CBAM is now in its definitive regime. Verification activities have started, and the first annual declaration covering 2026 imports is due on 30 September 2027. Weetra checks whether the goods, suppliers, producers, installations, reporting periods, emissions information and supporting documents in the file actually connect to one another before those records are relied on further.
Regulatory content last reviewed 1 October 2026
From September 2026, accredited CBAM verifiers can register in the CBAM Registry and the first verification activities can begin, including documentary review and site visits. From January 2027, accredited verifiers can issue the first verification reports through the Registry.
The first annual CBAM declaration covers imports made during 2026 and is due on 30 September 2027. The corresponding CBAM certificates must also be surrendered by that date.
The Commission’s current timetable places the start of first verification activities in September 2026. Verification can include documentary review and site visits.
The first annual declaration reports the quantity of CBAM goods imported, their embedded emissions and the corresponding number of CBAM certificates.
On 30 September 2026, the Commission reported that the current 50-tonne single mass-based threshold would exempt 0.87% of embedded emissions for the assessed period, below the 1% limit. The assessment does not itself change the current threshold.
European Commission guidance and explanatory materials do not replace the applicable legislation. Weetra provides documentary review upstream of accredited verification and does not provide legal advice, accredited verification, certification or assurance.
CBAM reporting depends on goods, quantities, installations, embedded emissions and, where relevant, carbon-price evidence. The rules require records capable of supporting the reported position, accredited verification where applicable and later review.
Regulatory references provide the legal context. Weetra does not provide legal advice or accredited verification.
The evidence problem
The evidence problem How the chain develops One value, many dependencies What Weetra examines What can break Four documentary questions that often determine CBAM readiness From finding to correction Relationship to accredited verification What the organisation receivesCBAM reporting produces figures. Embedded emissions attached to goods, quantities attached to declarations, carbon-price amounts attached to claimed treatment. Each figure is easy to place in a spreadsheet. What is harder is showing, months later, why that particular figure applies to those particular goods.
A number can be present in a file while the documents needed to rely on it remain incomplete. The value may be arithmetically correct, but the available records do not yet show that it belongs to the installation, period or source on which the CBAM file relies.
That question is more immediate now that accredited verification has entered its operational phase and the documentary record for the first annual declaration is being created around 2026 imports.
This is the problem Weetra works on. Within a defined document set and an agreed mandate, the review examines whether the relationships behind a reported value can be established, and records precisely where they cannot.
A CBAM file is built from information produced by different parties, systems and periods. At each handoff, an important link can be documented clearly or lost.
Goods move during an import period. The importer or authorised CBAM declarant remains responsible for the declaration and the information submitted under it. The information needed to characterise those goods, however, may originate elsewhere: from suppliers, producers, non-EU installations and the monitoring and emissions records maintained by parties the declarant does not control.
Where actual emissions are relied on and accredited verification is required, the verifier performs its own regulated function. The Commission’s current framework describes verification at installation level, including review of the monitoring approach, emissions calculations and supporting evidence.
The annual position then requires those elements to remain correctly associated: the right emissions basis attached to the right installation, for the right production and reporting period, for the right goods and quantities.
Weetra sits upstream of that verification process. Within the agreed mandate, it examines the documentary relationships supporting the figures and statements being relied on. It does not assume the declarant’s responsibilities, perform customs functions or issue the accredited verifier’s conclusion.
Reference sequence. The applicable path depends on the goods, emissions basis, supply chain and mandate.
An embedded-emissions figure is the end result, not the whole story. The imported goods still need to connect consistently to the producer, installation, monitoring basis, reporting period, calculation and supporting documents.
The existence of the final value does not itself establish everything upstream of it. A position may become difficult to sustain not because the number looks wrong, but because one necessary documentary relationship cannot be demonstrated from the set of records available.
Each step is a relationship that has to be evidenced, not assumed.
Depending on the mandate, the applicable review depth and what the document set actually contains, the examination may address relationships involving
Not every item applies to every file. What is examined depends on the mandate, the regulatory rules that apply and the documents actually available.
The following are illustrative documentary questions drawn from the kinds of situation a documentary review encounters. They are questions to be resolved, not automatic findings of failure.
Emissions data identify a producing installation, but the reviewed commercial and production evidence does not establish that the relevant imported goods came from it.
The calculation or emissions report refers to one monitoring-plan version, while a different version is present in the dossier.
Commercial, production and emissions records refer to periods that cannot be cleanly reconciled with the reporting or production period used in the file.
A precursor emissions value is relied on, but the producer, installation, period or documentary basis behind that precursor is incomplete.
Customs, commercial, production and emissions records express quantities that do not reconcile with one another.
Two documents in the same file support materially different values for the same regulatory fact.
A verification report is present, but the reviewed set of documents does not clearly establish its connection to the installation, production period or emissions information relied on.
A later correction exists, but the file cannot show which version supported a given calculation or conclusion.
The file shows a carbon-price amount, but the documents may not establish every element needed for the treatment being requested.
For the carbon-price evidence question, see Article 9 of the EU CBAM Regulation →
A payment receipt can establish that money moved. The review still has to connect the carbon-pricing mechanism, liable entity, installation, covered emissions, relevant period, rebates or compensation, net amount and the CBAM treatment for which the payment is being used.
An emissions value may identify an installation without proving that the imported goods were produced there. Commercial, production and shipment evidence has to carry that relationship.
For complex goods, a precursor value may depend on another producer, installation or production period. The file needs to show which precursor data were actually used and what supports them.
Customs quantities, invoices, production records and emissions workbooks can all be individually plausible while referring to different masses, units or periods. Cross-source reconciliation shows whether they describe the same underlying flow.
Concrete cases make the evidence problem easier to see. These examples do not replace the full review; they show why a figure or document can exist while the relationship needed to rely on it is still unresolved.
Finding a missing document is only the start of a deeper review.
Where follow-up is included, the review identifies what is unresolved, which figure or statement it affects, which documents were checked, why they are not enough and which party is likely to hold the missing information.
That turns a generic supplier request into a targeted question. It also makes the outcome checkable. When new or corrected documents arrive, Weetra can examine the same point again and record whether it was resolved, still could not be fully confirmed, or continued to prevent a conclusion.
Corrections do not guarantee that every issue will close. Some points are resolved, some remain limited, and the reviewed record shows which is which.
Follow-up questions and corrections apply where the commissioned review depth and mandate include them.
The Commission’s current verification framework makes the distinction between documentary preparation and accredited verification especially important. Accredited verifiers perform the regulated verification function and reach their own independent conclusion. Weetra works upstream on the documentary basis that may later be examined.
The Commission’s 24 August 2026 guidance also gives more operational detail on strategic and risk analysis, data flows and controls, source-data testing, monitoring methodology, data gaps, site visits, misstatements, non-conformities, internal verification documentation and independent review.
Organised in advance, a reviewed file changes the character of that external exchange. Documents are ordered, installation and period relationships are set out, open issues are identified rather than discovered late, corrections are documented, versions are controlled and the basis relied on can be understood.
First CBAM verification activities can already begin. The documentary record supporting 2026 imports is also the record that will feed the first annual CBAM declaration due on 30 September 2027. Identifying a broken relationship now is different from discovering it during verification or declaration preparation.
Where accredited verification is required, the Weetra review record can accompany the underlying file while the accredited verifier performs its own procedures and issues its own report.
According to the review depth and mandate, outputs may include
The aim is not only to state a conclusion, but to preserve enough of the reviewed basis for someone else to understand later how that conclusion was reached.
The reviewed record is designed to remain useful beyond the engagement. It can support internal decision-making and subsequent professional review by advisers, customs teams or other reviewers. Where accredited verification is required, the underlying file and Weetra review record can be made available while the verifier performs its own independent procedures.
Start with the CBAM documents already available. Weetra can identify visible gaps, inconsistencies and broken documentary relationships before deciding whether deeper review is justified.
€490 excl. VAT per dossier
The Evidence Check identifies visible weaknesses in the documents supplied. The file can then be corrected independently, stop there, or move to a deeper review only where the issues justify it.
No. Weetra reviews the documentary basis of the file upstream of accredited verification. Statutory verification of actual embedded emissions remains the function of an accredited CBAM verifier.
No. A Weetra output records what the reviewed evidence supports within scope. Authorities, advisers and verifiers retain their own responsibilities and judgement.
Yes. The mandate can be adviser-led so the end client remains the adviser’s client and Weetra provides a specialist documentary review inside that relationship.
The gap remains visible. It may be resolved with new documents, remain impossible to confirm fully, or prevent a material point from being finalised within the reviewed scope.
No. A deeper review examines more of the documentary structure; it does not improve the underlying evidence by itself.
Subject to engagement and confidentiality terms, the reviewed output can support internal or professional use. It does not bind the recipient or replace its statutory role.
