Since January 2010, airlines affected by the European Union (EU) Emissions Trading Scheme (ETS) must monitor their aircraft emissions and tonne-kilometer data according to their monitoring plans. Only airlines that operate more than a daily round-trip flight on average to, from or within the EU must comply with the EU ETS regulations. Affected airlines (from the African region) include Royal Air Maroc, Air Arabia Morocco, Jet4You, Air Algérie, Tunisair, Nouvelair Tunisie, Afriqiyah Airways, Air Cairo, Air Madagascar, Air Mauritius and Air Seychelles (administered by France); Libyan Airlines, Egyptair, Kenya Airways and South African Airways (administered by the UK); and Ethiopian Airlines (administered by Italy).

Early 2011, airlines will need to prepare their annual aircraft emissions and tonne-kilometer reports and have them verified by an accredited verifier before being submitted to their Competent Authority before 31 March 2011. Verification is one of the three pillars of the MRV process (Monitoring, Reporting and Verification) and is a key step to ensure the credibility, reliability and accuracy of the EU ETS. The aim of verification to reach a verification opinion with reasonable assurance that:
-The existing procedures conform with the approved monitoring plans and the EU ETS rules

The data submitted in the annual emissions  or tonne-kilometer reports are fairly stated, i.e. free from material misstatements. The verification audit may be split into three phrases and nine steps:

Step 1. Pre-contract Stage
Ensure that the scope and extent of verification activities and time quoted are sufficient to meet the requirements for «Reasonable Assurance».

Step 2. Strategic & Risk Analysis
Understand the operator's organization and the design and implementation of its EU ETS management and control systems. Identify where there are risks of system failure/breakdown that might result in a material misstatement in the EU ETS data.

Step 3. Verification Plan
Prepare a verification plan which includes a detailed verification program, a data analysis plan and the details of a site visit, if required.

Step 4. Business Process Analysis
Implement the verification plan in order to assess whether the EU ETS management system conforms with the approved monitoring plans, the MRG and the national legislation of the administering Member State.

Step 5. Data Analysis
Test data using an EU ETS data analysis system which automatically performs plausibility checks on the entire data set. Perform data sampling and other key cross-checks.

Step 6. Reporting
Maintain and share with the operator an Issues Log that lists issues arising so that they can be closed out before completion of the audit.

Step 7. Technical Review
Review the verification pack and draft verification opinion by an independent technical reviewer who did not take part in the verification process itself.

Step 8. Final Verification Report
Submit the final verification opinion to the operator who will forward it to the Competent Authority. Includes materiality analysis.

Step 9. EU ETS registry
Approve the relevant entries into the EU ETS registry of the operator.

In practice, the verifier will need to understand the data transformation process between the raw fuel and payload data and the final reports. The verifier will need to understand the procedures in place, the IT systems used to collect, store and process the EU ETS data, and to make sure the people involved are aware of their roles and responsibilities. This is done through the review of documents, the observation of processes, interviews, data testing and sampling, as well as audit trails.

Verification is based on the approaches used for both financial and management systems auditing. The duration of a verification audit depends on the complexity of the operator's EU ETS management and control systems, the size and complexity of its operations, and the scope of the verification activities. A typical verification audit lasts between 5 and 7 man-days, including 2-3 days on-site.
The main principles of verification are to make sure that the data satisfies the following principles: completeness, consistency, transparency, trueness, cost effectiveness, materiality, faithfulness, and improvement of performance.

Although the deadline for the submission of the verified reports to the Competent Authority is 31 March 2011, airlines are strongly recommended to start the verification process as early as possible in 2010. First of all, this allows them to avoid pressure by conducting all the verification work at the last minute. Most importantly, this allows time for corrective actions, if need be. Verification is an iterative process aiming at continuous improvement of operator's EU ETS management and control systems. A two-stage verification audit precisely allows time for improvement during the course of the verification audit.

In order to be considered as an approved verifier, a verification body must be accredited according to the ISO 14065 standard and the EA-6/03 guidance. This involves the design and the implementation of a quality-based EU ETS assurance management system. The accreditation is granted by the national accreditation body of the home country: the United Kingdom Accreditation Service (UKAS) in the UK, the Comité français d'accréditation (COFRAC) in France and ACCREDIA in Italy. The accreditation process includes a witnessed audit and is sector-specific, which means that non-aviation verifiers must be accredited for aviation.

In France, the legislation on EU ETS verification for aircraft operators was published on 9 August 2010. The legislation includes a facility that allows verification bodies that are candidate for accreditation to be considered as temporarily able to conduct verification audits while the accreditation process is underway. This allows solving the problem that in order to be accredited, a verification body must conduct verification audits.

The DGAC was the first Competent Authority to publish a list of accredited and temporarily able verifiers on 16 September 2010. Airlines reporting to France can select their verification body from this list. In the UK, although a couple of verification bodies have already been accredited, most of them are still in process of accreditation. Before selecting a verifier, airlines are recommended to contact UKAS to make sure that the verifier is indeed in process of accreditation with good chance of success. In Italy, at the time of writing, the Competent Authority had not yet published any list of approved verifiers.

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