBAM verification across the EU. He encouraged operators to request verification proposals now.
Monitoring plan identified as key challenge for operators
Drawing on SGS's pre-verification work, Casas identified the monitoring plan as a key challenge for operators. He said CBAM requires a monitoring system, with the plan explaining how an installation collects data, calculates emissions and meets the applicable requirements. The plan will be examined during verification. Casas noted that the relevant regulatory section contains 22 points that operators should review and address where applicable.
The monitoring plan covers the installation and its processes; goods identified by CN code and functional unit; CBAM production processes and routes; non-CBAM goods by process; relevant benchmarks; monitoring methods and calculation factors; emission sources and source streams; system boundaries; precursors used in each process; and controls over data quality. Casas cited Annex II, section A.5 of Commission Implementing Regulation (EU) 2025/2547 for the plan's minimum contents.
Casas also discussed specific embedded free allocation (SEFA), which he said must be calculated and verified alongside reported embedded emissions. He explained that EU installations receive free allowances based on sector-specific benchmarks and described SEFA's role in accounting for that free allocation under CBAM. Casas advised operators supplying the EU market to prepare the relevant information and EU importers to discuss it with their suppliers.
Verifier independence and data integrity under CBAM
On verifier independence, Casas said a company that has implemented an installation's emissions monitoring system could not then verify the same system. He added that, using another company in the same corporate group did not automatically remove a conflict of interest and that commercial referral agreements with consultants could also present a conflict. National accreditation bodies examine such arrangements as part of their assessments.
Casas also described several checks intended to address fraud and data manipulation. Operators reporting actual emissions must collect the required data and explain their calculations under the European Commission's methodology. An initial verifier site visit is mandatory, he said, allowing the verifier to examine the installation, measurement equipment, calculations and underlying records. Competent authorities and the European Commission can request further information about unusual or apparently incorrect reports, while data manipulation can lead to sanctions.
Verified emissions data can reduce CBAM costs
Casas compared three reporting options, describing verified emissions from both an installation and its relevant precursors as producing the lowest CBAM cost, provided suppliers are ready to supply the data. A second option uses verified installation emissions and default values for precursors. Under a third option, default values alone require no verification but are described as producing the highest CBAM cost. Casas said verification allows operators to report actual values and gives declarants information for purchasing decisions.
For declarants, he recommended contractual requirements for verified supplier emissions data, with financial consequences if the data are not provided. He also suggested agreeing on emissions thresholds and consequences if they are exceeded, checking whether suppliers have completed pre-verification, and supporting improvements to their monitoring and reporting systems.
Companies urged to prepare ahead of CBAM reporting deadline
Casas stated that CBAM certificates will be available for purchase from February 2027, while September 30 is the deadline for submitting verified reports and surrendering certificates. Casas urged companies to engage verifiers and suppliers early, warning that demand for verification could be concentrated near the deadline.
He said early planning was particularly important for iron and steel supply chains. Downstream producers may need verified emissions data from suppliers of precursors; without those data, they may have to use default values for the precursors even if emissions from their own operations have been verified. Casas also advised declarants to plan certificate purchases and submit their reports ahead of the deadline to avoid difficulties caused by heavy use of the reporting platform.
