EU-accredited CBAM verifiers can outsource defined verification activities to third-country specialists, but must retain responsibility for technical review and the final verification report.
Outsourcing Permitted Under Strict Conditions
The European Commission has clarified that accredited verifiers under the Carbon Border Adjustment Mechanism (CBAM) may outsource certain verification activities to another verifier, including activities performed in a third country. However, the accredited verifier must retain full responsibility for the verification and cannot delegate the technical review or issuance of the final verification report.
The guidance establishes a formal route for local technical expertise to support EU-accredited verification without transferring responsibility for the final assurance conclusion. 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.
Opportunities for Regional Engineering Specialists
The clarification is relevant to Serbia, Montenegro and other non-EU industrial markets where EU-accredited verifiers may require local engineering expertise, language capabilities and access to installation records.
Regional specialists can perform specifically defined activities, but they do not become the statutory verifier merely by carrying out work at an installation. The accredited body remains responsible for the overall verification and its final conclusions.
For verification firms, outsourcing can reduce travel requirements and provide greater access to specialised technical knowledge. For installation operators, it may make verification easier to schedule and coordinate.
Independence and Conflict-of-Interest Controls
The arrangement also creates challenges where local engineering consultancies have previously designed an installation’s monitoring system or prepared the emissions calculations that are subsequently subject to verification.
A clear separation between operator-side pre-verification and monitoring, reporting and verification (MRV) advisory services and verifier-side technical assistance is therefore important. Appropriate safeguards include client screening, personnel segregation and documented independence assessments. Fees should not depend on whether the verification outcome is favourable.
Contracts Must Preserve Accredited Verifier Responsibility
Contracts governing outsourced activities should specify the delegated tasks, personnel competence requirements, operator consent, confidentiality obligations, access to evidence and ownership of working papers.
They should also explicitly establish that the accredited verifier retains the final assurance decision. Technical review and issuance of the verification report remain the responsibility of the accredited body.
A Specialised CBAM Services Market Could Emerge
The clarification could support the development of a specialised services market around CBAM verification. EU assurance firms need expertise across sectors including steel, aluminium, cement, fertilisers, hydrogen and electricity, while engineering firms in third countries have direct knowledge of the installations producing those goods.
The framework creates opportunities for cross-border technical cooperation while preserving the regulatory boundary between outsourced support and statutory verification responsibility.
