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EU ETS Verification (big emitters)

Independent third-party GHG verification if a legal environmental audit that all aircraft operators in the EU ETS are required to conduct. Verifavia is a leading provider of independent verification services of GHG  emissions for aviation under the EU ETS directive. 

Between 2010 and 2017, Verifavia conducted EU ETS verification of nearly 800 different aircraft operators - including 110+ commercial airlines - from 70 countries and reporting to 25 different EU Competent Authorities.


Visit our EU ETS Verification section for small emitters

Mission statement

Verifavia provides  flexible,  efficient  and  competitive  verification services of greenhouse gas emissions for airlines and helicopter operators under the EU ETS Directive:
  • 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 annual emissions or tonne-kilometre report is fairly stated, i.e. free from material misstatements
  • The existing procedures conform with the approved monitoring plans and the EU ETS regulations
Verification is an iterative process aiming at continuous improvement of the operator's EU ETS 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 EU ETS management system (organisation, procedures, IT) and control system, identification of any risk areas, and assessment of whether the procedures conform with the monitoring plan and the EU ETS regulations
  2. Stage 2: detailed testing and analysis of ETS data, independent technical review, materiality analysis and final verification opinion
The structure of the verification activities is consistent with the EU ETS regulations and is documented in the Verifavia ETS Assurance Management System Manual which is based on the approaches used for both financial and management systems auditing.

Verification is an iterative process aiming at continuous improvement of the operator's management and control systems. 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 EU 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 a material misstatement or non-conformity in the annual emissions or tonne-kilometre 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 plans and any changes during the monitoring period
  • The nature, scale and complexity of the operator's operations and the EU ETS processes
  • The complexity of IT systems used to handle EU ETS data
  • Whether all the required control elements (MRR) 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 EU ETS management 
  • The availability of information and data in terms of access, completeness and accuracy

Step 4 – Verification Plan

Based on the strategic and risks 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(s), if required

Step 5 – Business Process Analysis

Verifavia will implement the verification plan and assess whether the EU ETS management system conforms with the approved monitoring plans and the MRR.

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 EU ETS manager, Flight Operations, Quality, Maintenance, IT, Ground Handling, Cargo and other departments if required
  • Observation of IT systems or spreadsheets used to process EU ETS data
  • Review of documents including Quality Manual, EU ETS Manual, calibration certificates and documented quality and maintenance activities
  • Review of flight documentation including technical logs, journey logs, load sheets, fuel delivery notes, fuel invoices
  Step 6 – Data Analysis

Verifavia will conduct a thorough analysis of EU ETS data by uploading flight, payload and fuel data into our VerifAvia EU ETS Data Analysis System (VEDAS) which automatically identifies data gaps, highlights flights with fuel consumption outside of the typical range and performs 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.

During Step 6, Verifavia will also:
  1. Cross-check flight data with the air traffic data collected by EUROCONTROL and accessible through the CEFA invoices or the ETS Support Facility
  2. Perform consistency checks between aggregated fuel consumption data and total fuel purchased (only when all flights are included into the EU ETS)
  3. Conduct data sampling of payload and fuel data 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. He then drafts the opinion and compiles its work papers and collected evidence into a verification pack.

Step 8 - Technical Review

Before a decision can be made to issue the final verification opinion, the verification pack 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 has been used, and that any verification risks have been minimised.

Step 9 – Final Verification Report

Verifavia will submit a final verification opinion to the operator. It is the operator's responsibility to submit this to the Competent Authority together with a copy of the verified emissions and tonne-kilometre reports.

Step 10 – Approval of data in the EU ETS registry

Verifavia will then approve the relevant entries into the EU ETS registry of the client.


Regulations & Criteria

Verifavia conducts EU ETS verification according to the following regulations and criteria:

DIRECTIVE 2003/87/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 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 THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 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 THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 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 of the European Parliament and of the Council

COMMISSION REGULATION (EU) No 109/2013 of 29 January 2013 amending Regulation (EC) No 748/2009 on the list of aircraft operators that performed an aviation activity listed in Annex I to Directive 2003/87/EC of the European Parliament and of the Council on or after 1 January 2006 specifying the administering Member State for each aircraft operator also taking into consideration the expansion of the Union emission trading scheme to EEA-EFTA countries

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 (EU) No 389/2013 of 2 May 2013 establishing a Union Registry pursuant to Directive 2003/87/EC of the European Parliament and of the Council, Decisions No 280/2004/EC and No 406/2009/EC of the European Parliament and of the Council and repealing Commission Regulations (EU) No 920/2010 and No 1193/2011

COMMISSION REGULATION (EU) No 421/2014 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 THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 24 April 2013 derogating temporarily from Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community

ISO 14065:2013 – 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 14065:2013

BS EN45011 – General requirements for bodies operating product certification systems

EA6/03 – EA Guidance document for Recognition of Verifiers Under EU ETS Directive

THE ACCREDITATION AND VERIFICATION REGULATION - Verification Guidance for EU ETS Aviation -  AVR Explanatory Guidance (GD III)

THE ACCREDITATION AND VERIFICATION REGULATION - Quick guide to verification of small emitters  (EU ETS Aviation)

> Go to our EU ETS pre-audit service section for big emitters