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Documented Evidentiary Due Diligence

A reviewed file should still make sense years later.

A WEETRA review connects the evidence examined, the facts relied upon, the contradictions and limitations identified, the clarifications or remediation undertaken and the final Determination. The outcome is not only a report. It is a preserved, reviewable evidentiary state.

ConceptWEETRA review practice
OutputDetermination Package
IntegritySHA-256 reference hashes
Regulatory basis

Primary regulatory anchors behind this page.

The references below separate what the law requires from how WEETRA structures evidentiary review and from controls that WEETRA adds for robustness. This is particularly important where a later reviewer must understand not only the conclusion, but the exact documentary state that existed when it was reached.

Regulatory basis
Evidence retention and later reviewRegulation (EU) 2023/956 · Art. 7(5)-(6) · Annex V · Art. 19(2)
Installation and operator recordsRegulation (EU) 2023/956 · Art. 10(5)-(6)
The WEETRA Determination is an internal review construct
WEETRA evidentiary response
  • WEETRA tests whether the reviewed corpus preserves the source, fact and period relationships needed to reconstruct the evidentiary state later.
  • WEETRA can map operator, installation, period and evidence relationships so disclosed information can be examined in context.
  • WEETRA uses controlled Professional Review and locking to state what the reviewed evidence supports, blocks or leaves unresolved within the mandate.
Additional WEETRA control

Version references, Evidence Manifests and SHA-256 integrity references are WEETRA controls. The Regulation does not prescribe those specific tools.

Evidence retention and later review

Official sourceRegulation (EU) 2023/956 · Art. 7(5)-(6) · Annex V · Art. 19(2)

Regulatory requirement

Records supporting embedded-emissions calculations must be sufficiently detailed for verification and later review, and retained until the end of the fourth year after the relevant declaration year.

WEETRA evidentiary response

WEETRA tests whether the reviewed corpus preserves the source, fact and period relationships needed to reconstruct the evidentiary state later.

Additional WEETRA control

Version references, Evidence Manifests and SHA-256 integrity references are WEETRA controls. The Regulation does not prescribe those specific tools.

Installation and operator records

Official sourceRegulation (EU) 2023/956 · Art. 10(5)-(6)

Regulatory requirement

Registered non-EU operators must retain verification reports and calculation records for four years, with sufficient detail for verification and review.

WEETRA evidentiary response

WEETRA can map operator, installation, period and evidence relationships so disclosed information can be examined in context.

The WEETRA Determination is an internal review construct

Official sourceWEETRA internal governance boundary · not a statutory CBAM function

Regulatory requirement

The CBAM legal framework does not prescribe a function called a “WEETRA Determination”. Regulatory verification, declaration responsibilities and authority decisions remain separate statutory functions.

WEETRA evidentiary response

WEETRA uses controlled Professional Review and locking to state what the reviewed evidence supports, blocks or leaves unresolved within the mandate.

Additional WEETRA control

Status taxonomy, Evidence Map, Contradiction Register, Remediation Register, locked states and integrity references are WEETRA governance mechanisms.

Primary legal texts prevail. Commission guidance is explanatory and is identified separately from binding law.

WEETRA structures the evidentiary record behind a regulatory Determination. It links the documentation examined, the facts relied upon, the contradictions, the limitations and the clarifications or remediation undertaken to the final conclusion.

The result is not simply a report. It is a preserved, reviewable evidentiary state.

What documented evidentiary due diligence means

Depending on the review level and mandate, the process can make it possible to demonstrate

  • What evidence was received
  • When it entered the controlled workflow
  • Which version was examined
  • Which facts were extracted or recomputed
  • Which source supported each material fact
  • Which contradictions or documentary gaps were identified
  • Which requests for clarification or remediation were issued
  • Which points required professional judgement and how they were resolved
  • Which evidentiary state supported the final determination.
Due diligence does not make uncertainty disappear. It makes the work performed, the basis relied upon and the limitations known at the time demonstrable.

What a documented review preserves

The following is the WEETRA reference model. The depth of each stage, and the deliverables attached to it, depend on the agreed review level and contractual scope.

  1. 01

    Documents received and identified

    Documents enter through the controlled workflow. A SHA-256 hash is calculated at ingestion, and each file is recorded with its filename, size, type, uploader and server timestamp.

  2. 02

    Versions and source relationships

    Each file becomes a registered evidence record. Records are append-only. A later correction is linked to the original through a supersedes reference rather than replacing it.

  3. 03

    Facts relied upon

    Material facts are extracted or recomputed where appropriate and kept tied to the source that supports them.

  4. 04

    Cross-source examination and recalculation where applicable

    Structured controls run across and within the evidentiary domains, comparing declared, extracted and, where possible, recalculated values.

  5. 05

    Contradictions and source limitations

    Where the record conflicts with itself, or a source cannot carry a claim, the contradiction or limitation is recorded rather than smoothed over.

  6. 06

    Clarification and remediation where included

    When the mandate provides for it, requests for clarification or correction are issued, and their outcomes are recorded.

  7. 07

    Professional review

    Where professional judgement is required, an authorised reviewer examines the relevant evidence and unresolved conditions before WEETRA issues any Determination. No conclusion is assigned automatically.

  8. 08

    Final Determination

    Only an authorised reviewer holding the required review authority may lock a Determination. The locked state records the reviewer identity and role, the timestamp, the Determination, its reasoning, the relevant version references and the integrity references.

  9. 09

    Preserved evidentiary state

    Depending on the level, a versioned Evidence Manifest and a Determination Package are assembled and preserved, linked to the exact versions relied upon.

  10. 10

    Later reconstruction and integrity checking

    A file presented later can be compared against a recorded reference hash to confirm whether it is the same version.

No evidence is silently replaced, and no historical version is overwritten.

The Determination Package

Depending on the review level and mandate, the package may include

  • The final Determination Report
  • The documentary inventory
  • The Evidence Manifest
  • The evidence register
  • The material fact record, or the relevant extracts
  • The control results relied upon
  • The contradiction and limitation register
  • The remediation history
  • The record of material review decisions
  • The determination lock record
  • The Evidence Map
  • SHA-256 reference hashes
  • Package and report version information
  • The external-verification preparation view, where included.

Each locked determination stays linked to the exact versions of the facts and evidence relied upon at the moment of decision.

The report communicates the conclusion.

The Determination Package preserves the basis from which that conclusion can be reconstructed.

How the package is organised

The package is built in two usability layers. One written to be read, one preserved to be reconstructed.

Human-readable layer

Written to be read

  1. 01Determination Report
  2. 02Executive Evidence Map
  3. 03Findings and limitations
  4. 04Remediation history
  5. 05External verification preparation
  6. 06Evidence Manifest

Composition depends on review level and contractual mandate.

Reconstruction / audit layer

Preserved to be reconstructed

  • /Evidence
  • /Facts
  • /Controls
  • /Contradictions
  • /Limitations
  • /Remediation
  • /Review
  • /Integrity

Not every review level receives every internal register. Scope depends on review level and contractual mandate.

From documents to a chain of explanation

A review does not follow a single perfectly linear path. A control may support a fact, expose a contradiction, reveal a source limitation or leave a gap unresolved. What follows is the reference structure, including the branches a file may actually take.

Document versioning and correction

  • A client cannot silently delete or replace evidence
  • An incorrect submission can be withdrawn through a controlled correction request
  • The original remains preserved
  • A new version is recorded separately
  • Superseded versions remain traceable
  • The current version and the historical versions are never confused.
Correction does not erase history. It adds a documented new state.

Integrity verification

SHA-256 lets a presented file be compared with a recorded reference hash.

A matching result confirms that the presented file has the same byte sequence as the referenced WEETRA file. A non-matching result indicates that the presented file is not identical to that reference version.

A mismatch can come from editing, format conversion, re-saving, replacement, corruption, or the use of another version. It is a difference in bytes, nothing more, and it is read as such.

How the reviewed record can be used after the engagement

The package may help an organisation

  • Present a structured documentary basis to an internal reviewer
  • Prepare exchanges with an authorised CBAM declarant
  • Organise information for an accredited verifier
  • Respond more coherently to a competent authority or a customs-related request
  • Explain how a determination was reached
  • Tell the historical reviewed state apart from later changes
  • Avoid rebuilding a file from scattered emails and uncontrolled document versions.
On use of the package

The package may be presented or relied upon as an organised evidentiary record, subject to the applicable legal framework, confidentiality rules and the recipient's own assessment.

Preparation for independent verification

The Determination Package preserves the documentary basis, review history, identified limitations and remediation state that may be relevant when preparing for or responding during independent verification. The accredited verifier then performs its own regulated procedures and reaches its own conclusion.

Organised in this way, the package may help address questions such as

  • Which installation is connected to the goods
  • Which reporting period applies
  • Which monitoring basis is documented
  • Whether actual or default values are relied upon
  • Whether precursor evidence is complete
  • Whether a verification report is available where relevant
  • Whether the report period corresponds to the claimed emissions period
  • Whether the verifier identity and relevant scope information are documented
  • Which documentary issues remain open
  • Which remediation steps have been completed.

Example. How the package may organise these elements

Illustrative example. Not a score, not a rating, and not a WEETRA determination

Illustrative example of the documentary elements a Determination Package may organise when preparing for an independent verification process.
ElementDocumentary state Evidence referenceOpen issueRemediation status
Installation identityDocumentedEV-014None recordedNot required
Reporting periodDocumentedEV-002None recordedNot required
Monitoring basisPartially documentedEV-021Method description incompleteClarification requested
Actual / default value basisDocumentedEV-023None recordedNot required
Precursor linkageSource limitedEV-031Supplier records incompleteIn progress
Verification report availabilityNot provided, Document not suppliedRequested
Verification-period alignmentNot assessable, Depends on document abovePending
Verifier identityNot provided, Document not suppliedRequested
Accreditation / scope evidenceNot provided, Document not suppliedRequested
Open documentary issueRecordedCR-004Contradiction between two sourcesProfessional review required
On this example

The states above are textual records of a documentary situation at a point in time. They are not a score, a rating or a percentage, they are not a WEETRA determination on verification, and they do not predict or bind the conclusion of an accredited verifier.

Review levels

LEVEL I

CBAM Documentary Review, Level I

  • Reference versions identified
  • Documentary evidence organised for review
  • Determination issued where applicable
  • Final review report.

A complete client-facing Evidence Manifest is not automatically included.

LEVEL II

CBAM Evidence Chain Review, Level II

  • Extended documentary mapping
  • Evidence and contradiction registers
  • Remediation history where included
  • Client-facing Evidence Manifest
  • Covered file hashes
  • Structured Determination Package.
LEVEL III

CBAM Forensic Evidence Review, Level III

  • Advanced evidence-chain reconstruction
  • Adversarial review
  • Deeper contradiction analysis
  • Exact version linkage
  • Enhanced preparation for external scrutiny
  • Advanced evidentiary package.

The levels describe the depth of review and package construction. They are not quality grades, and they do not represent increasing guarantees of regulatory acceptance.

Precise boundaries

Boundaries

Documented Evidentiary Due Diligence is WEETRA’s method for preserving a reviewable evidentiary state. The Determination Package records the review performed, the evidence available, the limitations identified and the conclusion reached at a defined cut-off. Regulatory, legal, customs and accredited-verification responsibilities remain with the actors empowered to exercise them. Mandate & Boundaries →

Evidence governance

Preserve today the evidentiary state you may have to explain tomorrow.

WEETRA helps organisations move from scattered documentation to a structured, reviewable and preserved determination record.