Yes. From 2026 onward, CBAM reports must be verified by EU-accredited independent bodies. This verification must follow detailed protocols issued by the EU Commission and be carried out by organizations listed in the official CBAM verifier registry.

● Certificate purchase
Certificates are sold via a central EU platform by Member States.
Pricing is based on the average weekly closing price of EU ETS allowances.
● Certificate surrender
By May 31 each year, authorized declarants must surrender certificates equal to the prior year’s embedded emissions
By each quarter's end, at least 80% coverage of total emissions must be maintained in the CBAM registry account
● Certificate buy-back (refund)
Certificates are valid for two years
Before June 30, declarants may request buy-back of up to one-third of unused certificates from the previous year
Refund is made at the original purchase price
● Certificate cancellation
By June 30, certificates purchased two years earlier but unused will be automatically cancelled by the Commission

Green certificates (RECs, GOs) are not accepted as evidence to lower emissions under CBAM. However, PPA-based renewable electricity is recognized. If a company uses green electricity under a valid Power Purchase Agreement, the electricity-related emissions can be excluded from indirect emission calculations. This offers a way to gain recognition for energy transition investments.

(Updated to reflect current enforcement stage):
Yes. From 2026, CBAM is in full enforcement. Declarants who fail to report accurately, underreport emissions, or submit unverifiable data are subject to penalties ranging from €10 to €50 per ton of CO₂.
Although legal responsibility lies with the EU importer, exporters may bear indirect liability via contractual or supply chain obligations.