The EU Accreditation and Verification Regulation (Commission Implementing Regulation (EU) 2018/2067 of 19/12/2018) is the uniform legal basis for the verification of emissions reports, tonne-kilometre reports and activity level reports from the start of the fourth trading period. It directly harmonises the checking and verification procedure and the accreditation of verifiers throughout the EU. 

On the one hand, this specifies the requirements to be fulfilled by the verifiers with regard to their internal organisation. These relate to verification processes, quality management systems, competence processes, ensuring independence, etc. in interaction with DIN EN ISO/IEC 17029 Conformity assessment – General principles and requirements for validation and verification bodies.

On the other hand, the EU Accreditation and Verification Regulation also sets requirements for the accreditation bodies and the accreditation procedure (including supervision of the accredited bodies) in interaction with DIN EN ISO/IEC 17011 (Conformity assessment – General requirements for accreditation bodies accrediting conformity assessment bodies).

The EU Accreditation and Verification Regulation thereby integrates the accreditation of verifiers into the already existing basic European legal framework for the accreditation of conformity assessment bodies. The competence for accreditation is basically assigned to the national accreditation bodies of the Member States established according to Regulation (EC) No 765/2008.

Finally, it also regulates the cooperation and exchange of information between the emissions trading authorities and the accreditation or certification bodies to ensure the highest possible quality in the field of verification on a permanent basis.

The EU Accreditation and Reporting Regulation, together with the EU Monitoring Regulation, creates the legal basis in EU emissions trading in the field of emissions monitoring, emissions reporting and activity level reporting with Europe-wide harmonisation with regard to verification, accreditation and certification of verifiers. This means that verifiers accredited or certified in one Member State are in principle entitled to offer and carry out verifications in all Member States (cf. Article 67 EU Accreditation and Verification Regulation).

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Legislation

Section 21 of the Greenhouse Gas Emissions Trading Act (TEHG) stipulates that only accredited or certified verifiers may operate in emissions trading.

Legal entities and ordinary persons can be approved as verifiers. However, the EU Accreditation and Verification Regulation primarily relies on the accreditation of verifiers under the competence of the national accreditation bodies of the Member States. In conjunction with DIN EN ISO/IEC 17029 and DIN EN ISO 14065, only legal persons or legal entities can obtain accreditation (cf. Article 3(3) alt. 1 Accreditation and Verification Regulation or Section 5.2 EN ISO 14065).

Secondarily, ordinary persons (sole traders) can also be approved as verifiers (Article 55(2) and cf. Article 3(3) alt. 2 of the Accreditation and Verification Regulation). The requirements of the EU Accreditation and Verification Regulation must be implemented in an equivalent manner. Article 28(2) of the TEHG contains the legal basis for ordinary persons to be certified and approved as verifiers in Germany.

The 2030 Emissions Trading Ordinance (EHV 2030) of 29/04/2019 (last amended by Article 19 of the Act of 10/08/2021) is an overarching implementing regulation for the TEHG. Section 6 (Sections 9 – 13 EHV 2030) regulates the certification of verifiers. Specifically, it follows from the regulations that the Deutsche Akkreditierungs- und Zulassungsgesellschaft für Umweltgutachter mbH (DAU, German Accreditation and Licensing Society for Environmental Auditors) is entrusted with the tasks of the national certification body for verifiers. In order to ensure the equivalence of certification with accreditation pursuant to the EU Accreditation and Verification Regulation, latter applies accordingly to the certification of verifiers.

You can find further information on German Accreditation and Registration Body for Environmental verifiers (DAU)

The DAkkS (German Accreditation Body of the Federal Republic of Germany) is responsible for the accreditation of verifiers located in Germany. In principle, only corporations or partnerships can be accredited.

The DAkkS is a government appointed agency of the Federal Republic of Germany. Pursuant to accreditation body legislation, and the appointment regulations based thereon (AkkStelleGBV), the agency performs the duties of the national accreditation body in accordance with Regulation (EC) No. 765/2008. Its responsibility for the accreditation of verifiers in Germany is therefore directly based on Article 55 (1) of the EU Accreditation and Verification Regulation.

If you have any questions about the details of the accreditation process, or the documentation that needs to be provided, please contact the DAkkS.

In future, the DAkkS will also maintain a directory of accredited verifiers for EU emissions trading (EU ETS 1) on its website (see Article 76(1) of the EU Accreditation and Verification Regulation). Accreditation is specific to activity groups (see Article 44 and Annex I EU Accreditation and Verification Regulation).

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Legislation

National accreditation body for the Federal Republic of Germany (DAkkS)

The Deutsche Akkreditierungs- und Zulassungsgesellschaft für Umweltgutachter mbH (DAU, German Accreditation and Licensing Society for Environmental Auditors) is responsible for the certification of verifiers. The certification is the formal recognition of individuals as single person verifiers.

The DAU is a government appointed agency of the Federal Republic of Germany. Pursuant to the Environmental Audit Act (Umweltauditgesetz) and the corresponding Appointment Regulation (UAGBV) the DAU is responsible for licensing environmental auditors and environmental auditor organisations, according to Regulation (EC) No. 1221/2009. In addition, it is tasked with the optional certification of verifiers ( see Section 9 (1) EHV 2030 and Article 55 (2) of the EU Accreditation and Verification Regulation). Certified verifiers do not have to be environmental verifiers at the same time. Certification is specific to groups of activities (compare Article 44 in conjunction with Annex I EU Accreditation and Verification Regulation).

If you have any questions about the details of the certification process, about whom to contact or about required documentation, etc., please contact the DAU.

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German Accreditation and Registration Body for Environmental verifiers (DAU)

The verification of emission reports and tonne-kilometre reports must be consistent with the EU Accreditation and Verification Regulation. Articles 6-33 of the EU Accreditation and Verification Regulation apply specifically.

To explain the requirements, the European Commission has published a series of guidance documents on its website. In principle, the documents can also be used for aviation. However, there is also a separate comprehensive Guide (aviation).

Virtual site visit

In exceptional cases due to force majeure, virtual site visits can also be carried out. However, since the pandemic situation has eased, these require approval from the third quarter of 2023 (Article 34a(3) Accreditation and Verification Regulation (EU) 2018/2067 AVR). The preconditions for a waiver of approval by the authority for a virtual site visit no longer exist pursuant to Article 34a (4) AVR.

An accredited verifier decides whether a site visit should be conducted virtually due to force majeure. The aircraft or installation operator then submits an application to DEHSt via the Virtual Post Office (VPS) with the verifier's decision. The application must be completed by the verifier and contain the following documentation in accordance with Article 34a (2) AVR:

• Evidence that no physical site visit can be carried out due to force majeure.
• Information on how the virtual site visit will be carried out;
• Information on the result of the verifier's risk analysis;
• Evidence that the verifier has taken measures to reduce the verification risk to an acceptable level.

Force majeure

Force majeure occurs due to serious, extraordinary and unforeseeable circumstances beyond the control of the aircraft or installation operator. Examples of force majeure within the meaning of Article 34a AVR are pandemics, war, terrorism, natural or man-made disasters. This also includes disasters that result in the facility being closed to external parties or that make it impossible to travel to the site. Force majeure can be very specific national, regional or even local circumstances.

More details on the individual requirements will be available shortly in the updated guidance documents on stationary installations and aviation.

The required application form can be found below.

Waiver of site visits

Under certain conditions, site visits may be waived in exceptional cases in accordance with Articles 31 and 32 of the EU Accreditation and Verification Regulation. However, the waiver must not be at the expense of the reliability of the verification. Depending on the amount of annual greenhouse gas emissions of a facility, a distinction must be made according to this article as to whether the verifier can decide on the waiver independently or whether additional approval from us is required. For the application to waive the site inspection, which the installation operator must submit, the form "Declaration by the verifier to waive a site inspection in accordance with Articles 31 and 32 GCEA", which can be downloaded below, must be used.

Details on the waiver of site inspections can be found in Chapter 23.6 of our guidelines.

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EU Commission: Monitoring, reporting and verification – Guidance and templates

The Accreditation and Verification Regulation - Site visits

The Accreditation and Verification Regulation - Verification Guidance for EU ETS Aviation

Waiver of site visits

Application for conducting a virtual site visit

Application for waiver of a site visit

Leitfaden zur Erstellung von Überwachungsplänen und Emissionsberichten für stationäre Anlagen (2021 bis 2030)

Allocation applications by new entrants

In the field of allocation for new market entrants, verification of the application by an accredited or certified verifier will also be required in future as part of the first two annual activity level reports, cf. Guideline 2021-2030 Allocation Part 4. Verifiers verifying allocation applications for new market entrants must also have accreditation in Activity Group 98 in addition to the specific accreditation for the respective activity group in accordance with Annex I No. 1a – 9 EU Accreditation and Verification Regulation.

Operational reports

According to Article 3 of the EU Adjustment Regulation, operators are obliged to report allocation data on an annual basis. In order to report this data reliably, operators shall monitor and collect the data in accordance with the EU Allocation Regulation and the approved methodology plan.

Each activity level report must be verified by a AVR accredited verifier and submitted to DEHSt by the operator together with the corresponding verification report.

Verifiers verifying annual activity level reports must be accredited for the Activity Level 98 and technical sector activity level of the Annex I installation for which the verifier is performing the verification. Since the verifier largely checks the same data sets for the verification of the activity level report as for the verification of the allocation application, comparable competence requirements apply to the verifiers verifying the activity level report. Verifiers must be familiar with the requirements of the EU Adjustment Regulation, the EU Allocation Regulation and the applicable guideline and know which additional checks are to be carried out for the verification of the activity level report, what is to be observed during the site inspection and how to report findings in the verification report.

Identification and Implementation of Energy Efficiency Measures

From the second allocation period (2026 – 2030) in the fourth trading period of the EU Emissions Trading System 1, the full free allocation is linked to investments in technologies to increase energy efficiency and reduce greenhouse gas emissions in accordance with Article 22a(1) of the EU Allocation Regulation ((EU) 2019/331, currently available as a draft in the public consultation). Further information and two working tools can be found via the link below.

Notes on the verification of allocation applications and allocation data reports

Part 4 of the guidelines from the first allocation period has not been revised.

Futher information you can find under allocation application 2026 to 2030