The European Commission clarified that CBAM accredited verifiers may outsource certain verification activities to another verifier, including work carried out in a third country. The accredited verifier must still retain full responsibility for the verification. It cannot delegate the technical review or the issuance of the final verification report.
The guidance sets out a route to use local technical expertise in support of EU-accredited verification while keeping responsibility for the final assurance conclusion with the accredited verifier. The outsourced body must provide sufficient guarantees of impartiality and independence. The installation operator must consent to the arrangement, and the relevant national accreditation body may assess the outsourced body during accreditation or surveillance.
Use of third-country specialists in non-EU industrial markets
The clarification is relevant for Serbia, Montenegro and other non-EU industrial markets where EU-accredited verifiers may need local engineering expertise. It also covers situations where language capabilities and access to installation records are required for defined verification activities.
Regional specialists may carry out specifically defined tasks, but they do not become the statutory verifier by performing work at an installation. The accredited body remains responsible for overall verification and its final conclusions.
For verification firms, outsourcing can reduce travel requirements and provide access to specialised technical knowledge. For installation operators, it may help make verification scheduling and coordination easier.
Independence requirements and MRV separation
The arrangement can create challenges when local engineering consultancies previously designed an installation’s monitoring system or prepared emissions calculations that are later subject to verification. In such cases, separation between operator-side work and verifier-side technical assistance becomes important.
A clear distinction is needed between operator-side pre-verification and monitoring, reporting and verification (MRV) advisory services, and verifier-side technical assistance. Safeguards cited include client screening, personnel segregation, and documented independence assessments.
The guidance also states that fees should not depend on whether the verification outcome is favourable. This is presented as part of controls intended to address potential conflicts of interest.
Contract terms preserving accredited verifier responsibility
Contracts governing outsourced activities should define delegated tasks and personnel competence requirements. They should also cover operator consent, confidentiality obligations, access to evidence, and ownership of working papers.
The contracts must explicitly establish that the accredited verifier retains the final assurance decision. Technical review and issuance of the verification report remain responsibilities of the accredited body.
Potential growth in CBAM verification services across borders
The Commission’s clarification could support development of a specialised services market around CBAM verification. EU assurance firms need expertise across sectors including steel, aluminium, cement, fertilisers, hydrogen and electricity.
Engineering firms in third countries can have direct knowledge of installations producing goods covered by CBAM. The framework enables cross-border technical cooperation while preserving the regulatory boundary between outsourced support and statutory verification responsibility.