02 · Control · Audit & Liability Defence
FilingDefence
Direct defence of submitted CBAM filings against verifier queries, Commission audit, and Article 20 penalty exposure — including reconstruction of evidence and structured response to challenge.
Registry lodgement support, audit defence, and post-submission response.
Direct defence of submitted CBAM filings against verifier queries, Commission audit, and Article 20 penalty exposure — including reconstruction of evidence and structured response to challenge.
In Scope
What we cover
- Registry lodgement review prior to submission — final defensibility check.
- Response drafting for verifier queries and Commission information requests.
- Article 20 penalty exposure assessment and mitigation strategy.
- Reconstruction of evidence chains where source documentation is incomplete or contested.
- Representation through to resolution — including correction filings where the position requires amendment.
Deliverables
What you receive
- A documented defence position for every contested figure in the filing.
- Reduced Article 20 penalty exposure through demonstrable good-faith methodology.
- A closed-loop record of every challenge raised and the response delivered.
100%
Of CBAM liability remains with the declarant under EU law. Filing Defence is the only mandate that operates with formal authority on the registry — and the only one that closes regulatory exposure on the lodged position.Regulation (EU) 2023/956 · Article 20
Best For
Operators facing an active verifier query, Commission audit, or who anticipate challenge on previously submitted filings — and who require a defence record assembled by counsel-grade documentation standards.
Exit Criteria
Engagement closes when the contested filing is accepted, amended, or otherwise resolved, with a complete defence file delivered to internal counsel.
Engagement
Take control of your CBAM exposure.
Run a controlled diagnostic. No commercial commitment until scope is confirmed in writing. Engagement closes on a written exposure report — regardless of whether you proceed to a mandate.