The specialist commissioning manager for a complex system must be a specialist contractor and not a general sub-contractor. They must be on hand to independently verify the work carried out by whoever installs the system.
In principle, it is possible for the specialist commissioning manager to be from the same organisation as the main contractor provided any conflicts of interest have been declared and records show how they have been managed to provide confidence that commissioning will be carried out appropriately.
The separate roles of the main contractor and specialist commissioning manager are so that the installation and commissioning are carried out independently by different parties.