Your filing needs a signature you are not allowed to give yourself.

There is no compliant route that ends with you certifying yourself.

Three clauses close it off between them. Verification has to be donethrough an accredited carbon verification agency. Appointing that agency is your obligation, not the Bureau's. And the performance assessment document in Form A is only accepted when it arrives together with that agency's certificate of verification in Form B.

So the agency is not a supplier you engage if you want extra assurance. It is a participant in your filing, and the quality of what you hand it decides how long the process takes and what it finds.

The procedure assigns acts, not roles.

This is the part worth reading closely before choosing software. A tool that lets your own staff record the site visit, close out the findings and issue the opinion is not being helpful — it is producing a document the Bureau can set aside, with the consequences falling on you and on the agency that signed it.

What your verifier will actually ask for.

The procedure prescribes fourteen lines of enquiry. Six of them are what a plant will feel, and none of them is satisfied by a total — they are all about how you got to it.

• Where your numbers come from

  Your data and information systems, the IT that holds them, the flow from meter or invoice to reported figure, and the controls over that flow. Not the total — the path to it.

• Whether you have counted everything

  Emission sources and source streams, checked for coverage. A source you forgot is a finding, not an omission nobody notices.

• Your figures against their origin

  Data verified against primary and secondary sources, with sampling, and further checks where a source looks unreliable.

• The methodology, factor by factor

  Net calorific value, emission factor, oxidation factor, energy consumption — the calculation for each emission source, not the arithmetic at the end.

• The plant, and the people in it

  A site visit, interviews with the staff responsible, and cross-checks of what they say against what was filed — to establish nothing was omitted, over- or under-valued.

• The reduction measures you claimed

  The GHG measures you say you implemented, verified as implemented — which is why photographs and investment figures belong in the record and not in a slide.

Every one of those is a question about traceability. If your answer is a spreadsheet that someone rebuilt from memory after the year closed, the verification is where that becomes expensive.

The disagreement is part of the filing.

When the agency finds a discrepancy, a data gap or a figure it cannot trace, it has to document it and obtain your explanation with supporting evidence. The verification report then has to record that exchange — and any change the agency made to its assessment because of what you supplied. It is not a private conversation that resolves before the paperwork starts.

• The thread is structured, not an inbox

  Each finding carries its category, your explanation, the evidence you attached, and whether it changed the agency's assessment — which is exactly what the report has to state, rather than something reconstructed from email at the end.

• An opinion cannot be issued out of order

  The conditions the procedure sets — team communicated, site visit recorded, report attached, every finding answered and accepted — are checked before an opinion can be recorded, and all of the missing ones are reported at once rather than one round-trip at a time.

• The agency you appoint gets its own access

  Scoped to the facility and cycle it was appointed for, and no further. Your own staff cannot perform the acts the procedure assigns to it — which protects the filing rather than restricting you.

• Form B is rendered from what happened

  The certificate is assembled from the recorded verification, with Annexure VII's attestations reproduced as the annexure words them. Anything still outstanding is named, because a certificate with a silent gap fails the filing it was meant to complete.

Questions we actually get asked.

Can we appoint anyone as our verifier?

It has to be an accredited carbon verification agency. Accreditation is time-bounded, so an agency accredited today may not have been accredited for the cycle you are filing on — a certificate signed by an agency that was not accredited for that period looks valid and is worthless.

Can our own internal audit team do it?

No. The procedure assigns the verification acts to the accredited agency, and Form A is not accepted without that agency's certificate. An internal review is useful preparation for verification; it is not a substitute for it.

What happens if the agency disagrees with our numbers?

It documents the discrepancy and asks you to explain it with supporting evidence. Your explanation and any resulting change to the agency's assessment both go into the verification report — so the disagreement becomes part of the filing rather than something settled off the record.

Is it over once Form B is signed?

Not entirely. The Bureau can open an independent review up to six months after the compliance report or three months after certificates are issued, whichever falls later, and the agency that signed has ten working days to respond point by point. Any such review goes to a different agency — one that has not verified you before.

EU CBAM also requires accredited verification once you report actual rather than default values, but it is a separate regime with its own accreditation — see theCBAM page.