India Builds CBAM Verification Capacity: What It Means for Steel, Aluminium and Industrial Supply Chains

India is moving to expand its capacity to verify embedded emissions for EU CBAM, and that matters well beyond Indian exporters. The main constraints on verified CBAM data for Indian steel and aluminium in 2026 are likely to be the limited availability of recognised verifiers and the difficulty of getting reliable emissions data from upstream suppliers, rather than the calculation method itself. For EU importers and procurement teams, it means planning now for tight verification capacity, patchy precursor data and a real risk of falling back on marked-up default values for 2026 imports.

On 15 September 2026, India’s commerce ministry described the steps it is taking through its Committee on Export Preparedness for EU CBAM. Additional Secretary Darpan Jain said verification through verifiers had started in September, while exporters’ returns are due by September 2027 1. Later reporting said the government is working to have local bodies approved to carry out verification, rather than relying on foreign teams, and has sought EU recognition for India’s National Accreditation Board for Certification Bodies (NABCB) 2.

Why verification capacity is the bottleneck

Under the definitive CBAM regime, actual emissions only count if an accredited verifier has verified them. The Commission published guidance for CBAM verifiers and national accreditation bodies on 24 August 2026 and opened the procedure for verifier access to the CBAM Registry on 1 September 2026. Accreditation comes first, followed by a registry access application 3. Verification reports can be issued from January 2027 4.

Site visits make the constraint concrete. Implementing Regulation (EU) 2025/2546 requires a physical site visit in the first year an installation is verified. Virtual visits or waivers are possible only in later years, under specific conditions, and physical visits must take place at least every two years. Materiality is set at 5% of total specific embedded emissions per tonne of good 5.

For India, that means every steel, aluminium or fertiliser installation whose EU customers want actual values for 2026 needs an in-person visit from an accredited verifier within roughly the same window. With limited accredited capacity, and verifiers only now getting registry access, the first cycle will be tight.

Why upstream data is the second bottleneck

India’s steel sector includes large integrated producers alongside many secondary producers using induction furnaces, rolling mills and sponge-iron units. Aluminium supply chains mix primary smelters with downstream extruders and fabricators. For a large share of CBAM goods, the exporter’s embedded emissions depend on precursors, such as pig iron, sponge iron, semi-finished steel or unwrought aluminium, bought from other companies.

CBAM requires precursor emissions to be included in the embedded emissions of the final good. If the precursor supplier has no verified data, the exporter must use default values for that input, which weakens the case for the whole product. This is a structural problem for fragmented supply chains, and verification capacity alone cannot solve it.

India’s domestic carbon market is part of the answer

India’s Carbon Credit Trading Scheme (CCTS) is building domestic monitoring, reporting and verification infrastructure. Compliance obligations for the first sectors, including aluminium, apply from fiscal year 2025–26, and India launched an Indian Carbon Market Portal in March 2026 covering the accreditation of third-party verification bodies 6. For iron and steel, a revised draft notification in June 2026 set out emission-intensity targets for 255 units, subject to consultation 7.

Over time, this should mean more Indian producers hold regularly monitored emissions data. But CCTS targets are intensity-based and use their own methodology, so CCTS data will need to be reconciled with CBAM boundaries and precursor rules rather than transferred directly.

The India–EU free trade agreement text also includes a CBAM annexure. According to the commerce ministry, it covers SME concerns about verification and verifier recognition, and provides that India will benefit from any future CBAM flexibilities granted to other partners 8. How far this changes verification in practice will depend on implementation.

What this means for EU importers

If you import Indian steel, aluminium or fertilisers above the 50-tonne threshold, the cost of missing verified data is clear: default values carry a mark-up of 10% in 2026, rising to 20% in 2027 and 30% from 2028 for most goods 9. Practical steps:

• Segment Indian suppliers now. Separate those likely to deliver verified actual data for 2026 from those that will rely on defaults, and cost both scenarios.
• Ask about verifier bookings, not just data. A supplier with a monitoring plan but no verifier booked is unlikely to deliver a verification report in time for the September 2027 declaration.
• Check precursor coverage. Ask which inputs are bought in and whether those suppliers can provide data.
• Use the O3CI portal. Encourage suppliers to register installations and share data through the CBAM Registry, rather than sending spreadsheets to each customer 10.
• Reflect CBAM in sourcing. Where volumes allow, favour producers that can document lower-emission routes and verified data.

What this means for Indian exporters and suppliers

• Book verification early. First-year physical site visits are mandatory, and demand will cluster ahead of the 2027 deadline.
• Prepare before the verifier arrives. A documented monitoring plan, fuel and material records, production data and precursor information shorten the visit and reduce findings.
• Work upstream. Agree data-sharing with suppliers of sponge iron, pig iron, billets, slabs or ingots, and help smaller suppliers with simple templates.
• Align CCTS and CBAM work. Use the same underlying records for both, but keep the two calculations separate.

Industrial supply chains beyond steel and aluminium

Companies buying fasteners, castings, forgings, machinery parts and other metal-intensive components from India should watch the proposed extension of CBAM to downstream goods, currently under negotiation in the EU. The verification and data gaps now visible for primary steel and aluminium will be harder to solve further down the chain, where suppliers are smaller and precursor data even scarcer.

For a fuller explanation of what suppliers need to provide, see our guide to CBAM data from Asian suppliers and our factory-level supplier carbon assessment checklist. If you are reviewing CBAM exposure in Indian or wider Asian supply chains, talk to our team.

Sources

1. Economic Times, “India ramps up preparedness for European Union’s carbon tax; verifiers begin EU registry access”, 15 September 2026 (as republished). https://fvbb.com/ns/india-ramps-up-preparedness-for-european/319470
2. EIJ News, “EU CBAM Compliance: India Enables Local Verification to Prepare Exporters for Carbon Tax”, 17 September 2026. https://www.eij.news/post/eu-cbam-compliance-india-verifiers-registry-access
3. European Commission, Taxation and Customs Union, “The European Commission publishes guidance for CBAM verifiers and accreditation bodies”, 24 August 2026. https://taxation-customs.ec.europa.eu/news/european-commission-publishes-guidance-cbam-verifiers-and-accreditation-bodies-2026-08-24_en
4. European Commission, Taxation and Customs Union, “Verification of CBAM emissions”. https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en
5. Official Journal of the European Union, “Commission Implementing Regulation (EU) 2025/2546 of 10 December 2025”. https://eur-lex.europa.eu/eli/reg_impl/2025/2546/oj/eng
6. International Carbon Action Partnership (ICAP), “Compliance obligations under India’s Carbon Credit Trading Scheme enter into force for seven sectors”, 30 March 2026. https://icapcarbonaction.com/en/news/compliance-obligations-under-indias-carbon-credit-trading-scheme-enter-force-seven-sectors
7. LKS, “Emission targets notified for Iron & Steel units under CCTS”, July 2026. https://sustainability.lkslaw.com/insights/gei-targets-iron-steel
8. The Tribune, “India-EU FTA includes dedicated CBAM annexure to address exporters’ concerns, support SMEs”, 30 July 2026. https://www.tribuneindia.com/news/business/india-eu-fta-includes-dedicated-cbam-annexure-to-address-exporters-concerns-support-smes/
9. International Carbon Action Partnership (ICAP), “EU CBAM enters compliance phase and outlines path ahead”. https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead
10. European Commission, Taxation and Customs Union, “CBAM Definitive Registry (from 2026 onwards)”. https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-registry-and-reporting_en