Introduction: The Quiet Bottleneck in CBAM
Accredited CBAM verifiers are not expected in numbers until autumn 2026, yet every 2026-import emissions dataset that uses actual values must be verified before the first declaration on 30 September 2027. That is a narrow window through a small door.
Most CBAM coverage focuses on rules and costs. Far less is said about a practical constraint that could decide who can use verified actual data at all: whether there are enough accredited verifiers to go round. The early signals suggest the answer, for a while, is no.
The Timeline Math
CBAM’s definitive period began on 1 January 2026, but verifiers cannot access the CBAM Registry before 30 September 2026, and the first accredited verifiers are not expected in numbers until autumn 2026. The first annual declaration and certificate surrender — covering 2026 imports, with verified actual data — falls on 30 September 2027. In practice that compresses most verification into a window of roughly twelve months.
A Small, Slow-Growing Pool
Accreditation is handled by EU/EEA National Accreditation Bodies. According to European Accreditation, around 21 accreditation bodies intend to issue CBAM accreditations, but only seven have declared they will accredit verifiers established in non-EU countries — precisely where most exposed installations sit. National pools are small: Poland’s PCA, for example, showed roughly six CBAM-verification firms in early 2026.
| Signal | What it means |
|---|---|
| ~21 NABs issuing CBAM accreditation; 7 willing to accredit non-EU verifiers | Capacity for third-country installations is the tightest part of the system |
| First verifiers in numbers only from autumn 2026 | Roughly a 12-month run-up to the 30 Sep 2027 deadline |
| National competent authorities (e.g. France) warning of insufficient capacity | The concern is official, not just commentary |
Why Non-EU Producers Feel It First
A verifier established outside the EU must be accredited by an EU/EEA National Accreditation Body that offers CBAM accreditation — and only a handful do. With a large number of production sites worldwide and limited verifier capacity, on-time verification without early preparation is, in many cases, unlikely. For a non-EU steel or aluminium producer that wants its EU customers to use favourable actual values, getting in the queue early is itself a competitive move.
The Honest Caveat: Demand Is Uncertain
There is a genuine unknown on the other side of the ledger: operators can choose to use default values instead of commissioning verification. Because of that escape hatch, no one yet knows how many installations will actually request verification. The crunch is therefore a risk, not a certainty — but it is a risk that falls hardest on exactly the low-carbon producers for whom verification pays off most.
What to Do Now
- Decide early whether verified actual data beats your default value (see what CBAM actually costs). If it does, you are a candidate for the queue.
- Build your installation-level data now, so a verifier’s job is fast when capacity arrives — this is the longest lead-time item and entirely in your control.
- Engage a verifier ahead of the rush, rather than competing for slots in 2027.
How EPD Polska / Multicert Can Help
We prepare your emissions data under the CBAM methodology and get it verification-ready, so that when accredited capacity is available the verification step is quick and low-risk — and we coordinate the accredited verifier. Contact us to get ahead of the queue.