Reliability of verification

A verified emission report, non-CO 2 aviation effects report, baseline data report, new entrant data report, annual activity level report or climate-neutrality report shall be reliable for users. Those reports shall represent faithfully that, which they either purport to represent or may reasonably be expected to represent.

The process of verifying operator’s or aircraft operator’s report shall be an effective and reliable tool in support of quality assurance and quality control procedures, providing information upon which an operator or aircraft operator can act to improve performance in monitoring and reporting emissions, non-CO 2 aviation effects, data relevant for free allocation or data relevant for climate-neutrality reports, including in relation to milestones and targets.’

Article 7 is amended as follows:

paragraph 4 is amended as follows:

points (a) and (b) are replaced by the following:

the operator’s or aircraft operator’s report is complete and meets the requirements laid down in Annex X to Implementing Regulation (EU) 2018/2066, in Annex IV to Delegated Regulation (EU) 2019/331, Article 3(2) or Annex II to Implementing Regulation (EU) 2019/1842, as appropriate;

the operator or aircraft operator has acted in compliance with the requirements of the greenhouse gas emissions permit and the monitoring plan approved by the competent authority, where the verification of an operator’s emission report is concerned, and with the requirements of the monitoring plan approved by the competent authority, where the verification of an aircraft operator’s emission report or non-CO 2 aviation effects report is concerned;’;

the following point (ca) is inserted:

where the verification of an operator’s climate-neutrality report is concerned, the operator has acted in conformance with the specifications of the climate-neutrality plan pursuant to Commission Implementing Regulation (EU) 2023/2441 ( *2 ) , in particular in relation to measures, milestones, investments and targets;

( *2 ) Commission Implementing Regulation (EU) 2023/2441 of 31 October 2023 laying down rules for the application of Directive 2003/87/EC of the European Parliament and of the Council as regards the content and format of climate-neutrality plans needed for granting free allocation of emission allowances ( OJ L, 2023/2441, 3.11.2023, ELI: http://data.europa.eu/eli/reg_impl/2023/2441/oj ).’;"

the third subparagraph is replaced by the following:

‘For the purpose of point (d), the verifier shall obtain clear and objective evidence from the operator or aircraft operator to support the reported aggregated emissions, non-CO 2 aviation effects, data relevant for free allocation or data relevant for climate-neutrality reports taking into account all other information provided in the operator’s or aircraft operator’s report.’;

the following paragraph (5a) is inserted:

‘5a. If the verifier discovers that an operator is not complying with Implementing Regulation (EU) 2023/2441, that irregularity shall be included in the verification report even if the climate-neutrality plan has been deemed compliant with that Regulation by the competent authority in accordance with Article 22b(1), point (c), of Delegated Regulation (EU) 2019/331.’

Article 9(1) is amended as follows:

the following point (ba) is inserted:

the level of information and complexity of the climate-neutrality plan, where the verification of the climate-neutrality report is concerned;’;

point (e) is replaced by the following:

the location of information and data related to greenhouse gas emissions, non-CO 2 aviation effects, data relevant for free allocation or data relevant for climate-neutrality reports.’;

Article 10(1) is amended as follows:

the following point (ca) is inserted:

the latest version of the operator’s climate-neutrality plan as well as any other relevant versions of the climate-neutrality plan;’;

point (h) is replaced by the following:

the operator’s or aircraft operator’s annual emission report, non-CO 2 aviation effects report, baseline data report, new entrant data report, annual activity level report or climate-neutrality report, as appropriate;’;

the following point (kb) is inserted:

if the climate-neutrality plan was updated during the climate-neutrality reporting period, a record of all those updates in accordance with Article 22d of Delegated Regulation (EU) 2019/331;’;

points (m), (n) and (o) are replaced by the following:

the verification report from the previous year, the previous baseline period or the previous climate-neutrality reporting period, as appropriate, if the verifier did not carry out the verification for that particular operator or aircraft operator the previous year, baseline period or climate-neutrality reporting period, as appropriate;

all relevant correspondence with the competent authority, in particular information related to the notification of modifications of the monitoring plan, monitoring methodology plan, the climate-neutrality plan or milestones and targets as well as corrections of reported data, as appropriate;

information on databases and data sources used for monitoring and reporting purposes, including those from Eurocontrol or another relevant organisation, non-CO 2 aviation effects tracking system (”NEATS’) or third-party IT tool pursuant to Article 56a(7) of Implementing Regulation (EU)2018/2066;’;

the following point (oa) is inserted:

information and underlying data that is used by the aircraft operator to compile flight information, information on aircraft properties and other type of information monitored, in order to perform the CO 2 equivalent calculation for non-CO 2 aviation effects per flight, where NEATS is made available later by the Commission in accordance with Article 56b(6) of Implementing Regulation (EU) 2018/2066;’;

Article 11 is amended as follows:

paragraph 3 is amended as follows:

point (b) is replaced by the following:

for the purposes of the verification of the aircraft operator’s emissions report or non-CO 2 aviation effects report, the size and nature of the aircraft operator, the distribution of information in different locations as well as the number and type of flights;’;

the following point (ca) is inserted:

for the purposes of verifying the climate-neutrality report, the climate-neutrality plan, the specific milestones and targets laid down in that plan as well as any updates of the climate-neutrality plan in the climate-neutrality reporting period;’;

point (d) is replaced by the following:

the nature, scale and complexity of emission sources and source streams as well as the equipment and processes that have resulted in emissions, non-CO 2 aviation effects or data relevant for free allocation, including the measurement equipment described in the monitoring plan or monitoring methodology plan as appropriate, the origin and application of calculation factors and other primary data sources;’;

the following point (f) is inserted:

for the purposes of verifying non-CO 2 aviation effects report the extent to which data is provided by the aircraft operators in NEATS or third-party IT tools approved by the Commission pursuant to Article 56a(8) of Implementing Regulation (EU) 2018/2066.’;

paragraph 4 is amended as follows:

the following point (aa) is inserted:

whether the climate-neutrality plan presented to it is the most recent version and whether this was deemed compliant by the competent authority in accordance with Article 22b(1), point (c), of Delegated Regulation (EU) 2019/331;’;

the following point (bb) is inserted:

whether there have been any modifications to the climate-neutrality plan during the climate-neutrality reporting period and whether the competent authority was informed on those modifications;’;

Article 13 is amended as follows:

in paragraph 1, point (c) is replaced by the following:

a data sampling plan setting out the scope and methods of data sampling related to data points underlying the aggregated emissions in the operator or aircraft operator’s emission report, the aggregated non-CO 2 aviation effects in the non-CO 2 aviation effects report, the aggregated data relevant for free allocation in the operator’s baseline data report, new entrant data report or annual activity level report, or the aggregated data relevant for demonstrating that milestones and targets laid down in the climate-neutrality plan have been achieved.’;

in paragraph 2, the first subparagraph is replaced by the following:

‘The verifier shall set up the test plan referred to in paragraph 1, point (b), in a manner that allows it to determine the extent to which the relevant control activities may be relied on for the purposes of assessing compliance with the requirements mentioned in Article 7(4), point (b), (c), (ca) and (d), or Article 7(4), third subparagraph.’;

in Article 14, the first subparagraph is replaced by the following:

‘The verifier shall implement the verification plan and, based on the risk analysis, the verifier shall check the implementation of the monitoring plan or monitoring methodology plan approved by the competent authority, or the climate-neutrality plan, as appropriate.’;

Article 16 is amended as follows:

paragraph 2 is amended as follows:

the introductory wording in the first subparagraph is replaced by the following:

‘2. As part of the data verification referred to in paragraph 1 and taking into account the approved monitoring plan, monitoring methodology plan or the climate-neutrality plan, as appropriate, including the procedures described in that plan, the verifier shall check:’

the following point (ca) is inserted:

for the purposes of verifying a climate-neutrality report, the consistency with the boundaries of the installation set out in Implementing Regulation (EU) 2018/2066 and its sub-installations set out in Delegated Regulation (EU) 2019/331;’;

point (d) is replaced by the following:

for the purposes of verifying an aircraft operator’s emission report or non-CO 2 aviation effects report, the completeness of flights covered by an aviation activity listed in Annex I to Directive 2003/87/EC for which the aircraft operator is responsible as well as the completeness of emission data or non-CO 2 aviation effects;’;

the following point (fb) is inserted:

for the purposes of verifying a climate-neutrality report, whether the historical emissions, emission levels as well as the activity levels are consistent with data included in the baseline data reports and the activity level reports;’;

the following paragraphs 2a, 2b, 2c and 2d are inserted:

‘2a. Where the aircraft operator provides data on flight trajectories in the non-CO 2 aviation effects report, the verifier shall check the completeness of flight trajectory information as part of the data verification referred to in paragraph 1 and taking into account the approved monitoring plan.

2b. Where the aircraft operator provides data on aircraft properties in the non-CO 2 aviation effects report, the verifier shall at least check as part of the data verification referred to in paragraph 1 and taking into account the approved monitoring plan:

the consistency between the aircraft types listed in the approved monitoring plan with reported data on aircraft types and those recorded in internal records;

the consistency between aircraft operator’s data sources and procedures on aircraft engines with the aircraft engine unique identifier number listed in the International Civil Aviation Organization (ICAO) engine emissions databank or equivalent data source that is used to identify engines attached to the aircraft;

the consistency between the aircraft mass, take-off mass or load factor in the aircraft operator’s internal records and mass and balance documentation with the data reported by the aircraft operator.

The verifier shall also use the aircraft performance simulation base of aircraft data to estimate the aircraft mass, take-off mass or load factor in order to compare to the data provided by the aircraft operator.

2c. Where the aircraft operator provides data on aircraft performance in the non-CO 2 aviation effects report, the verifier shall, as part of the data verification referred to in paragraph 1 and taking into account the approved monitoring plan, check the following:

the consistency between flight trajectory data and aircraft performance data along its trajectory, including cross checking the time stamps used for flight trajectory data and aircraft performance data;

the consistency between aggregated fuel consumption, data on fuel purchased or otherwise supplied to the aircraft performing the aviation activity and tank measurements;

the consistency between the data reported by the aircraft operator and manufacturer’s specifications, internal records and procedures related to the fuel delivered, fuel flow and aircraft engine efficiency, including the thrust of the aircraft engine;

any information that the verifier deems necessary to reduce the verification risk to an acceptable level to obtain reasonable assurance that the non-CO 2 aviation effects report is free from material misstatement.

When checking the consistency of data referred in point (a), the verifier shall also use the aircraft performance simulation base of aircraft data to estimate the fuel flow measurements and the engine efficiency in order to compare to the data provided by the aircraft operator.

2d. Where the aircraft operator uses its own method to determine fuel properties or weather data in the non-CO 2 aviation effects report, its own fuel burn module or emission estimation module referred to in Article 56a(4), point (a), of Implementing Regulation (EU) 2018/2066, the verifier shall check as part of the data verification referred to in paragraph 1, the validity of the input information used to determine the data and apply the methods as approved by the competent authority in the monitoring plan.’

the following paragraph 4 is added:

‘4. For the purposes of checking the completeness of flight trajectories referred to in paragraph 2a, the verifier shall use Eurocontrol’s Current Tactical Flight Model, Eurocontrol’s Regulated Tactical Flight Model, or alternatively, the Eurocontrol’s Filed Tactical Flight Model or equivalent in terms of data accuracy, where appropriate, as well as Automatic Dependent Surveillance–Broadcast data.’

Article 17 is amended as follows:

paragraph 4 is replaced by the following:

‘4. Where transferred CO 2 is subtracted in accordance with Article 49 of Implementing Regulation (EU) 2018/2066 and the CO 2 transferred is measured by both the transferring and receiving installation or the CO 2 transport infrastructure, the verifier shall check whether differences between the measured values at both installations or the CO 2 transport infrastructure can be explained by the uncertainty of the measurement systems and whether the correct arithmetic average of the measured values has been used in the emission reports of both installations or the CO 2 transport infrastructure.

Where the differences between the measured values at both installations or the CO 2 transport infrastructure cannot be explained by the uncertainty of the measurement systems, the verifier shall check whether adjustments were made to align the differences between the measured values, whether those adjustments were conservative and whether the competent authority has granted approval for those adjustments.

Where the CO 2 in transit has been reported in accordance with Article 49(7) of Implementing Regulation (EU) 2018/2066, the verifier shall check whether the CO 2 in transit has been transferred to another installation or CO 2 transport infrastructure no later than 31 January of the following year.’

the following paragraphs 4a, 4b and 4c are inserted:

‘4a. Where transferred N 2 O is not counted as emitted in accordance with Article 50 of Implementing Regulation (EU) 2018/2066 and the N 2 O transferred is measured by both the transferring and receiving installation, the verifier shall check whether differences between the measured values at both installations can be explained by the uncertainty of the measurement systems and whether the correct arithmetic average of the measured values has been used in the emission reports of both installations.

Where the differences between the measured values at both installations cannot be explained by the uncertainty of the measurement systems, the verifier shall check whether adjustments were made to align the differences between the measured values, whether those adjustments were conservative and whether the competent authority has granted approval for those adjustments.

4b. Where the CO 2 transferred in accordance with Article 49(6) of Implementing Regulation (EU) 2018/2066 results from materials or fuels containing zero-rated carbon, the verifier shall check all of the following:

the CO 2 transferred results from materials or fuels containing zero-rated carbon;

the transferring installation or CO 2 transport infrastructure has subtracted the transferred CO 2 correctly, proportional to the fraction of carbon that does not originate from zero-rated carbon;

the operator of the installation or the CO 2 transport infrastructure has monitored emissions from leakage events, fugitive emissions or vented emissions if such emissions occurred;

any information that the verifier deems necessary to reduce the verification risk to an acceptable level to obtain reasonable assurance that the emission report is free from material misstatement.

4c. Where CO 2 is permanently chemically bound in a product in line with Article 49a of Implementing Regulation (EU) 2018/2066, the verifier shall check all of the following:

the product is listed in Delegated Regulation (EU) 2024/2620;

the operator has subtracted correctly the CO 2 originating from non-zero-rated carbon that is permanently chemically bound in accordance with Article 49a of Implementing Regulation (EU) 2018/2066;

the quantity of CO 2 permanently chemically bound in a product listed in Delegated Regulation (EU) 2024/2620;

where the CO 2 results from material or fuels containing a fraction of zero-rated carbon:

the CO 2 results from those materials or fuels;

the operator has subtracted the CO 2 that is permanently chemically bound correctly, proportional to the fraction of carbon that does not originate from zero-rated carbon;

any information that the verifier deems necessary to reduce the verification risk to an acceptable level to obtain reasonable assurance that the emission report is free from material misstatement.’

paragraph 5 is replaced by the following:

‘5. For the purposes of verifying the operator’s emission report, the verifier shall, as part of the check referred to in paragraph 1, check the following evidence:

the operator’s evidence demonstrating compliance of zero-rated biomass fuels with the sustainability and greenhouse gas savings criteria laid down in Article 29(2) to (7) and (10) of Directive (EU) 2018/2001;

the operator’s evidence demonstrating compliance of zero-rated renewable fuel of non-biologic origin (‘‘RFNBO’’) or recycled carbon fuels (‘‘RCF’’) with the greenhouse gas savings criteria laid down in Article 29a of Directive (EU) 2018/2001;

the operator’s evidence demonstrating all the following:

compliance of zero-rated synthetic low carbon fuels with the greenhouse gas emission reduction threshold as referred to in Article 2, point (13), of Directive (EU) 2024/1788;

whether the carbon content of synthetic low carbon fuels have been subject to prior surrendering of allowances under Directive 2003/87/EC.’

the following paragraphs 5a and 5b are inserted:

‘5a. Where the operator has determined the biomass fraction and identical zero-rated biomass fraction of biogas using purchasing records in accordance with Article 39(4) of Implementing Regulation (EU) 2018/2066, the verifier shall check all the following:

the quantity of biogas purchased is not claimed to be used by anyone else;

the operator and producer of the biomass fraction are connected to the same grid;

any information that the verifier deems necessary to reduce the verification risk to an acceptable level to obtain reasonable assurance that the emission report is free from material misstatement.

5b. Where the RFNBO or RCF fraction and identical zero-rated RFNBO or RCF fraction of natural gas is determined in accordance with Article 39a of Implementing Regulation (EU) 2018/2066, the verifier shall check all the following:

the quantity of RFNBO or RCF purchased is not claimed to be used by anyone else;

the operator and producer of the RFNBO/RCF are connected to the same grid;

any information that the verifier deems necessary to reduce the verification risk to an acceptable level to obtain reasonable assurance that the emission report is free from material misstatement.’

paragraph 6 is replaced by the following:

‘6. Where the alternative aviation fuel or eligible aviation fuel is delivered to the aircraft in physically identifiable batches and can be physically attributed to a reported flight, the verifier shall check whether the alternative aviation fuel or eligible aviation fuel quantity is correctly attributed to the flight directly following the uplift of the fuel.

If several subsequent flights are carried out without fuel uplift between those subsequent flights, the verifier shall check whether the alternative aviation fuel or eligible aviation fuel quantity is assigned to these flights proportionally to the emissions from those flights calculated using the preliminary emission factor.

Where the alternative aviation fuel cannot be physically attributed at an aerodrome to a specific flight, the verifier shall check whether the alternative aviation fuel is attributed to flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC, proportionally to the emissions from those flights departing from that aerodrome calculated using the preliminary emission factor.

Where the eligible aviation fuel cannot be physically attributed at an aerodrome to a specific flight, the verifier shall check whether the eligible aviation fuel is attributed to flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC and to flights covered by Article 3c(8) of that Directive, proportionally to the emissions from those flights calculated using the preliminary emission factor.

For the purposes of the third and fourth subparagraph, the verifier shall check whether the alternative aviation fuel or eligible aviation fuel was delivered to the fuelling system of the departure aerodrome in the reporting period, or 3 months before the start, or 3 months after the end, of that reporting period as specified in the monitoring plan approved by the competent authority.

For the purposes of the first, second, third and fourth subparagraph, the verifier shall check whether:

the alternative aviation fuel or eligible aviation fuel is correctly assigned to aerodrome pairs in the aircraft operator’s emission report;

the total amount of the alternative aviation fuel claimed does not exceed the total fuel reported of that aircraft operator for flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC, originating from the aerodrome at which the alternative aviation fuel is supplied;

the total amount of eligible aviation fuel does not exceed the total fuel reported of that aircraft operator for flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC and for flights covered by Article 3c(8) of that Directive, originating from the aerodrome at which the eligible aviation fuel is supplied;

the total amount of alternative aviation fuel for flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC does not exceed the total quantity of alternative aviation fuel purchased from which the total quantity of alternative aviation fuel sold to third parties is subtracted;

the total amount of eligible aviation fuel for flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC and from flights covered by Article 3c(8) of that Directive does not exceed the total quantity of eligible aviation fuel purchased from which the total quantity of eligible aviation fuels sold to third parties is subtracted;

the ratio between alternative aviation fuel or eligible aviation fuel and fossil fuels attributed to flights aggregated per aerodrome pair does not exceed the maximum blending limit for that alternative aviation fuel or eligible aviation fuel as certified according to a recognised international standard;

the aggregated zero-rated fraction in the alternative aviation fuel does not exceed the amount of alternative aviation fuel for which the following proof is provided:

where the zero-rated fraction concerns the biomass fraction of a mixed alternative aviation fuel, the proof for meeting the sustainability and greenhouse gas savings criteria laid down in Article 29(2) to (7) and (10) of Directive (EU) 2018/2001;

where the zero-rated fraction concerns the RFNBO or RCF fraction of a mixed alternative fuel, the proof for meeting the greenhouse gas savings criteria laid down in Article 29a of Directive (EU) 2018/2001;

where the zero-rated fraction concerns the synthetic low carbon fuel fraction of a mixed alternative fuel, the proof for meeting the greenhouse gas emission reduction threshold as referred to in Article 2, point (13), of Directive (EU) 2024/1788 and proof that the carbon content of the synthetic low carbon fuel has been subject to prior surrendering of allowances under Directive 2003/87/EC;

the same amounts of alternative aviation fuel or eligible aviation fuel have not been accounted for and claimed to be used in an earlier report, or by another aircraft operator, or in another carbon pricing system.’

The following Article 17c is inserted:

COMMISSION IMPLEMENTING REGULATION (EU) 2025/1192 of 18 June 2025 amending Implementing Regulation (EU) 2018/2067 as regards certain aspects on the verification of data and on the accreditation of verifiers ANNEX