German Emissions Trading Authority

Verifiers

Accredited or certified verifiers play a central role in the European Emissions Trading Scheme (EU ETS 1) because they verify the information provided by operators and aircraft operators.

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Verified independently

The verification of various reports and applications from operators and aircraft operators by an independent, third-party body is intended to ensure that the information provided by the operators is correct and reliable. After completing all verifications and with satisfactory results, the accredited verifier will verify the reports and applications.

In addition to the written data check, verification also includes an on-site inspection of the operator's installation. This involves a comparison of the actual conditions with the approval situation. This includes the monitoring plan, method plan, emission permit and the data in the reports and applications. As part of this verification, verification reports are prepared in which the verifier declares whether the verified data are free of material misstatements and deviations from the applicable regulations with reasonable certainty. The verification reports are then submitted by the operators together with their own reports and applications to the German Emissions Trading Authority (DEHSt).

For the application, please use the form "Application for virtual site visit" on our website.

14/11/2023

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Tasks

The reports and applications for the fourth trading period to be submitted to DEHSt must be verified in advance by an independent, accredited or certified verifier (cf. Section 21 TEHG 2011, last amended by Act of 10/08/2021).

In addition to accreditation or certification, which give the verifiers direct authority to act, Germany also requires mandatory participation in the electronic administrative procedure so that reports and applications are effectively verified.

You will find the necessary steps for the electronic administrative procedure below:

  1. The Form Management System (FMS)
    DEHSt provides operators and aircraft operators with various electronic templates for submitting applications and reports based on the FMS. The verification report that has been prepared is linked to the verified report or application on the respective FMS form. Therefore, each verifier requires verifier access to the FMS electronic report templates.

  2. Electronic Signature (QES)
    The test reports should be provided with a qualified QES as an equivalent to a legally valid signature.

  3. Virtual Post Office (VPS).
    Electronic communication requires a P.O. Box in DEHSt's VPS.

  4. Verifier account
    Verifiers in Germany need a verifier account in the German part of the Union Registry and must be assigned by the commissioning operators or aircraft operators to the relevant operator holding accounts. Verifiers in other Member States also need an account in the part of the Union Registry of the nation in which they operate. For more information on how to apply for a verifier account, see Union Registry.

22/02/2023

Legal framework

EU Accreditation and Verification Regulation

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).

To the topic

TEHG and EHV 2030

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.

Accreditation/certification

Accreditation of Verifiers by the DAkkS

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 (ECNo. 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).

Certification of Verifiers by the DAU

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 (ECNo. 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.

Accreditation and certification fields

The accreditation or certification is specific with regard to different emissions trading activities (see Article 43 in conjunction with Annex I EU Accreditation and Verification Regulation). A global accreditation or certification as a verifier in the EU emissions trading system (EU ETS 1) does not exist.

The verifier must ensure that the commissioned verification service also falls within his scope of accreditation.

The activities subject to emissions trading are grouped into ‘activity groups’ pursuant to Annex I EHRL or TEHG in Annex I of the EU Accreditation and Verification Regulation.

Overview of Accreditation Fields
Activity group No.Scopes of accreditation
1aCombustion of fuels in installations, where only commercial standard fuels as defined in Regulation (EU) No 601/2012 are used, or where natural gas is used in category A or B installations.
1bCombustion of fuels in installations, without restrictions
2Refining of mineral oil
3
  • Production of coke
  • Metal ore (including sulphide ore) roasting or sintering, including pelletisation
  • Production of pig iron or steel (primary or secondary fusion) including continuous casting
4
  • Production or processing of ferrous metals (including ferro-alloys)
  • Production of secondary aluminium
  • Production or processing of non-ferrous metals, including production of alloys
5Production of primary aluminium (CO2 and PFC emissions)
6
  • Production of cement clinker
  • Production of lime or calcination of dolomite or magnesite
  • Manufacture of glass including glass fibre
  • Manufacture of ceramic products by firing
  • Manufacture of mineral wool insulation material
  • Drying or calcination of gypsum or production of plaster boards and other gypsum products
7
  • Production of pulp from timber or other fibrous materials
  • Production of paper or cardboard
8
  • Production of carbon black
  • Production of ammonia
  • Production of bulk organic chemicals by cracking, reforming, partial or full oxidation or by similar processes
  • Production of hydrogen (H2) and synthesis gas by reforming or partial oxidation
  • Production of soda ash (Na2 CO3) and sodium bicarbonate (NaHCO3)
9
  • Production of nitric acid (CO2 and N2O emissions)
  • Production of adipic acid (CO2 and N2O emissions)
  • Production of glyoxal and glyoxylic acid (CO2 and N2O emissions)
  • Production of caprolactam
10
  • Capture of greenhouse gases from installations covered by Directive 2003/87/EC for the purpose of transport and geological storage in a storage site permitted under Directive 2009/31/EC
  • Transport of greenhouse gases by pipelines for geological storage in a storage site permitted under Directive 2009/31/EC
11Geological storage of greenhouse gases in a storage site permitted under Directive 2009/31/EC
12Aviation activities (emissions and tonne-kilometre data)
98Other activities pursuant to Article 10a of Directive 2003/87/EC
99Other activities, included by a Member State pursuant to Article 24 of Directive 2003/87/EC, to be specified in detail in the accreditation certificate

Example:

An installation is subject to emissions trading as a factory for the production of ammonia according to §2(1) in conjunction with Annex 1, Part 2, No. 26 TEHG. The operator must then ensure that the verifier mandated by him is accredited for the activities in group No. 8 Annex I EU Accreditation and Verification Regulation.

22/02/2023

To the topic

Notes on verification fields

Emission reports/tonne-kilometre reports 2013 to 2020

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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.

Allocation period 2021 to 2025

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.

Allocation period 2026 to 2030

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.

Further information

Exchange of experience for verifiers , 17/11/2022

On 17/11/2022, we organised our exchange of experience for verifiers together with the Deutsche Akkreditierungsstelle GmbH (DAkkS). 

The focus was on emissions and allocation operational reports in verification, also in connection with the BEHG.

(The slides are available in German only.)

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