The European Commission has clarified how accredited verifiers can use technical specialists based in non-EU countries to support verification under the Carbon Border Adjustment Mechanism (CBAM), setting boundaries between outsourced technical work and the responsibilities reserved for accredited verification providers.
The clarification appears in the Commission’s CBAM Questions and Answers, updated on 15 October 2026. It addresses whether an accredited verifier may outsource certain activities to a local branch or subsidiary operating in a third country.
Under the Commission’s explanation, specific verification activities may be outsourced, provided 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.
Final verification decisions remain with accredited providers
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. In addition, the installation operator whose emissions are being verified must consent to the arrangement. The relevant national accreditation body may also assess the outsourced organisation when overseeing the accredited verifier.
These conditions establish a controlled framework for using third-country technical expertise without transferring the statutory verification function to an unaccredited service provider.
Engineering specialists could support verification across Southeast Europe
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 themselves 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.
Such arrangements could help EU-accredited verification providers working with Serbian steel mills, aluminium plants, fertiliser producers and power installations. Local engineering expertise, access to industrial sites, language capabilities and familiarity with national metering, dispatch and industrial-record systems could support evidence collection and reduce travel requirements.
The accredited verifier would nevertheless retain independent judgement and responsibility for the final verification conclusion.
Conflicts of interest separate preparation from verification
The clarification also has implications for companies providing CBAM preparation and emissions-accounting services to industrial operators. An engineering consultancy that designed an installation’s monitoring system, prepared its emissions calculations or assembled the evidence later subject to verification could face a self-review or impartiality conflict if it subsequently participated in verifying that same work.
Companies operating on both sides of the CBAM market will therefore need effective separation between client-facing preparation services and assignments performed on behalf of accredited verifiers.
For Clarion.Engineer and comparable regional providers, this could mean maintaining two distinct service streams: an operator-side monitoring, reporting and verification (MRV) and pre-verification practice, and a verifier-side technical-support practice limited to assignments that pass conflict-of-interest screening.
Accreditation oversight extends to outsourced organisations
The Commission’s clarification makes clear that national accreditation bodies may inspect outsourced organisations during verifier accreditation or surveillance. Technical subcontractors should consequently expect scrutiny of personnel competence, working papers, methodologies, independence safeguards and evidence trails.
This oversight brings outsourced CBAM technical support closer to the requirements of formal assurance work. Contracts will need to specify delegated activities, responsible personnel, evidence requirements, confidentiality arrangements, operator consent, access rights and the responsibilities retained by the accredited verifier.
Remuneration arrangements also require attention. Payments 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. Nor does it 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 the applicable conditions, while accreditation, technical review, report issuance and the final assurance responsibility remain with the accredited verifier.
The Commission’s clarification, published as the first full CBAM verification cycle approaches, defines the conditions under which EU verification providers can draw on engineering expertise in the countries producing CBAM-covered goods.
