Guidance on CBAM and Possible Implications for Türkiye

Overview and Key Implications

The Guidance on CBAM Verification and Accreditation for Verifiers and National Accreditation Bodies, published by the European Commission on 24 August 2026, provides comprehensive explanations regarding the verification and accreditation system applicable during the definitive period of the Carbon Border Adjustment Mechanism (CBAM), which commenced on 1 January 2026. The Commission expressly characterises the document not as a new legislative instrument but as explanatory guidance intended to facilitate the implementation of the existing CBAM framework. Accordingly, the Guidance should be viewed not as introducing new legal obligations, but rather as a practical document explaining how the existing CBAM legislation is to be applied.

The primary purpose of the Guidance is to explain in detail how emissions data from installations producing CBAM goods in third countries should be verified and how the entities performing such verification may obtain accreditation. The document is addressed principally to CBAM verifiers and to the National Accreditation Bodies (NABs) of EU Member States responsible for accrediting and supervising those verifiers. At the same time, it contains important practical clarifications for producers and other stakeholders intending to rely on actual emissions data.

One of the key messages of the Guidance is that verification is not limited to reviewing the final emissions figures reported in an annual emissions report. Rather, the Commission treats verification as a comprehensive assurance process conducted at installation level. In this context, the verifier is expected to assess the installation's monitoring plan, production processes, emission sources, data flows, measurement systems, control activities, precursor data, and all information underlying the calculation of embedded emissions. Verification therefore constitutes a comprehensive audit-type exercise aimed at assessing not only the reported data itself but also how that data is generated and whether it can be regarded as reliable.

The Commission also provides detailed guidance on the fundamental principles governing verification activities. According to the Guidance, verification should be based on the principles of completeness, consistency, comparability, accuracy, methodological integrity, and continuous improvement. Verifiers are required to perform their work at a reasonable level of assurance. This approach requires verifiers not merely to accept information provided by operators, but actively to test its reliability, obtain sufficient verification evidence, and apply professional scepticism throughout the verification process. Verifiers are also required to identify misstatements, non-conformities, and instances of non-compliance, assess their materiality, and evaluate their effect on the final verification opinion.

The Guidance describes the verification process as a highly structured and detailed exercise. The process begins with a pre-contract assessment and includes information gathering, strategic analysis, risk analysis, preparation of a verification plan, process analysis, testing of data and control systems, analytical procedures, assessment of the correct application of the monitoring methodology, and evaluation of any data gaps. This approach demonstrates that installations must establish a verifiable data infrastructure well before the end of the reporting period. The Guidance also requires verifiers to maintain comprehensive internal verification documentation, including risk assessments, evidence collected, site visit findings, sampling methodologies, materiality assessments, and the basis for the final verification opinion.

One of the most significant sections of the Guidance from a practical perspective concerns site visits. The Commission maintains physical site visits as a fundamental component of the verification system. Physical visits are regarded as the primary means of examining measurement instruments, interviewing personnel, and comparing the monitoring plan with the installation's actual operations. Nevertheless, virtual site visits or even the waiver of a site visit may be permitted under certain circumstances. These options are not intended as general simplification measures but rather as exceptions subject to specific conditions. In all cases, the verifier must obtain sufficient evidence to reach a reasonable level of assurance. Where adequate assurance cannot be achieved through remote means, a physical site visit remains necessary.

The Guidance places particular emphasis on the independence and impartiality of verifiers. Special attention is given to potential conflicts of interest that may arise where a verifier has participated in the preparation of a monitoring plan, the development of emissions reports, or the provision of consultancy services to the same installation. Common ownership structures, management links, financial relationships, and personnel movements may also undermine independence. In certain circumstances, a separation period of at least two years is cited as an appropriate safeguard. Additional measures such as staff rotation, separation of advisory and assurance functions, and formal independence controls are also encouraged.

With respect to accreditation, one of the most important clarifications provided by the Guidance is that the authority to grant CBAM accreditation rests exclusively with the National Accreditation Bodies of EU Member States. Verification bodies established in third countries may apply to NABs offering CBAM accreditation services. However, NABs are not obliged to accept applications from third-country entities. The Guidance further explains that existing accreditations obtained under standards such as ISO 17029 and ISO 14065 may be considered evidence of competence and may facilitate the accreditation process. Nevertheless, such accreditations do not replace CBAM accreditation, which must ultimately be granted by an EU NAB. Accreditation assessments include document reviews, audits at the verifier's premises, and at least one witness audit. Accreditation may remain valid for a maximum period of five years and is subject to ongoing surveillance and reassessment.

The Guidance also establishes a simplified pathway for entities already accredited as EU ETS verifiers. However, the Commission makes clear that prior EU ETS experience alone is insufficient. Additional expertise is required in relation to CBAM-specific matters, including monitoring plan assessments, precursor data, indirect emissions, and related calculation methodologies. Existing EU ETS accreditation may therefore facilitate the accreditation process, but it does not remove the need to demonstrate the additional competencies required for CBAM accreditation.

Under the system established by the Commission, accreditation alone is not sufficient. Verifiers must also be registered in the CBAM Registry before they can operate within the CBAM verification framework. According to information published by the European Commission, Registry access for accredited verifiers will become available from 1 September 2026, following verification of their accreditation status by the relevant National Competent Authority (NCA). The Commission has further indicated that accredited and registered verifiers will be able to generate verification reports through the CBAM Registry from January 2027, enabling declarants to use verified actual emissions data in respect of imports made during 2026.

Possible Implications for Türkiye

The Guidance is particularly significant for Türkiye in terms of the development of CBAM verification capacity and the future role of Turkish verification bodies during the definitive period. As Türkiye is one of the European Union's major trading partners for CBAM-covered goods, Turkish producers wishing to rely on actual embedded emissions rather than default values will require access to a reliable and accessible verification infrastructure. The Guidance provides important clarification regarding the operation of that infrastructure, particularly in relation to accreditation and verification procedures.

One of the most important implications for Türkiye is that verification bodies established in third countries may apply for CBAM accreditation. The Guidance does not impose a requirement to establish a separate legal entity within the European Union as a condition for applying for CBAM accreditation. In practice, the availability of NABs willing to accept applications from third-country entities may become an important consideration for Turkish verification bodies seeking to obtain CBAM accreditation.

A second important point is the distinction between TÜRKAK accreditation and CBAM accreditation. The Guidance recognises that accreditations granted in third countries under relevant international standards may serve as evidence of competence. However, the final accreditation required to obtain CBAM verifier status must be granted by an EU Member State NAB. As a result, verification bodies in Türkiye that already possess significant experience in greenhouse gas verification and hold TÜRKAK accreditation may benefit from an important starting advantage. Nevertheless, they will still be required to complete the relevant NAB accreditation process in order to become CBAM verifiers.

The Guidance also demonstrates that, from the perspective of Turkish exporters, verification is not simply a matter of appointing a verifier at the end of the reporting period. In order to use actual embedded emissions, monitoring plans, data flows, measurement systems, control activities, and supporting documentation must be designed in a manner that allows for effective verification. Consequently, installations operating in sectors such as iron and steel, aluminium, cement, fertilisers, and hydrogen should begin preparing for verification well before the end of the reporting period.

The site visit framework may also have practical implications for operators and verification bodies in Türkiye. As physical site visits remain the default verification approach, the implementation of verification activities may, in some circumstances, require additional planning, logistical coordination, and resources, particularly where verifiers are located outside Türkiye. Over time, the accreditation of verification bodies established in Türkiye could contribute to the development of domestic verification capacity and broaden the availability of verification services for exporters.

The Guidance further demonstrates that the CBAM verification framework should not be confused with the national ETS and MRV systems currently being developed in Türkiye. A verifier authorised or accredited under Turkish national legislation will not automatically become a CBAM-accredited verifier on the basis of that status alone. Compliance with the separate accreditation and Registry requirements established under EU law remains necessary. At the same time, greater alignment between the two systems could reduce administrative burdens by enabling installations to rely on more consistent monitoring, reporting, and verification infrastructures for different regulatory purposes.

Finally, the Guidance points to a broader strategic issue for Türkiye. The ability to use actual emissions under CBAM is not merely a technical reporting matter. It may also have implications beyond technical reporting and compliance considerations. In particular, for installations whose emissions intensity is lower than the applicable default value, the ability to demonstrate actual emissions through a robust monitoring and verification framework may become increasingly relevant in the context of CBAM compliance. Accordingly, in the coming years it may be useful to monitor not only the level of CBAM compliance achieved by Turkish producers, but also the extent to which a sufficient pool of CBAM-accredited verifiers with appropriate sectoral expertise becomes available to support exporters operating in CBAM-covered sectors.

 @Zeynep EMİROĞLU