Every verified installation needs a site visit in its first verification year

National accreditation bodies are expected to grant the first CBAM accreditations around September 2026, and accredited verifiers can register in the CBAM Registry from the same month. The first declaration, covering 2026 imports, falls due in September 2027. Between those two dates sits a requirement that cannot be negotiated away: in the first year an installation is subject to verification, a physical site visit is mandatory in all cases, with a narrow exception under Article 4 for serious, extraordinary and unforeseeable circumstances that prevent the verifier from travelling.

That rule holds for one year only. What replaces it afterwards is conditional on the plant itself.

The relief valve comes with a condition attached

Implementing Regulation (EU) 2025/2546 lets a verifier replace the physical visit with a virtual one, or waive it altogether, from a later reporting period. What opens up when is easy to get wrong.

Which visit types are open to a verifier in each reporting period, and what each relaxation depends on. Source: Implementing Regulation (EU) 2025/2546, Articles 2 to 4 and Recital 3. Own diagram.

A virtual visit needs a physical visit in the immediately preceding reporting period, and a full waiver needs physical visits in two preceding periods (electricity-only installations follow a looser rule: one physical visit within the last five periods). Nobody reaches either in 2026. The condition starts to bite for the 2027 verification year, which is when operators will first argue that nothing at their plant has changed.

Article 3(1) attaches seven cumulative conditions to that argument, and the seventh is not an administrative formality. Article 3(1)(g) requires that the installation or its monitoring plan "has not undergone any significant changes or modifications since the last physical site visit".

The regulation then defines what counts. Seven categories of change disqualify a virtual visit or a waiver, and they are a mix of physical and paper alterations:

The right-hand column is this article's reading, not the regulation's wording. It matters because only one kind of change leaves a trace anybody outside the installation can look for.

Some of those changes are visible from outside

Two of the seven categories describe physical construction on the site. A new production route involves constructing new buildings or equipment. A transfer line is a real physical object, a pipe, conveyor, road or rail, that links one part of the facility to another.

Claims of that kind are claims about the actual built condition of an industrial site between two dates, and the standard way to test them is repeated satellite imagery.

Flagging that something changed is the cheaper half of the job. Radar can do it through cloud, which makes it the better tool over South and South-East Asia, where the sky stays closed for months at a time.

But establishing what was actually built needs a sharper second look, and a buyer who wants high resolution optical satellite imagery over a named site can task it through Sfera Technologies alongside archive scenes covering the earlier date.

The capability is documented rather than promotional. A January 2026 study by Gu and colleagues in Remote Sensing Applications: Society and Environment, detecting new buildings from Sentinel-1 radar time series, reported an F1 score of 0.83, with recall of 0.87 and precision of 0.79, tested across Paris, Johor Bahru, Pyongyang and Phoenix. Adding a Landsat optical algorithm improved the result by a comparatively small margin.

What the report pins down

The verification report is where the installation stops being a company name. Its template sets out, field by field, what must identify the installation under verification:

• The name of the operator, its registration number and its full address in English
• The name of the installation and its unique identifier in the CBAM Registry
• The UN/LOCODE of the location
• The full address in English, and the geographical coordinates in longitude and latitude, down to six decimal places

Six decimal places is a survey point rather than a postal address. It is roughly eleven centimetres of latitude, which is a level of precision no delivery ever needs.

The same report summarises the installation's monitoring plan, and that summary has to list all CBAM production processes and production routes carried out on site. Location and route are therefore both attested rather than asserted, by a verifier who has physically stood there and whose accreditation number appears on the document.

That is what makes the following year's claim checkable. A later argument that nothing significant has changed is then measured against a fixed, dated reference point, not against memory.

Who gets a verifier at all

Verification is not a universal audit on every import but the price of using actual values. A declarant relying on the Commission's default values under Implementing Regulation (EU) 2025/2621 needs no verifier, no site visit and no cooperation from the producer.

What that declarant pays instead is a mark-up on the default value, rising from 10% to 30% between 2026 and 2028, with fertilisers on a separate 1% track.

The reason given for phasing it in rewards a second reading. The increase is gradual because the number of verifiers may grow in the first years after the transitional period, particularly in 2026. The Commission wrote the shortage of verifiers into the price schedule.

One consequence catches importers out. Verified actual values exist only if the third-country operator takes part: an importer cannot obtain a valid verification report without the producer's cooperation, which makes the choice between actual and default values a matter of whether the supplier cooperates, not of budget.

What the visit costs, and what nobody has published

The cost of the mandatory visit is quoted freely and sourced poorly. Figures in the range of five to fifty thousand euros per installation circulate widely, including in this site's own guides, but the traceable origins are verification vendors and compliance service providers rather than the Commission, a national authority or the trade press.

The last clear official figure is old. The Commission's 2021 impact assessment cited verification cost estimates starting at roughly four thousand euros per installation, which predates the final rules, the accreditation framework and the first-cycle physical visit obligation. Anyone budgeting from that number is budgeting from a different regime.

Nor is there a defensible published ratio of accredited verifier capacity against the number of installations needing a first physical visit before September 2027. Concern about the gap is real and documented, most visibly from Turkish cement producers earlier in 2026, but no credible source has published the arithmetic behind it.

What imagery does not settle

The limits deserve as much space as the capability, because overstating this is how a useful check becomes a liability.

• Nothing in Regulation 2025/2546, 2025/2547 or Delegated Regulation 2025/2551 lets a verifier substitute independently sourced data for the operator's records, so imagery belongs in the buyer's own due diligence rather than in the verification file
• Telling a blast furnace route from an electric arc furnace by shape alone has no published accuracy figure, but what does show up is heat. Coke ovens and blast furnace stoves run hot enough for infrared sensors to pick them out, so a heat source that stays in the same place over months points to the integrated route. An electric arc furnace melts scrap inside a closed vessel and leaves no comparable trace
• Absence proves much less than presence: no hotspot on a given date can mean cloud, maintenance or a viewing angle, and no visible demolition does not mean the equipment inside still runs
• Sharper is not automatically better. At very high resolution the same roof or yard varies more from pixel to pixel, and the two dates have to be aligned far more precisely, so coarser imagery often wins for the simple question of whether anything changed
• Seeing that a plant operated tells you nothing reliable about tonnage, and tonnage tells you nothing reliable about emissions per tonne, so satellite evidence can support or contradict a declaration but never replace verified activity data

Taken together these limits point the same way. Imagery is good at one question only, the one Article 3(1)(g) actually asks, and poor at almost every other question a CBAM file contains.

What is worth doing before September

For the 2026 reporting year the question is settled: every installation whose actual values a declarant wants to use gets a physical visit, and finding a verifier with the right accreditation scope is the constraint that matters.

The question that opens next year is different. When a supplier proposes that the 2027 verification proceed without a visit, somebody has to be comfortable that the site is materially as it was. That comfort currently rests on the operator's own account of itself, checked by a verifier who last stood there twelve months earlier.

A dated record of what the site looked like at the last physical visit costs very little to establish and is awkward to argue with later. It will not appear in the verification report, and it should not. It changes what the declarant knows before signing something.