Commission Delegated Regulation (EU) 2025/2551 of 20 November 2025 supplementing Regulation (EU) 2023/956 of the European Parliament and of the Council by specifying the conditions for granting accreditation to verifiers, for the control and oversight of accredited verifiers, for the withdrawal of accreditation and for mutual recognition and peer evaluation of accreditation bodies

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism (1), and in particular Article 18(3) thereof,

Whereas:

(1) Pursuant to Regulation (EU) 2023/956, where embedded emissions in goods imported into the customs territory of the Union from 2026 are determined based on actual values, they are to be verified by a verifier.

(2) In accordance with Article 1(2) of Regulation (EU) 2023/956, the carbon border adjustment mechanism (CBAM) complements the EU Emissions Trading System (ETS) established under Directive 2003/87/EC of the European Parliament and of the Council (2). Ensuring coherence and consistency between the CBAM accreditation and verification requirements and those applicable to the EU ETS will strengthen synergies between the two instruments and reduce the administrative burden for verifiers, national accreditation bodies and competent authorities.

(3) Pursuant to Regulation (EU) 2023/956, national accreditation bodies, as appointed by each Member State pursuant to Regulation (EC) No 765/2008 of the European Parliament and of the Council (3), are to accredit verifiers. In order to ensure that only applicants that are able to carry out verification of embedded emissions in accordance with Regulation (EU) 2023/956 with the necessary competence and knowledge are accredited, it is necessary to lay down requirements for the competence of verifiers and the activities which they need to be able to perform once accredited.

(4) To ensure consistency with the accreditation and verification requirements applicable to the EU ETS and to take account of the specificities of the CBAM, it is necessary to specify the competence requirements and activities which verifiers are to carry out pursuant to this Regulation, in a similar fashion as for the activities and requirements provided under the EU ETS. To ensure an effective application procedure, it is also necessary to lay down rules for the submission of the request for accreditation through which applicants will demonstrate technical competence.

(5) To their take account of internationally applicable standards, ensure consistency with the rules applicable to the EU ETS and avoid any unnecessary duplication of procedures, it is appropriate to draw on best practices resulting from the application of the relevant harmonised standards adopted by the European Committee for Standardisation on the basis of a request made by the Commission in accordance with Regulation (EU) No 1025/2012 of the European Parliament and of the Council (4). It is therefore appropriate to foresee compliance with certain relevant harmonised standards which shall be complemented by additional and specific requirements set out in this Regulation.

(6) To respect the principle of non-competition between national accreditation bodies, applicants should request accreditation in the Member State in which they are established. However, it is necessary to ensure that applicants are able to request accreditation in another Member State where there is no national accreditation body in the applicant’s Member State or where the national accreditation body is not competent to provide the accreditation services requested.

(7) To increase the number of eligible applicants, reduce costs for verifiers established in third countries and allow operators to use their verification services, it should be possible for a legal person not established in a Member State to apply for accreditation with any national accreditation body. Where the national accreditation body, for reasons of lack of capacity or other related reasons, is unable to process the application of an applicant established in a third country, it should provide the applicant with duly justified reasons thereof, as well as a list of national accreditation bodies which may be able to process the request.

(8) National accreditation bodies should ensure that verifiers possess the necessary competence to understand the technical processes carried out by installations and to assess the specific monitoring and reporting boundaries of an installation depending on the goods produced. For this purpose, a separate accreditation scope should be created for each relevant CBAM activity group so that national accreditation bodies are able to evaluate the verifier’s competence and performance against specific criteria depending on the particular scope of accreditation.

(9) To avoid duplication of processes and an excessive administrative burden while maintaining the robustness of the accreditation process, verifiers that are already accredited for a relevant group of activities under the EU ETS pursuant to Commission Implementing Regulation (EU) 2018/2067 (5) should be able to apply for an extension of the scope of their accreditation to the corresponding CBAM accreditation certificates. To allow national accreditation bodies to take into account the corresponding groups of activities under the EU ETS, it is necessary to identify such corresponding groups of activities.

(10) To ensure that national accreditation bodies are able to adequately carry out accreditation activities, it is necessary to lay down rules and requirements for the assessment of requests for accreditation.

(11) To allow national accreditation bodies to exercise control and oversight over verifiers and to ensure that verifiers maintain their technical competence to perform the entrusted task, it is necessary to specify the surveillance activities that national accreditation bodies are to carry out. Where the national accreditation body concludes that the verifier has failed to meet the requirements and perform the verification activities pursuant to this Regulation, Regulation (EU) 2023/956 and Commission Implementing Regulation (EU) 2025/2546 (6), the national accreditation body should be able to adopt administrative measures including the suspension, withdrawal or reduction of the scope of accreditation.

(12) To ensure efficient control and oversight of verifiers, it is appropriate to lay down rules for the exchange of information between the verifier and the national accreditation body that has accredited it, the national accreditation body and the competent authority of a Member State as well as between competent authorities and the Commission. Such information exchanges should be governed by the strictest guarantees of confidentiality and professional secrecy and be handled in accordance with applicable Union and national law.

(13) Where a Member State does not establish a national accreditation body or does not carry out accreditation activities for the purpose of this Regulation, to ensure efficient oversight of verifiers, the competent authority should communicate any complaint it received concerning a verifier accredited by another national accreditation body to the latter, as well as information on the review of verification reports to other competent authorities and the Commission via the CBAM registry.

(14) To ensure that the information on accredited verifiers in the CBAM registry is reliable and up-to-date, national accreditation bodies should notify the competent authority of any change to the accreditation of a verifier.

(15) To support the review of verification reports, the national accreditation body should periodically exchange information with the competent authority on the activities planned for verifiers and the results of the control of these activities. The competent authority should share this information with the Commission and other competent authorities via the CBAM registry. In turn, the competent authority should also share with the national accreditation body any relevant information from the review of verification reports in order to support its accreditation activities related to the control and oversight of verifiers.

(16) To ensure the smooth functioning of accreditation and verification, Member States and competent authorities should recognise the equivalence of the services of national accreditation bodies which have successfully undergone peer evaluation, or which have started a peer evaluation during which no irregularity was identified, and should accept the accreditation certificates and verification reports of verifiers accredited by those national accreditation bodies.

(17) National accreditation bodies that demonstrate conformity with this Regulation and that have already successfully undergone peer evaluation before the date of application of this Regulation should be presumed to fulfil the relevant procedural requirements and should be exempt from the obligation to undergo a new peer evaluation in accordance with Regulation.

(18) Where the outcome of the peer evaluation is negative, in order to mitigate any uncertainty about the mutual recognition of accreditation certificates or verification reports, the national accreditation body should be prevented from providing any accreditation services.

(19) When personal data is processed in the context of the application of this Delegated Regulation, Regulation (EU) 2016/679 of the European Parliament and of the Council (7) is to apply.

(20) As this Regulation lays down provisions on the accreditation of verifiers carrying out activities in relation to greenhouse gas emissions released from 1 January 2026, it should apply from that date.

(21) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council (8) and delivered an opinion on 13 November 2025,

HAS ADOPTED THIS REGULATION:

CHAPTER I

GENERAL PROVISIONS

Article 1

Definitions

For the purposes of this Regulation, in addition to the definitions laid down in Article 1 of Implementing Regulation (EU) 2025/2546 and Article 1 of, and Annex I to, Commission Implementing Regulation (EU) 2025/2547 (9), the following definitions apply:

(1) ‘verifier’ means a legal person carrying out verification activities pursuant to this Regulation and accredited by a national accreditation body for the purpose of Regulation (EU) 2023/956 at the time a verification report is issued;

(2) ‘verification’ means the activities carried out by a verifier to issue a verification report pursuant to this Regulation, Regulation (EU) 2023/956, and Implementing Regulation (EU) 2025/2546;

(3) ‘scope of accreditation’ means the CBAM activity groups referred to in Annex I to this Regulation for which accreditation is sought or has been granted;

(4) ‘inherent risk’ means the susceptibility of a parameter in the operator’s emissions report to misstatements that could be material, individually or when aggregated with other misstatements, before taking into consideration the effect of any related control activities;

(5) ‘control activities’ means any acts carried out or measures implemented by the operator to mitigate inherent risks;

(6) ‘control risk’ means the susceptibility of a parameter in the operator’s emissions report to misstatements that could be material, individually or when aggregated with other misstatements, and that will not be prevented or detected and corrected on a timely basis by the control system;

(7) ‘verification risk’ means the risk, which is caused either by the inherent risk, the control risk, or the risk that the verifier does not detect a material misstatement, that the verifier expresses an incorrect verification opinion when the operator’s emissions report is not free of material misstatements;

(8) ‘level of assurance’ means the degree of assurance the verifier provides on the verification report based on the objective of reducing the verification risk according to the circumstances of the verification engagement;

(9) ‘reasonable assurance’ means a high but not absolute level of assurance, expressed positively in the verification opinion, as to whether the operator’s emissions report subject to verification is free from material misstatement;

(10) ‘site’ means the installation to which the operator’s emissions report subject to verification refers;

(11) ‘CBAM lead auditor’ means an auditor in charge of directing and supervising the verification team, who is responsible for performing and reporting on the verification of an operator’s emissions report;

(12) ‘CBAM auditor’ means a member of a verification team who is responsible for conducting a verification of an operator’s emissions report;

(13) ‘assessor’ means a person assigned by a national accreditation body to perform individually or as part of an assessment team an assessment of a verifier pursuant to this Regulation.

CHAPTER II

GRANTING AND WITHDRAWAL OF ACCREDITATION

SECTION 1

Procedure

Article 2

Scope of assessment by national accreditation bodies

The national accreditation body shall assess whether the legal person applying for accreditation (‘the applicant’) or the verifier:

(a) meets the competence requirements laid down in Section 1 of Annex II, including the harmonised standard referred to in Section 1.5.1 of Annex II;

(b) is carrying out the verification activities laid down in Section 2 of Annex II to this Regulation in accordance with this Regulation, Regulation (EU) 2023/956, and Implementing Regulation (EU) 2025/2546.

Article 3

Request for accreditation

By way of derogation from the first subparagraph, the applicant that is established under the national law of a Member State shall request a national accreditation body other than that of its Member State of establishment to grant accreditation in any of the following situations:

(a) where the Member State in which it is established has decided not to establish a national accreditation body and has not had recourse to the national accreditation body of another Member State;

(b) where the national accreditation bodies referred to in the first subparagraph do not perform accreditation in respect of the verification activities for which accreditation is sought;

(c) where the national accreditation bodies referred to in the first subparagraph have not successfully undergone peer evaluation in respect of the activity groups for which accreditation is sought.

(a) a description of the applicant’s competence to carry out the procedures and processes referred to in Section 1.5.1 of Annex II and the quality management system referred to in Section 1.5.2 of that Annex;

(b) a description of the competence criteria referred to in Section 1.1.1, second paragraph, points (a) and (b), of Annex II, the results of the competence process referred to in that Section and other relevant documentation on the competence of all personnel involved in verification activities as referred to in Sections 1.2 and 1.3 of Annex II;

(c) a description of the process for ensuring continuous impartiality and independence, as referred to in Section 1.7.5 of Annex II, including relevant records on the impartiality and independence of the applicant and its personnel;

(d) the list of the technical experts in verification and key personnel involved in the verification of operators’ emissions reports;

(e) a description of the procedures and processes referred to in Section 1.5.1 of Annex II, including those concerning the internal verification documentation referred to in Section 2.16 of Annex II;

(f) the records referred to in Section 1.6 of Annex II;

(g) if applicable, any relevant evidence of proven competence in applying the international standard referred to in Section 1.5 of Annex II, as recognised by a national accreditation body or a third-country accreditation body.

The body that is recognised as the organiser of peer evaluation referred to in Article 24 shall facilitate the exchange of information between national accreditation bodies by maintaining a list of national accreditation bodies providing accreditation services for CBAM and of national accreditation bodies which may be able to undertake the accreditation process for applicants established in a third country.

Article 4

Requests for accreditation by applicants accredited under Implementing Regulation (EU) 2018/2067

An applicant accredited pursuant to Implementing Regulation (EU) 2018/2067 for the relevant group of activities listed in Annex I to this Regulation may apply for an extension of the scope of its accreditation to the corresponding CBAM activity groups as listed in that Annex.

The application for a scope extension shall be submitted to the national accreditation body designated in accordance with Article 3(1).

Article 5

Assessment of requests to grant accreditation

(a) review the information supplied by the applicant pursuant to Article 3;