Entity Setup
How CBAM Impacts Entity Setup and Verification Obligations
New CBAM guidance changes how non-EU operators and verifiers must prepare for the definitive period—entity setup, accreditation, and registry registration are now front and center.
By NomadicTax Research Team • 5-8 min read • September 1, 2026
## What is CBAM and its scope
The **Carbon Border Adjustment Mechanism (CBAM)**, in force since 1 January 2026, is the EU’s tool for aligning the carbon cost of imports from third-country operators with EU ETS standards. Importers must report embedded carbon emissions either by using **default values** or **actual emissions verified by accredited verifiers**, while the CBAM Registry handles declarations and compliance. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en?utm_source=openai))
## Recent developments: guidance for verifiers & National Accreditation Bodies
On **24 August 2026**, the European Commission released **new guidance** for CBAM verifiers and National Accreditation Bodies (NABs) focused on verification/accreditation procedures, roles/responsibilities of all parties, and timeline expectations. Also included is a **procedure from 1 September 2026** for verifiers accessing the **CBAM Registry**, which is their gateway to issuing verified emissions reports. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/news/european-commission-publishes-guidance-cbam-verifiers-and-accreditation-bodies-2026-08-24_en?utm_source=openai))
### Key dates & timelines
| Date | Event |
|---|---|
| ~September 2026 | NABs begin accrediting CBAM verifiers. Verifiers can create EU Login accounts, request registry access, and prepare for on-boarding. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en?utm_source=openai))|
| January 2027 | Accredited verifiers issue first verification reports via registry, enabling importers to use **actual verified emissions** rather than default values. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/news/european-commission-publishes-guidance-cbam-verifiers-and-accreditation-bodies-2026-08-24_en?utm_source=openai))|
## Implications for entity setup
To be part of the CBAM ecosystem, non-EU installations, verifiers, and importers must take action:
• **Non-EU operators** need to monitor emissions from their installations since 2026 correctly, align with methodology defined in CBAM regulations, and be ready to share the required data with verifiers. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en?utm_source=openai))
• **Verifiers** must be accredited by the NAB of their country of establishment (or by another NAB if mandated). Once accredited, they must register in the CBAM Registry (but not before 1 September 2026). ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en?utm_source=openai))
• Legal entities should ensure they have the technical competence, independence, and impartiality required to carry out verifications, and that their internal IT and record-keeping systems can respond to registry requirements. Missing or inadequately documented verification could force importers to rely solely on default values. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/news/european-commission-publishes-guidance-cbam-verifiers-and-accreditation-bodies-2026-08-24_en?utm_source=openai))
## Actionable steps for companies considering import/export with CBAM goods
- From now till September: if you aim to become a verifier, initiate application with NAB, set up EU Login access, and compile required accreditation documents.
- Installations exporting CBAM goods should start preparing monitoring plans, collecting emissions data, and familiarizing themselves with calculation methodologies now.
- Importers dependent on non-EU operators should ensure supply chain partners understand CBAM actual-emissions reporting requirements; without timely data, default values may apply.
- Legal counsel and tax/ESG teams should review liability under CBAM (customs, registry, penalties) and integrate into compliance frameworks.
## Example scenario
A steel manufacturer in Vietnam produces steel slabs to export to the EU. To allow its buyer in Germany to use **actual emissions data**, the Vietnamese installation must have emissions measured systematically, hire or partner with an EU-based accredited verifier (via NAB), and ensure the verifier is registered in the CBAM Registry from September 2026. If this chain breaks, the buyer must use EU default values, potentially increasing its costs or exposing them to competitiveness risks.