A development finance loan and a border carbon regime have the same shape: a list of obligations written by someone else, a calendar that does not move, and a verifier who cannot help you prepare. For a typical 50 to 250 MW project financed by EBRD, IFC or ADB the list runs to 120 to 180 discrete obligations; for a steel or aluminium exporter under CBAM it is a monitoring plan, an installation boundary and a verification gate every cycle.
Our practice builds the requirements library once and operates it: every obligation with an owner, a deadline and the evidence the monitor will ask for; reporting produced from the library rather than assembled before each deadline; and the audit trail kept in the shape the second cycle will need. The CBAM programme is set out on its own page with the working instruments.