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EU ETS Pre-audit (big emitters)

A pre-verification audit (or 'gap analysis') is a 'readiness for legal verification' audit which aims to highlight any weakness in the aircraft operator's EU ETS management and control systems, and to identify any areas where there are risks of non-compliance.

The benefit is that if done early in the reporting period, it can highlight any compliance and system design issues enabling correction in a timely manner.

Important note: this service is not consultancy; under no circumstances do we offer technical assistance or consultancy services to aircraft operators.

Compliance Review

Verifavia will compare the approved monitoring plans (Annual Emissions and /or Payload Tonne-Kilometers) with the EU ETS regulations to identify any non-compliance. Also, Verifavia will review the monitoring plans to determine if they contain sufficient details for each procedure for the operator's personnel to follow.

It is possible that the operator's monitoring plans have been approved by the competent authority but do not comply with the MRR or member state specific guidelines. The gap analysis can help identify these problems.

In addition, Verifavia will consider the following elements:
  • Whether there have been any changes to the procedures listed in the monitoring plan(s) and how the operator has communicated them to the Competent Authority
  • The nature, scale and complexity of the operator's operations and the associated EU ETS procedures
  • The complexity of IT systems used to handle EU ETS data
  • Whether all the required control elements (MRR) have been accounted for

ETS Management System Review

Upon the outcome of the Compliance Review, Verifavia will look at how these systems have been implemented in practice, to ensure that they have been implemented correctly, that EU ETS related systems have been integrated properly with other parts of the operator’s business control systems, and that overall they are robust.

As part of the management system review, Verifavia will consider:
  • The existence of an environmental or a quality management system
  • The existence of relevant quality control and assurance processes
  • The organizational structure of EU ETS management
  • The availability of information and data in terms of access, completeness and accuracy
The aim of these tasks is to ensure that the overview provided by the monitoring plan is sufficient for transparency and robustness; and that the EU ETS systems have been designed effectively and implemented properly.

Data Analysis

Verifavia will conduct a thorough analysis of EU ETS data collected until the audit day by uploading flight, payload and fuel data into the Verifavia ETS Data Analysis System (VEDAS) which will identify data gaps, highlight flights whose fuel consumption is outside of the typical range and perform plausibility checks on fuel and payload data.

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

Verifavia will also test a sample of the data to determine if there have been any errors in the data transfer processes from the primary data source (load sheets, fuel delivery notes, etc.) to the reported data.


Verifavia will prepare a pre-verification report to highlight the weaknesses of the EU ETS systems designed and implemented by the operator and will assess the readiness of the operator for the legal verification process.

> Go to our EU ETS Training section