Can a UK CBAM verifier use local auditors in India?
Yes, with conditions. HMRC's guidance lets a UK CBAM verifier outsource auditors or technical experts if your plant consents, legal agreements are in place and it keeps evidence of their competence and independence. The verifier keeps full responsibility. The independent review, drafting and issue of the verification report can never be outsourced.
What the verifier must have in place
- Your consent, as operator, to the outsourced auditors or experts.
- Documented legal agreements with the outsourced body.
- Evidence that the outsourced people meet the competence rules and the independence and impartiality rules.
- Its own procedures for managing outsourced work, which are checked in its annual surveillance.
- Full responsibility for the verification and for completing the report.
What stays with the accredited verifier
- The independent review.
- Drafting the verification report.
- Issuing the verification report.
What this means for your contract
If a verifier proposes a local partner for the site work, ask who the outsourced firm is, ask to see that it meets the independence rules, and give your consent in writing. The report your UK buyer receives must still come from the accredited verifier itself.
What Senseible does here
Senseible is not a verifier and cannot act as one. It builds the figure from your fuel and input invoices for the verifier to check. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.
Sources: HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026)
Last reviewed 2026-11-03.