The European Commission clarified how accredited CBAM verifiers may draw on technical specialists located in non-EU countries. The guidance is set out in the Commission’s CBAM Questions and Answers, updated on 15 October 2026. It focuses on how to separate delegated technical work from responsibilities reserved for accredited verification providers.
The clarification addresses whether an accredited verifier can outsource certain activities to a local branch or subsidiary operating in a third country. It states that outsourcing is possible for specific verification activities when arrangements meet CBAM accreditation and verification requirements and EN ISO 14065. The accredited verifier remains responsible for the verification process and the resulting report.
Outsourced tasks allowed, final assurance stays with the verifier
The Commission distinguishes between technical activities that may be delegated and functions that must remain with the accredited verifier. According to the explanation, 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. The relevant national accreditation body may assess the outsourced organisation while overseeing the accredited verifier.
The Commission frames these conditions as a controlled framework for using third-country technical expertise without transferring the statutory verification function to an unaccredited provider. This approach is intended to keep accreditation-linked responsibilities with the accredited entity issuing assurance.
Technical support role for Serbia, Montenegro 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 can undertake assigned technical tasks for accredited EU verifiers without becoming the legally responsible CBAM verifier. The accredited verifier continues to apply independent judgement for the final verification conclusion.
Potential delegated assignments listed in the guidance include industrial-process assessments, metering checks, site inspections, data-system examinations and mass-balance assessments. It also includes reviews of other engineering evidence. Technical partners may inspect plant equipment, reconcile meter readings with production records, and test SCADA or ERP data.
Other examples include examining material flows and assessing 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 expertise, site access, language capabilities and familiarity with national metering, dispatch and industrial-record systems can support evidence collection and reduce travel requirements.
Separation needed between CBAM preparation work and verification support
The clarification also affects companies providing CBAM preparation and emissions-accounting services to industrial operators. It highlights that an engineering consultancy involved in designing an installation’s monitoring system or preparing emissions calculations could face an impartiality conflict if it later participates in verifying that same work. The issue is described as a self-review or impartiality concern.
Companies operating across both sides of the CBAM market are therefore expected to maintain separation between client-facing preparation services and assignments performed on behalf of accredited verifiers. For Clarion.Engineer and comparable regional providers, this could involve maintaining two distinct service streams. One stream covers 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 guidance ties this separation requirement directly to impartiality safeguards relevant to CBAM verification arrangements.
Accreditation bodies may inspect 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 is described as bringing outsourced CBAM technical support closer to formal assurance requirements.
Contracts covering delegated activities are expected to specify responsibilities retained by the accredited verifier alongside details such as responsible personnel, evidence requirements and confidentiality arrangements. The guidance also points to operator consent requirements and access rights for relevant parties involved in oversight or assessment.
It also notes that remuneration arrangements require attention. Payments linked to a particular outcome or agreements rewarding a favourable verification conclusion could raise additional impartiality concerns under these safeguards.
Technical subcontracting does not replace CBAM accreditation
For exporters, the clarification does not remove the 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.
The Commission states that third-country specialists may perform defined verification activities under applicable conditions. However, accreditation-related responsibilities—including technical review, report issuance and final assurance responsibility—remain with the accredited verifier. The clarification is published as the first full CBAM verification cycle approaches.