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

A verified emission report, non-CO2 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-CO2 aviation effects, data relevant for free allocation or data relevant for climate-neutrality reports, including in relation to milestones and targets.’

For the purposes of verifying a climate-neutrality report the verifier shall check whether the milestones and targets laid down in the climate-neutrality plan have been achieved. To this end the verifier shall check: (a) the operator’s evidence on whether the measures related to milestones and targets have been implemented and whether the implementation of those measures has been completed; (b) the impact of any updates to the climate-neutrality plan on the achievement of milestones and targets; (c) whether the operator’s evidence of meeting milestones and targets is consistent with the climate-neutrality plan; (d) whether appropriate data is used to demonstrate whether milestones and targets laid down in the climate-neutrality plan have been achieved; (e) whether the calculation of data used to demonstrate whether milestones and targets laid down in the climate-neutrality plan have been achieved, is correct and whether that data is consistent with other relevant data in the verified emission report, baseline data report and annual activity level report; (f) whether the achieved targets demonstrate a reduction in line with the estimated greenhouse gas emission reduction described in the climate-neutrality plan and if not, what the justification is.’

1 By way of derogation from Article 21(1) of this Regulation, a verifier may decide not to carry out a site visit of an aircraft operator using the simplified tools referred to in Article 55(2) of Implementing Regulation (EU) 2018/2066 to determine CO2 emissions if the verifier has concluded, based on its risk analysis, that all relevant data can be remotely accessed by the verifier.

2 Where an aircraft operator uses the simplified tools referred to in Article 55(2) of Implementing Regulation (EU) 2018/2066 to determine the fuel consumption and the reported CO2 emission data has been generated using those tools independently from any input from the aircraft operator, the verifier may, based on its risk analysis, decide not to carry out the checks referred to in Articles 14 and 16, Article 17(1) and (2) and Article 18 of this Regulation.’

1 By way of derogation from Articles 7 to 27 of this Regulation, the aircraft operator’s non-CO2 aviation effects report is considered to be verified if the report is populated from NEATS or a third-party IT tool referred to in Article 56a(7) of Implementing Regulation (EU) 2018/2066, independently from any input of and without any amendment by the aircraft operator and if the aircraft operator is one of the following: (a) a small emitter within the meaning of Article 55(1) of Implementing Regulation (EU) 2018/2066; (b) for the reporting period 2025 and 2026, an aircraft operator having total annual emissions lower than 3000 tonnes of CO2 from flights other than those referred to in Article 28a(1), point (a), and Article 3c(8) of Directive 2003/87/EC.

2 Where the non-CO2 aviation effects report of an aircraft operator other than those referred to in paragraph 1, is populated from NEATS or a third party IT tool referred to in Article 56a(7) of Implementing Regulation (EU) 2018/2066, independently from any input of and without amendment by that aircraft operator, the non-CO2 aviation effects report is considered verified. However, the verifier carrying out a verification of that aircraft operator’s emission report shall check, as part of that verification, the consistency between flight information in the emission report and the flight information in NEATS or the third-party tool taking into account the scope of flights covered by Directive 2003/87/EC and reported by the aircraft operator.’

1 Articles 34 and 34a shall apply to the verification of regulated entity’s emissions covered by Chapter IVa of Directive 2003/87/EC. For that purpose, any reference to operator, installation and aircraft operator shall be read as if it were a reference to the regulated entity.

2 For the purpose of verifying a regulated entity’s emissions report pertaining to the reporting periods 2025 and 2026, the verifier may, based on the risk analysis, decide not to carry out checks on the methodology to determine the released fuel amounts if the quantity of the released fuel amounts in the regulated entity’s emission report is determined based on methodology as referred to in Article 75j(1)(a) of Implementing Regulation (EU) 2018/2066 and any of the following applies: (a) there is evidence from an independent source that the fuel quantities determined by the methods as referred to in Article 75j(1)(a) of Regulation (EU) 2018/2066 correspond to the released fuel amounts in the regulated entity’s emission report; (b) the released fuel amounts in the regulated entity’s emission report are generated from the computerised system used for the movement and surveillance of excise goods referred to in Article 20(2) of Council Directive (EU) 2020/262, without any change by the regulated entity.

3 The regulated entity shall provide the verifier with access to the evidence as referred to in paragraph 2, (point (a) and evidence from computerised system as referred to in paragraph 2, (point (b), in order to cross-check the quantity of the fuel amounts in the evidence with the released fuel amounts in the annual emission reports.

4 Article 43v(7)(a) shall not apply if the conditions laid down in Article 43w(3) are applicable and the verifier has decided not to carry out checks on the methodology to determine the released fuel amounts in accordance with paragraph 2.

5 Article 43v(7)(a) shall not apply if the conditions laid down in Article 43w(2) are applicable.

This Regulation shall enter into force on the third day following that of its publication in the Official Journal of the European Union. Article 1, points (11)(c), (11)(d) and (11)(e), (19)(b)(iii) and (29) shall apply from 1 January 2025 to the verification of emissions occurring from 1 January 2024 onwards.