A monitoring plan is the core document defining which emissions data your facility collects, using what method, how often, and how it's calculated. Both reporting and verification rest on this plan.

A well-prepared monitoring plan isn't just a compliance document — it's also a tool that helps you spot gaps and inconsistencies in your data collection early.

A typical CBAM monitoring plan covers your facility and production process description, product scope, data sources (measurement instruments, invoices, lab analyses), calculation methodology, and quality control procedures.

The plan is also expected to define the responsibilities of the people involved in data collection, and the fallback procedures to follow when data gaps occur.

For every emissions source, you need to clearly define what data is obtained, from which instrument or document, and how often. This clarity strengthens both your internal processes and the documentation you present to your verifier.

Leaving data collection responsibility with a single person is risky — naming a backup owner protects data continuity through staff changes.

The first step is mapping your product scope and the emissions sources tied to it. Next, match your existing data collection infrastructure (measurement instruments, ERP systems, manual records) against that scope and identify the gaps.

In the final step, you write up the methodology and procedures you've defined into an updatable document your verifier can also access.

You need to update your monitoring plan whenever there's a significant change in your production process, the fuel or energy source you use, or your data collection system. An outdated monitoring plan can be flagged as a non-conformity during verification.