Commission Implementing Regulation (EU) 2025/2546 of 10 December 2025 on the application of the principles for verification of declared embedded emissions pursuant to Regulation (EU) 2023/956 of the European Parliament and of the Council

For the purposes of this Regulation, in addition to the definitions laid down in Article 1 of Commission Delegated Regulation (EU) 2025/2551 and Article 1 of Commission Implementing Regulation (EU) 2025/2547 , the following definitions apply: (1) ‘misstatement’ means an omission, misrepresentation or error in the operator’s reported data, not considering the uncertainty associated with measuring instruments or laboratory analyses; (2) ‘material misstatement’ means a misstatement that, either individually or when aggregated with other misstatements, exceeds the materiality level or could, based on the expert judgement of the verifier, because of its size and nature, have an impact on the total reported emissions or other relevant information; (3) ‘materiality level’ means the quantitative threshold or cut-off point above which the verifier considers misstatements, either individually or when aggregated with other misstatements, to be material; (4) ‘non-conformity’ means any act or omission of an act by the operator that does not meet the requirements of the monitoring plan or of the monitoring methodology applicable to the specific installation, as laid down in Implementing Regulation (EU) 2025/2547; (5) ‘material non-conformity’ means a non-conformity that causes a material misstatement.

1 The verifier may replace a physical site visit referred to in Section 2.12 of Annex II to Delegated Regulation (EU) 2025/2551 with a virtual site visit where the conditions laid down in Article 3 or 4 are met.

2 The verifier may waive the obligation to carry out a physical site visit referred to in Section 2.12 of Annex II to Delegated Regulation (EU) 2025/2551 where the conditions laid down in Article 3 are met.

3 The verifier shall inform the operator of its decision to replace the physical site visit by a virtual site visit or to waive the obligation to carry out a physical site visit without delay.

1 The verifier may decide to carry out a virtual site visit or to waive the obligation to carry out a physical site visit provided that all of the following conditions are fulfilled: (a) a verifier has carried out a physical site visit during the reporting period immediately preceding the current reporting period; (b) in the case of a waiver of the obligation to carry out a physical site visit, a verifier has carried out a physical site visit during two reporting periods preceding the current reporting period; (c) the verifier has sufficient understanding of the installation’s functioning, the production processes and the monitoring and reporting system, including the operator’s control system; (d) the verifier considers that the nature and level of complexity of the installation’s monitoring and reporting system as well as the inherent and control risks are such that they do not require a physical site visit; (e) the verifier is able to obtain and assess remotely all information required for the verification, including on the correct application of the methodology described in the monitoring plan, the data reported in the operator’s emissions report, the production processes and precursors used; (f) the decision to carry out a virtual site visit or to waive the physical site visit is based on the results of the risk analysis, and the verifier has identified and taken the necessary measures to reduce the verification risk to an acceptable level to obtain reasonable assurance that the operator’s emissions report is free from material misstatements and non-conformities; (g) the installation or its monitoring plan has not undergone any significant changes or modifications since the last physical site visit, including any of the following significant changes: (1) starting of new production processes or production route or closing of production processes or production route; (2) changes in the joint production process of precursors and complex goods, as defined in Article 4(9) of Implementing Regulation (EU) 2025/2547 on the calculation of embedded emissions; (3) changes in the energy supply of the installation; (4) changes of technical connections between production processes or production routes, such as additional or removed lines for transfer of fuels, materials, measurable heat, waste gases or goods produced; (5) where actual values are used, changes relating to precursors produced at the installation or received from other installations; (6) a change of monitoring methodology (calculation-based, measurement-based, other); (7) changes that the verifier identified during the strategic analysis or risk analysis as requiring significantly different verification approaches than those applied during the previous verification, such as the addition of new fuels or materials, or the addition of new measuring instruments.

2 The verifier may waive the obligation to carry out a physical site visit of the installation where electricity is produced, provided that all of the following conditions are fulfilled: (a) electricity is the only good covered by Annex I to Regulation (EU) 2023/956 produced by the installation; (b) the installation does not use any materials, fuels, or production processes with the potential to emit greenhouse gases during normal operation. The following installations shall not be regarded as compliant with this criterion: (1) installations using biomass as defined in Section 1, point 9, of Annex I to Implementing Regulation (EU) 2025/2547; (2) installations carrying out carbon capture, including for the purpose of geological storage or for use of the GHG in the production of fuels or other materials; (3) installations transferring greenhouse gases to other installations, pipelines or CO2 transport infrastructures as defined in Article 3(29) of Regulation (EU) 2024/1735 of the European Parliament and of the Council . (c) a verifier has carried out at least one physical site visit in the last five reporting periods immediately preceding the current reporting period; (d) the conditions laid out in paragraph 1, points (c) to (f) are fulfilled.

The verifier may decide to carry out a virtual site visit provided that the following conditions are fulfilled: (a) the verifier is prevented from carrying out a physical site visit due to serious, extraordinary and unforeseeable circumstances outside the control of the operator, and those circumstances cannot, after using all reasonable efforts, be overcome; (b) the decision of the verifier to carry out a virtual site visit is based on the results of the risk analysis; (c) the verifier has identified and taken the necessary measures to reduce the verification risk to an acceptable level to obtain reasonable assurance that the operator’s emissions report is free from material misstatements.

1 When assessing misstatements on reported data in the reporting period subject to verification, the verifier shall, for each tonne of the relevant good, identified by its Combined Nomenclature (CN) code, apply the following materiality levels: (a) 5 % of the total specific embedded emissions; (b) 5 % of the total specific embedded free allocation.

2 The verifier shall also use expert judgement as to whether misstatements or non-conformities, individually or when aggregated with other misstatements or non-conformities, justified by their size and nature, are to be considered material, for: (a) misstatements, individually or when aggregated with other misstatements, which are below the materiality level pursuant to paragraph 1; (b) parameters which are not referred to in paragraph 1.

The verification report shall be prepared based on an electronic template provided by the Commission via the CBAM Registry. The electronic template shall contain at least the information listed in the Annex to this Regulation.

This Regulation shall enter into force on the third day following that of its publication in the Official Journal of the European Union. It shall apply from 1 January 2026.