Discrepancies between previously published accreditation information and revised Italian records are creating additional due-diligence requirements for companies arranging verification under the EU Carbon Border Adjustment Mechanism (CBAM). The issue concerns whether individual verification companies hold the specific authorisations needed for particular sectors, industrial activities and emissions categories.
The changes relate to RINA Services and SGS ICS Italia, two verification organisations accredited by Italy’s national accreditation body, Accredia. A revised Accredia decision dated 9 October identifies activity-group scopes that differ from details communicated in an earlier announcement.
Under the revised record, RINA Services holds accreditation for groups I–VIII, L, LI and LII. The listed scope includes electricity verification under group LI and finished iron, steel and aluminium products under group VIII.
For SGS ICS Italia, the revised document identifies groups I, II, IV, VI, VIII, L, LI and LII. These entries differ from previously published information, changing the apparent coverage of several verification activities.
Accreditation must match the specific activity
CBAM accreditation does not confer unrestricted authority to verify every category of covered goods or emissions. Authorisation applies to defined activity groups, which cover different industrial processes, product categories, electricity and indirect emissions.
Consequently, an EU importer commissioning verification for imported electricity, crude steel, aluminium or finished metal products must confirm that the exact legal entity contracted holds the required accreditation. A company’s general claim that it is “CBAM accredited” does not establish that it can undertake every type of verification.
Electricity is a particularly important example. Verification of imported electricity requires accreditation covering activity group LI. Accreditation for steel, aluminium or other industrial emissions does not, by itself, authorise a company to perform statutory electricity verification if LI is outside its approved scope.
Similar distinctions apply across metal supply chains. Steel and aluminium production can involve multiple manufacturing stages, precursor materials and finished goods. A verifier authorised for one activity may not be accredited for another, making it necessary to match the certificate and its annexes to the specific installation, production activity and goods concerned.
Procurement checks for Southeast European exporters
For exporters in Serbia, Montenegro and other Southeast European markets, the discrepancies underline the need to treat verifier selection as a formal compliance control rather than a routine purchasing decision.
Before signing an engagement, companies preparing for CBAM verification should obtain and review the current accreditation certificate, its detailed activity-group annex, confirmation from the relevant accreditation body and the organisation’s status in the CBAM Registry. These checks should be completed before site visits or substantive verification work begins.
Without that review, an exporter could incur preparation costs and devote resources to an assignment before discovering that the selected verifier lacks the necessary authorisation.
EU authorised CBAM declarants have a corresponding commercial interest in confirming accreditation. They rely on verified emissions information to meet their obligations, making the scope of the verification provider an important part of their assessment of the documentation supporting imported goods.
A more complex verifier market
The risk may become more prominent as the CBAM verification market grows. Additional accreditation bodies are opening applications and more verification companies are entering the sector. Although this expansion increases the number of potential providers, it also makes comparisons between accreditation scopes more complicated.
The presence of a large international verification brand does not eliminate the need for checks. Such organisations may operate through several national legal entities, and those entities may hold different accreditation scopes.
For importers, exporters and advisers, selecting a verifier is therefore increasingly a matter of technical due diligence. At a minimum, the review should establish the provider’s exact legal entity, national accreditation body, accreditation number, validity dates, authorised activity groups, CBAM Registry status and any restrictions attached to its accreditation.
Potential implications for export financing
Banks financing companies with substantial EU sales may also need to account for verification risks when assessing borrowers. If an exporter cannot obtain valid verification, customer acceptance of its emissions data could be delayed. The company may also face greater reliance on default values, potentially increasing CBAM costs and putting pressure on profit margins.
The revised Italian accreditation records do not change the underlying EU rules governing embedded-emissions calculations, claims based on actual electricity emissions, default values or hourly matching requirements.
They nevertheless highlight an operational vulnerability as CBAM compliance volumes increase: companies must establish not only whether their emissions information is reliable, but also whether the organisation verifying that information is accredited for the precise activity involved.
