CORSIA / EU ETS / Swiss ETS / UK ETS Verification

Independent third-party verification is a legal environmental audit that all aircraft operators subject to CORSIA, EU ETS, Swiss ETS and UK ETS are required to perform. VERIFAVIA is the world's leading provider of emissions verification services for aviation.

Between 2010 and 2021, VERIFAVIA conducted emissions verification of 1000+ different aircraft operators - including 300+ commercial airlines - from 80+ countries.
 

VERIFAVIA (SINGAPORE) PTE LTD is accredited by the Singapore Accreditation Council (SAC) for CORSIA; VERIFAVIA SAS is accredited by COFRAC for CORSIA and EU ETS, and is about to be accredited by the United Kingdom Accreditation Service (UKAS) for UK ETS.
 

Mission statement

Verifavia provides flexible, efficient and competitive emissions verification services for airlines and other aircraft operators subject to CORSIA and / the EU ETS / the CH ETS / the UK ETS:
 

• Flexible: we offer a personal, customized and hassle-free service
• Efficient: we focus on the key areas to speed up the verification process
• Competitive: we have low overhead costs so we can offer competitive rates

We strive to work as efficiently as possible while maintaining the highest degree of data accuracy and the highest level of customer service.
 

What is verification?

The aim of verification is to reach an opinion with reasonable assurance that:
 

• The data submitted in the emissions report is fairly stated, i.e. free from material misstatements
• The existing procedures conform with the approved monitoring plans and the relevant CORSIA and/or EU ETS/UK ETS/CH ETS regulations.

Verification is an iterative process aiming at continuous improvement of the operator's emissions management and control systems. For efficiency and to allow time for corrective actions, the process follows a two-stage approach:

1. Stage 1: analysis of the design and implementation of the operator's emissions management system (organisation, procedures, IT) and control system, and assessment whether the procedures conform the monitoring plan and the CORSIA and/or EU ETS/UK ETS/CH ETS regulations.
2. Stage 2: detailed testing and analysis of data, independent technical review, materiality analysis and final verification opinion

The structure of the verification activities is consistent with the CORSIA and/or EU ETS/UK ETS/CH ETS regulations and is documented in the VERIFAVIA Assurance Management System Manual which is based on the approaches used for both financial and management systems auditing.
 

What are the steps of verification?

The verification process includes the ten following steps:
 

Step 1 - Pre-Contract Stage

The aim is to ensure that the scope and extent of verification activities and time quoted are sufficient to meet the requirements for 'Reasonable Assurance'. In this step, VERIFAVIA will:
 

• Analyse the information provided by the operator
• Evaluate the scope and complexity of the verification activities
• Select the verification team and allocate time to verification activities
• Prepare a draft contract, including quotation and contract conditions

Steps 2 & 3 – Strategic and Risk Analysis

The strategic analysis aims to understand the operator’s organisation and obtain an overview of the design and implementation of its CORSIA and/or EU ETS/UK ETS/CH ETS management and control systems so that an appropriate verification plan can be established.

The aim of the risk analysis is to identify where there are risks of system failure that might result in misstatements or non-conformities in the emissions report; it is on the higher risk areas that the verifier team will focus its efforts.

VERIFAVIA will consider the following inputs:
 

• The approved monitoring plan and any changes during the monitoring period
• Results of previous verification audits, if applicable
• The nature, scale and complexity of the operator's operations 
• The complexity of IT systems used to handle CORSIA and/or EU ETS/UK ETS/CH ETS data
• Whether all the required control elements have been accounted for
• The existence of an environmental or a quality management system
• The existence of quality control and assurance processes
• The organizational structure of CORSIA and/or EU ETS/UK ETS/CH ETS management 
• The availability of information and data in terms of access, completeness and accuracy

Step 4 – Verification Plan

Based on the strategic and risk analysis, VERIFAVIA will prepare a verification plan which will include:
 

• A program that includes the nature, scope and timeframe of the verification activities
• A data analysis plan setting out the data to be sampled and tested
• The details of any site visit, if required

Step 5 – Business Process Analysis

VERIFAVIA will implement the verification plan and assess whether the CORSIA and/or EU ETS/UK ETS/CH ETS management system conforms with the approved monitoring plans and the regulations of the schemes.

The process analysis is based on a site visit (if required), interviews, document review, observation of processes and corroboration of information. The process includes:
 

• Interview of CORSIA and/or EU ETS/UK ETS/CH ETS Manager, Flight Operations, Quality, IT and other departments, if required
• Observation of IT systems or spreadsheets used to process CORSIA and/or EU ETS/UK ETS/CH ETS data
• Review of documents including relevant manuals, documented quality procedures, flight documentation, fuel invoices, etc.

Step 6 – Data Analysis

VERIFAVIA will conduct a thorough analysis of data by uploading aircraft, flight and fuel data into our VERIFAVIA Data Analysis System (VEDAS) which automatically identifies data gaps, performs multiple plausibility checks, and generates the operator's emission report.

The data analysis will allow the identification of problems with the data so that the operator can undertake corrective actions if necessary.

During Step 6, VERIFAVIA will also:

1. Cross-check flight data with independent sources of data such as airlines' schedules and air traffic data (e.g. EUROCONTROL) 
2. Perform consistency checks between aggregated fuel consumption data and total fuel purchased
3. Conduct sampling of flight documentation on selected flights

Steps 7 - Reporting

Throughout all the steps identified above, the verification team maintains an Issues Log that lists issues arising. VERIFAVIA will share this Issues Log with the operator so there is a common list of issues to be closed out before completion of the audit.

The operator is required to undertake corrective actions and provide evidence to the verification team. Some issues that are not critical can be viewed as 'improvement opportunities' and carried forward for future implementation.

At the end of the verification, the verifier evaluates all its findings and conducts a materiality analysis on any errors and non-conformities remaining. The verifier then drafts the opinion and compiles its work papers and collected evidence into an internal verification report.
 

Step 8 - Independent Technical Review

Before a decision can be made to issue the final verification opinion, the internal verification report must be independently reviewed by a technical reviewer.

The objective of the independent review is to ensure that the verification process was conducted in accordance with VERIFAVIA's documented procedures, that due professional care and judgment have been used, and that any verification risks have been minimized.
 

Step 9 – Final Verification Report

VERIFAVIA will submit the verified annual emissions report to the operator through any system, document or procedure required by the Competent Authority and/or the Administering Authority of the operator.
 
For EU ETS, UK ETS, and CH ETS, it is the operator's responsibility to formally submit the verified report to the Competent Authority.
 
For CORSIA verification, VERIFAVIA will submit the operator’s emissions report as well as the verification report to the Administering Authority upon authorization by the aeroplane operator.
 

Step 10 – Approval of data in the EU ETS registry [only for EU ETS/UK ETS /CH ETS]

In Member States where this is required, VERIFAVIA will approve the relevant entries into the EU ETS/UK ETS/CH ETS registry of the client.
 

Step 11 – Cancellation report [only for CORSIA]

 
VERIFAVIA will verify the cancellation report provided by the client. This step is carried out in 2025 for the first time (offsetting of 2021-2023 cycle).

 

Regulations & Criteria

VERIFAVIA conducts verification according to the following criteria:
 

• ISO14065:2013 – Greenhouse gases – requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition
• IAF MD 6:2014 – IAF Mandatory Document for the Application of ISO 14065:2007
• ISO 14064-3:2006 - Greenhouse gases – Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions
• ISO 14066:2011 - Greenhouse gases – Competence requirements for greenhouse gas validation teams and verification teams

VERIFAVIA conducts CORSIA verification according to the following requirements:
 

• International Standards and Recommended Practices (SARPs), Environmental Protection — Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) (Annex 16, Volume IV to the Convention on International Civil Aviation)
• Environmental Technical Manual (ETM) (Doc 9501), Volume IV – Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)
• CORSIA Implementation Elements and Supporting Documents (in development)
• IATA Airline Handbook on CORSIA

VERIFAVIA conducts EU ETS verification according to the following regulations:
 

• DIRECTIVE 2003/87/EC of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC
• DIRECTIVE 2008/101/EC of 19 November 2008 amending Directive 2003/87/EC so as to include aviation activities in the scheme for greenhouse gas emission allowance trading within the Community
• DIRECTIVE 2009/29/EC of 22 April 2009 amending Directive 2003/87/EC so as to improve and extend the greenhouse gas emission allowance trading scheme of the Community
• COMMISSION DECISION of 8 June 2009 on the detailed interpretation of the aviation activities listed in ANNEX I to Directive 2003/87/EC 
• COMMISSION REGULATION 601/2012 of 21 June 2012 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC (MRR)
• COMMISSION REGULATION 600/2012 of 21 June 2012 on the verification of greenhouse gas emission reports and tonne-kilometre reports and the accreditation of verifiers pursuant to Directive 2003/87/EC (AVR)
• COMMISSION REGULATION 421/2014 of 16 April 2014 amending Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community, in view of the implementation by 2020 of an international agreement applying a single global market-based measure to international aviation emissions
• DECISION No 377/2013/EU of 24 April 2013 derogating temporarily from Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community
• REGULATION (EU) 2017/2392 of 13 December 2017 amending Directive 2003/87/EC to continue current limitations of scope for aviation activities and to prepare to implement a global market-based measure from 2021
• EA6/03 – EA Guidance document for Recognition of Verifiers Under EU ETS Directive
• Verification Guidance for EU ETS Aviation - AVR Explanatory Guidance (GD III)

> Visit our EU ETS Verification section for small emitters
> Go to our EU ETS pre-audit service section for airlines