The European Commission has clarified how accredited verifiers may use technical specialists based in non-EU countries to support verification under the Carbon Border Adjustment Mechanism (CBAM). The clarification is set out in the Commission’s CBAM Questions and Answers, updated on 15 October 2026. It focuses on boundaries between outsourced technical work and responsibilities reserved for accredited verification providers.
The Commission addresses whether an accredited verifier can outsource certain activities to a local branch or subsidiary operating in a third country. It states that specific verification activities may be delegated if the arrangements meet CBAM accreditation and verification requirements and EN ISO 14065. The accredited verifier must remain responsible for the verification process and the resulting report.
Delegation rules for outsourced verification activities
The Commission distinguishes between technical tasks that may be delegated and functions that must stay with the accredited verifier. It specifies that issuing the verification report and conducting its technical review cannot be outsourced. The verifier retains responsibility for the final assurance outcome.
The organisation receiving outsourced work must provide sufficient guarantees of impartiality and independence. The installation operator whose emissions are being verified must also consent to the arrangement. In addition, the relevant national accreditation body may assess the outsourced organisation when overseeing the accredited verifier.
These conditions are intended to maintain a controlled framework for using third-country technical expertise without transferring the statutory verification function to an unaccredited service provider. The Commission’s approach is linked to how accreditation and surveillance processes can include checks on delegated parties. This structure keeps decision-making authority with the accredited provider.
Technical-assurance support in Serbia and other non-EU markets
The clarification creates a defined role for engineering and technical-assurance companies in Serbia, Montenegro and other non-EU manufacturing markets. Local specialists may undertake assigned technical tasks for accredited EU verifiers without becoming the legally responsible CBAM verifier. The accredited verifier retains independent judgement and responsibility for the final verification conclusion.
Potential delegated assignments include industrial-process assessments, metering checks, site inspections, data-system examinations, mass-balance assessments, and reviews of other engineering evidence. Technical partners may also inspect plant equipment, reconcile meter readings with production records, test SCADA or ERP data, examine material flows, and assess specific technical calculations requested by the verifier.
The Commission links these arrangements to EU-accredited verification providers working with Serbian steel mills, aluminium plants, fertiliser producers, and power installations. It notes that local engineering expertise, access to industrial sites, language capabilities, and familiarity with national metering, dispatch, and industrial-record systems can support evidence collection while reducing travel requirements. Delegated work remains bounded by the responsibilities retained by the accredited verifier.
Separating preparation services from verification work
The clarification also affects companies providing CBAM preparation and emissions-accounting services to industrial operators. It highlights that an engineering consultancy involved in designing a monitoring system or preparing emissions calculations could face a self-review or impartiality conflict if it later participates in verifying that same work. This applies where preparation activities are connected to evidence later subject to verification.
Companies operating across both sides of the CBAM market are expected to maintain effective separation between client-facing preparation services and assignments performed on behalf of accredited verifiers. For regional providers such as Clarion.Engineer, this could involve maintaining two distinct service streams. One stream would cover operator-side monitoring, reporting and verification (MRV) and pre-verification practice.
A second stream would cover verifier-side technical support limited to assignments that pass conflict-of-interest screening. The Commission’s clarification ties this separation requirement to impartiality safeguards within CBAM verification arrangements. It frames conflict management as part of how outsourced technical tasks can be used without undermining assurance independence.
Accreditation oversight for outsourced organisations
The Commission states that national accreditation bodies may inspect outsourced organisations during verifier accreditation or surveillance. Technical subcontractors should therefore expect scrutiny of personnel competence, working papers, methodologies, independence safeguards, and evidence trails. This oversight extends delegated technical support closer to requirements applied in formal assurance activities.
Contracts covering delegated work need to specify delegated activities, responsible personnel, evidence requirements, confidentiality arrangements, operator consent, access rights, and responsibilities retained by the accredited verifier. The Commission also flags remuneration considerations linked to impartiality risks. Payments tied to a particular outcome or agreements rewarding a favourable verification conclusion could raise additional concerns.
CBAM accreditation remains required for exporters
The clarification does not remove exporters’ requirement to obtain verification from an appropriately accredited CBAM verifier. It also does not grant regional engineering companies the status of accredited verifiers. Instead, it establishes a controlled technical-support role between industrial installations and EU assurance providers.
Third-country specialists may perform defined verification activities under applicable conditions described by the Commission. However, accreditation requirements continue to govern who can issue assurance outputs. The accreditation framework covers technical review processes, report issuance responsibilities, and final assurance responsibility remaining with the accredited verifier.
The Commission’s clarification is published as the first full CBAM verification cycle approaches. It defines conditions for how EU verification providers can draw on engineering expertise in countries producing CBAM-covered goods while keeping statutory assurance functions within accredited structures.