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 clarification states that the accredited verifier must remain fully responsible for the verification process. It also specifies that the accredited verifier cannot delegate the technical review or the issuance of the final verification report.
The guidance sets out a route for local technical expertise to support EU-accredited verification without shifting responsibility for the final assurance conclusion. It requires sufficient guarantees of impartiality and independence from the outsourced body. The installation operator must consent to the arrangement, and the relevant national accreditation body may assess the outsourced body during accreditation or surveillance.
Third-country specialists supporting EU-accredited verification
The clarification is described as relevant to Serbia, Montenegro and other non-EU industrial markets. In these contexts, EU-accredited verifiers may need local engineering expertise, language capabilities and access to installation records. The outsourced specialists can carry out specifically defined activities under the arrangement.
The guidance also notes that regional specialists do not become the statutory verifier solely by performing work at an installation. The accredited body is stated to remain responsible for overall verification and its final conclusions. For verification firms, outsourcing can reduce travel requirements and increase access to specialised technical knowledge.
For installation operators, outsourcing may make verification scheduling and coordination easier. The Commission’s clarification links this support role to defined delegated activities rather than a transfer of verification authority. The operator-side consent requirement is presented as part of the conditions for using outsourced support.
Separation of MRV advisory work and verifier technical assistance
The arrangement can create challenges when local engineering consultancies have previously designed an installation’s monitoring system or prepared emissions calculations later subject to verification. The guidance indicates that separation between operator-side pre-verification and monitoring, reporting and verification (MRV) advisory services and verifier-side technical assistance is important. It frames this separation as a way to manage potential overlaps in roles.
Safeguards referenced in the clarification 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 presented as part of ensuring impartiality and independence in outsourced support arrangements.
Contract terms preserving accredited verifier responsibility
The Commission’s guidance says contracts for outsourced activities should define delegated tasks and set personnel competence requirements. It also lists operator consent, confidentiality obligations, access to evidence, and ownership of working papers as elements to be specified. These contract provisions are intended to structure how outsourced work supports the accredited process.
The guidance further requires contracts to explicitly establish that the accredited verifier retains the final assurance decision. It states that technical review and issuance of the verification report remain responsibilities of the accredited body. This requirement applies even when outsourced activities are performed by another verifier or in a third country.
Potential demand for cross-border CBAM verification services
The clarification indicates it could support development of a specialised services market around CBAM verification. It notes that EU assurance firms need expertise across sectors including steel, aluminium, cement, fertilisers, hydrogen and electricity. It also points to engineering firms in third countries having direct knowledge of installations producing goods covered by these sectors.
The framework is described as creating opportunities for cross-border technical cooperation while preserving the regulatory boundary between outsourced support and statutory verification responsibility. The conditions on impartiality, independence, operator consent and accredited-verifier responsibility are presented as central elements of that boundary.