The European Commission clarified how accredited verifiers may use technical specialists based in non-EU countries to support verification under the Carbon Border Adjustment Mechanism (CBAM). The guidance 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 clarification addresses whether an accredited verifier may outsource certain activities to a local branch or subsidiary operating in a third country. It states that specific verification activities may be outsourced if the arrangements comply with CBAM accreditation and verification requirements and EN ISO 14065. The accredited verifier remains fully responsible for the verification process and the resulting report.
Accredited verifier responsibilities cannot be delegated
The Commission distinguishes between technical activities that may be delegated and functions that must remain with the accredited verifier. 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 when overseeing the accredited verifier.
These conditions are intended to create a controlled framework for using third-country technical expertise without transferring the statutory verification function to an unaccredited service provider. The Commission’s approach maintains that only accredited providers can issue verification outcomes under CBAM rules.
Third-country engineering support in Serbia, Montenegro and other markets
The clarification creates a defined role for engineering and technical-assurance companies in Serbia, Montenegro and other non-EU manufacturing markets. Local specialists could undertake assigned technical tasks for accredited EU verifiers without becoming the legally responsible CBAM verifier.
Potential assignments include industrial-process assessments, metering checks, site inspections, data-system examinations, mass-balance assessments and reviews of other engineering evidence. Technical partners could 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 support for EU-accredited verification providers working with Serbian steel mills, aluminium plants, fertiliser producers and power installations. It also cites practical factors such as access to industrial sites, language capabilities and familiarity with national metering, dispatch and industrial-record systems that could support evidence collection and reduce travel requirements.
Separating CBAM preparation from verification work
The clarification also affects companies providing CBAM preparation and emissions-accounting services to industrial operators. It notes that an engineering consultancy that designed an installation’s monitoring system, prepared its emissions calculations or assembled evidence later subject to verification could face self-review or impartiality conflicts if it then participates in verifying that same work.
Companies operating on both sides of the CBAM market therefore need 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: operator-side monitoring, reporting and verification (MRV) plus pre-verification practice, alongside verifier-side technical support limited to assignments passing conflict-of-interest screening.
Accreditation bodies can scrutinise outsourced subcontractors
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.
Contracts for delegated activities are expected to specify delegated tasks, responsible personnel, evidence requirements, confidentiality arrangements, operator consent, access rights and responsibilities retained by the accredited verifier. The Commission also highlights that remuneration linked to a particular outcome or agreements rewarding a favourable verification conclusion could raise additional impartiality concerns.
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. Third-country specialists may perform defined verification activities under applicable conditions while accreditation, technical review, report issuance and final assurance responsibility remain with the accredited verifier.
The Commission’s clarification was published as the first full CBAM verification cycle approaches. It sets out conditions under which EU verification providers can draw on engineering expertise in countries producing CBAM-covered goods.