Commission clarification on outsourcing verification tasks
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, however, must keep full responsibility for the verification process. The verifier 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 without transferring responsibility for the final assurance conclusion. It requires the outsourced body to 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.
Regional relevance for Serbia and Montenegro
The clarification is relevant to Serbia, Montenegro and other non-EU industrial markets where EU-accredited verifiers may need local engineering expertise. Such needs can include language capabilities and access to installation records. Under the framework, regional specialists can carry out specifically defined activities.
Even when specialists perform work at an installation, they do not become the statutory verifier by virtue of that activity. The accredited body remains responsible for the overall verification and for its final conclusions. The guidance also notes that outsourcing can reduce travel requirements for verification firms and help installation operators schedule and coordinate verification activities.
Independence safeguards amid MRV-related prior involvement
The arrangement can raise challenges when local engineering consultancies previously designed an installation’s monitoring system or prepared emissions calculations later subject to verification. Because of this, the Commission guidance highlights the need for separation between operator-side pre-verification and monitoring, reporting and verification (MRV) advisory services and verifier-side technical assistance.
Safeguards referenced in the guidance include client screening, personnel segregation, and documented independence assessments. It also states that fees should not depend on whether the verification outcome is favourable. These controls are intended to address potential conflicts arising from earlier roles connected to MRV work.
Contract terms preserving accredited verifier responsibility
Contracts covering outsourced activities should define the delegated tasks and set requirements for personnel competence. They should also cover operator consent, confidentiality obligations, access to evidence, and rules on ownership of working papers. The contractual framework is expected to make clear what is delegated and what remains under verifier control.
The guidance further specifies that 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. This requirement applies even where outsourced support includes third-country activities.
Potential expansion of cross-border CBAM services
The Commission clarification could support a specialised services market around CBAM verification activities. EU assurance firms may require sectoral expertise across steel, aluminium, cement, fertilisers, hydrogen and electricity. Engineering firms in third countries may have direct knowledge of installations producing goods covered by CBAM.
The framework creates opportunities for cross-border technical cooperation while preserving the regulatory boundary between outsourced support and statutory verification responsibility. Outsourcing is therefore positioned as defined technical assistance rather than a transfer of statutory verification authority.