CBAM Internal Audit Checklist Template 2026 (Free PDF Download)
Reviewed against current law:
General Summary
The CBAM internal audit checklist is a PDF with 17 tick-box items in 4 sections that produces a dated self-assessment of an importer's CBAM process. Compliance managers, internal auditors and customs leads at authorised CBAM declarants use it to find gaps before the Commission or a national competent authority reviews a declaration. It tests governance, data quality, controls, and records and retention.
What This Checklist Covers
The checklist covers 4 sections, from who owns CBAM to how long the records are kept.
| Section | Items | What you test |
|---|---|---|
| Governance | 3 | Named owner, documented process, management reporting |
| Data quality | 5 | Source and date of supplier data, actual or default basis, verification, carbon price evidence, traceability |
| Controls | 5 | Quarter-end reconciliation, deadline ownership, threshold monitoring, regulatory watch, audit trail |
| Records and retention | 4 | Annex V minimum data, extra data for actual emissions, four-year retention |
How to Use It
- Set the scope. Download the PDF and choose the declaration year and the import flows the review covers.
- Test governance. Confirm who owns CBAM, where the process is written down and how management is informed.
- Sample the data. Pick import lines and trace each emissions figure back to the supplier file, the installation and, for actual emissions, the verification report.
- Check the controls. Review the quarter-end reconciliations, the deadline calendar and the 50 tonne threshold monitor.
- Inspect the records. Compare the files against the Annex V minimum data and the four-year retention period.
- Log the gaps. Record each unticked item with an owner and a date, then repeat the review before the next declaration.
What the Regulation Requires Here
Article 7(5) of Regulation (EU) 2023/956 requires an authorised CBAM declarant to keep records of the information needed to calculate embedded emissions, as listed in Annex V.
Those records must be detailed enough for an accredited verifier to verify the emissions and for the Commission and the competent authority to review the declaration. Article 7(6) sets the retention period: until the end of the fourth year after the year in which the CBAM declaration has been or should have been submitted. Evidence for a carbon price reduction follows the same period under Article 9(3).
The review window matches it. Under Article 19(2) the Commission, and the competent authority of the Member State of establishment, may review a declaration within the period ending with the fourth year after the year in which it should have been submitted, including through an audit at the declarant's premises. Records for the 2026 declaration, due September 30, 2027, therefore stay on file until December 31, 2031.
Background reading: CBAM record keeping guide and CBAM verification guide. For the mechanism as a whole, start with the EU CBAM overview.
Related templates
- CBAM Declaration Checklist Template 2026 (Free PDF Download)
- CBAM Certificate Tracker Template 2026 (Free CSV Download)
- CBAM Monitoring Plan Template 2026 (Free CSV Download)
- All CBAM templates and checklists
Frequently Asked Questions
How long must CBAM records be kept?
Until the end of the fourth year after the year in which the CBAM declaration was or should have been submitted (Article 7(6)). For the first declaration, due September 30, 2027, that is December 31, 2031.
Which records does Annex V require?
The declarant name and CBAM account number, the type and quantity of each type of goods, the country of origin, and the actual emissions or default values. For actual emissions it adds the installation, the operator contact, the verification reports, the specific embedded emissions and the calculation method.
Who can review a CBAM declaration?
The Commission and the competent authority of the Member State where the declarant is established (Article 19(2)). A review can include an audit at the premises of the authorised CBAM declarant.
Is this checklist an official audit standard?
No. It is a self-assessment from cbamguide.com. The binding duties are in Article 7(5) and (6) and Annex V of Regulation (EU) 2023/956.
CBAM Brief (EUR 199 a month) emails you when a certificate price, default value, CN code or deadline changes.
This template is a starting point, not an official form, and not legal advice. The binding text is Regulation (EU) 2023/956 and its implementing acts. Content reviewed on October 12, 2026.