The Verification Process: An Overview

This section explains the main stages of our process for the monitoring, reporting and verification against the requirements of EU MRV & EU ETS & UK ETS & FUEL EU.   The verification process for most schemes includes two main stages before the Verification Report and document of compliance can be finalised and issued. These two main stages are:

  • Monitoring Plan assessment of conformity – comprising assessment that each ship’s Monitoring Plan conforms with requirements
  • Verification of data and information

At each stage our verifiers will be open and helpful and will follow a practical approach. In this way, we can add value to the verification process. Before each stage we will inform you about the dates, how long the stage will last, team members and where the verification will take place. The above stages will be done remotely in most cases, but to gain a better understanding of your systems and data gathering and data flow activities it may be more efficient to spend a short amount of time reviewing these at your office.

Our solutions

  • Monitoring Plan assessment
  • Verification of data and information
  • Findings/Gradings
  • Site visits

We carry out this stage to assess conformity of every ship Monitoring Plan to requirements defined in the applicable regulatory requirements. Your organisation will be required to provide at least the information defined within the Evidence Pack Requirements document provided in Emissions Verifier. If we agree that the process may be more efficient with a short visit to your head office, we will start with an opening meeting, at which the Verifier will explain the verification approach to your management team and be introduced to the company. The Verifier will also agree a plan for the visit with your company. We will review the key information provided to establish conformity against applicable regulatory requirements. 

Our verification process follows EU regulatory requirements to ensure your emissions reports are accurate, complete and compliant.

1. Strategic review

We begin by reviewing your ship's activities and Monitoring Plan (MP) to understand the scope and complexity of the verification. If the Monitoring Plan is incomplete, outdated or awaiting approval from the Administering Authority (AA), the verification process is paused until this has been resolved.

2. Evidence review

You provide the required documentation and evidence. We review the information against the Evidence Pack Requirements and, where necessary, request additional evidence to confirm completeness, accuracy and compliance.

3. Risk assessment

Our verifier assesses potential risks within your monitoring and reporting processes, including data calculations, controls and any methods used to manage data gaps. This forms the basis of the verification plan.

4. Verification activities

We verify that your monitoring system is implemented as described in the Monitoring Plan by:

  • Reviewing internal controls and procedures
  • Testing emissions data using a risk-based sampling approach
  • Checking calculations and data gap methodologies
  • Collecting sufficient evidence to support our verification opinion

5. Findings and corrections

If any errors, inconsistencies or non-conformities are identified, we provide a report outlining the required corrective actions. The shipping company must address these before verification can be completed.

6. Independent technical review

Once verification is complete, an independent reviewer—who has not participated in the verification—conducts a technical review to ensure the process meets all regulatory requirements.

7. Final verification

If no material misstatements or non-conformities remain, we issue:

  • Verification Report
  • Document of Compliance (DOC)
  • Required supporting deliverables

If material issues remain unresolved, a positive Verification Report cannot be issued until corrective actions have been completed.

8. Regulatory submission

Following issuance of the Verification Report, your company must complete the required submissions in THETIS, METS and the Union Registry, where applicable, to demonstrate regulatory compliance.

Material Misstatement: means a misstatement that, in the opinion of the verifier, individually or when taken together with other misstatements, exceeds the materiality level or could otherwise have an impact on the total reported emissions or other relevant information. If such a finding is left outstanding at the end of the verification, then the misstatement must be corrected or a positive Verification Report and Document of Compliance will not be possible.

Misstatement: means an omission, misrepresentation or error in the
reported data. If such a finding is outstanding at the end of the verification, a positive Verification Report and Document of Compliance will be possible. Where identified, they should be corrected.

Non-conformity means:

  1. For the purpose of assessing a monitoring plan, that the plan does
    not fulfil requirements of the MRV Regulation
  2. For the purpose of verifying an emissions report, that the GHG emissions and other relevant information are not reported in line with the monitoring methodology described in a monitoring plan that an accredited verifier has assessed as satisfactory.

Non-conformities identified during the assessment of Monitoring Plan requirements must be addressed accordingly. If such a finding is outstanding at the end of the verification, a positive Verification Report and Document of Compliance willbe possible. Where identified, they should be corrected.

Recommendation for improvement: A recommendation for improvement is an impartial suggestion from the verifier to improve the operator’s performance in monitoring and reporting emissions. Recommendations for improvement can be made in relation to uncorrected misstatements and non-conformities not leading to material misstatements, but the verifier shall not jeopardise its impartiality by giving advice or developing parts of the monitoring and reporting process pursuant to the criteria.

Site visits are required for the purposes of FUEL EU, EU MRV & EU ETS. Site visits can be virtual or physical.

A virtual site visit is in principle a video conference accompanied by any further written/electronic communication. For that purpose the verifier will request the shipping company to provide all necessary information electronically. If during the virtual site visit the verifier does not obtain all necessary evidence for positively concluding on the emissions report, the verifier has to consider to carry out a physical site visit. 

The verifier shall not carry out a virtual site visit if no physical site visit has been carried out in the three reporting periods immediately preceding the current reporting period71. This means in practice that a physical site visit shall take place at least once over a period of four consecutive years, irrespective of whether verification in previous years was carried out by the same verifier or a different one, and except if circumstances under point (d) apply. Carrying out a virtual site visit is not considered as a waiving of site visit.

Monitoring Plan assessment

We carry out this stage to assess conformity of every ship Monitoring Plan to requirements defined in the applicable regulatory requirements. Your organisation will be required to provide at least the information defined within the Evidence Pack Requirements document provided in Emissions Verifier. If we agree that the process may be more efficient with a short visit to your head office, we will start with an opening meeting, at which the Verifier will explain the verification approach to your management team and be introduced to the company. The Verifier will also agree a plan for the visit with your company. We will review the key information provided to establish conformity against applicable regulatory requirements. 

Verification of data and information

Our verification process follows EU regulatory requirements to ensure your emissions reports are accurate, complete and compliant.

1. Strategic review

We begin by reviewing your ship's activities and Monitoring Plan (MP) to understand the scope and complexity of the verification. If the Monitoring Plan is incomplete, outdated or awaiting approval from the Administering Authority (AA), the verification process is paused until this has been resolved.

2. Evidence review

You provide the required documentation and evidence. We review the information against the Evidence Pack Requirements and, where necessary, request additional evidence to confirm completeness, accuracy and compliance.

3. Risk assessment

Our verifier assesses potential risks within your monitoring and reporting processes, including data calculations, controls and any methods used to manage data gaps. This forms the basis of the verification plan.

4. Verification activities

We verify that your monitoring system is implemented as described in the Monitoring Plan by:

  • Reviewing internal controls and procedures
  • Testing emissions data using a risk-based sampling approach
  • Checking calculations and data gap methodologies
  • Collecting sufficient evidence to support our verification opinion

5. Findings and corrections

If any errors, inconsistencies or non-conformities are identified, we provide a report outlining the required corrective actions. The shipping company must address these before verification can be completed.

6. Independent technical review

Once verification is complete, an independent reviewer—who has not participated in the verification—conducts a technical review to ensure the process meets all regulatory requirements.

7. Final verification

If no material misstatements or non-conformities remain, we issue:

  • Verification Report
  • Document of Compliance (DOC)
  • Required supporting deliverables

If material issues remain unresolved, a positive Verification Report cannot be issued until corrective actions have been completed.

8. Regulatory submission

Following issuance of the Verification Report, your company must complete the required submissions in THETIS, METS and the Union Registry, where applicable, to demonstrate regulatory compliance.

Findings/Gradings

Material Misstatement: means a misstatement that, in the opinion of the verifier, individually or when taken together with other misstatements, exceeds the materiality level or could otherwise have an impact on the total reported emissions or other relevant information. If such a finding is left outstanding at the end of the verification, then the misstatement must be corrected or a positive Verification Report and Document of Compliance will not be possible.

Misstatement: means an omission, misrepresentation or error in the
reported data. If such a finding is outstanding at the end of the verification, a positive Verification Report and Document of Compliance will be possible. Where identified, they should be corrected.

Non-conformity means:

  1. For the purpose of assessing a monitoring plan, that the plan does
    not fulfil requirements of the MRV Regulation
  2. For the purpose of verifying an emissions report, that the GHG emissions and other relevant information are not reported in line with the monitoring methodology described in a monitoring plan that an accredited verifier has assessed as satisfactory.

Non-conformities identified during the assessment of Monitoring Plan requirements must be addressed accordingly. If such a finding is outstanding at the end of the verification, a positive Verification Report and Document of Compliance willbe possible. Where identified, they should be corrected.

Recommendation for improvement: A recommendation for improvement is an impartial suggestion from the verifier to improve the operator’s performance in monitoring and reporting emissions. Recommendations for improvement can be made in relation to uncorrected misstatements and non-conformities not leading to material misstatements, but the verifier shall not jeopardise its impartiality by giving advice or developing parts of the monitoring and reporting process pursuant to the criteria.

Site visits

Site visits are required for the purposes of FUEL EU, EU MRV & EU ETS. Site visits can be virtual or physical.

A virtual site visit is in principle a video conference accompanied by any further written/electronic communication. For that purpose the verifier will request the shipping company to provide all necessary information electronically. If during the virtual site visit the verifier does not obtain all necessary evidence for positively concluding on the emissions report, the verifier has to consider to carry out a physical site visit. 

The verifier shall not carry out a virtual site visit if no physical site visit has been carried out in the three reporting periods immediately preceding the current reporting period71. This means in practice that a physical site visit shall take place at least once over a period of four consecutive years, irrespective of whether verification in previous years was carried out by the same verifier or a different one, and except if circumstances under point (d) apply. Carrying out a virtual site visit is not considered as a waiving of site visit.

Confidentiality, Impartiality, Complaints & Appeals

This section gives guidance on how to raise a complaint or issue an appeal to Lloyd’s Register with regards our EU MRV/ FUEL EU/UK ETS/EU ETS verification services and how these are handled by LR. 

Complaints are expressions of dissatisfaction whether justified or not, which may arise from clients or third parties concerning certified clients. Complaints may concern either technical issues such as audit delivery, recommendation outcome, raise of findings etc. or non-technical issues such as audit planning, invoicing etc. 

Appeals concern objections against LR decisions on complaints, verification outcomes etc.

  • Confidentiality
  • Impartiality
  • Complaints & Appeals

As defined by our contract, we will not pass on any of the data or information we gather about your organization (including the contents of your Emissions Reports) to any other person or organisation without your permission (except as required by the accreditation bodies, or Regulation requirements).

This confidentiality will be maintained during the term of and following any termination of our Agreement, with the exception of information which was in our possession before disclosure by your organisation, information which is in the public domain or that which is made available to us from an independent source.

LR has established a Conflict of Interest, Independence, Impartiality and Integrity Policy and procedure. It is essential to the success of our organisation that stakeholders can be confident that we provide these services with impartiality and integrity.

This means we must identify, avoid or appropriately manage, any situation in which our ability to make an independent and impartial judgement or decision may be put at risk by a conflict of interest. We have therefore determined, documented and applied controls for managing conflict of interest. LR encourages clients to raise any queries, concerns they may have regarding the impartiality of our services. 

At various stages during assessment, verification activities, disputes over findings occasionally arise. All Complaints and appeals will be managed according to the LR Group policy and procedure. To formally initiate the complaints process, issue an appeal or leave any feedback either positive or negative use the online Feedback form alternatively, write to your local LR office.

Upon receipt of feedback, you will receive an acknowledgment within 24 hours with an expected resolution date. Complaints and appeals will be managed by LR in a confidential and impartial manner. The decision resolving the complaint or appeal shall be made by, or reviewed and approved by, personnel not involved in the activities related to the complaint or appeal.

When we receive negative feedback, an investigation is undertaken, the outcome of which we will communicate to you. Where the response does not resolve the issue or your dissatisfaction, you may request further appeal review with relevant justification.

We shall take any subsequent action needed to resolve the complaint or appeal and shall give you formal notice of the end of the appeal.

 

Confidentiality

As defined by our contract, we will not pass on any of the data or information we gather about your organization (including the contents of your Emissions Reports) to any other person or organisation without your permission (except as required by the accreditation bodies, or Regulation requirements).

This confidentiality will be maintained during the term of and following any termination of our Agreement, with the exception of information which was in our possession before disclosure by your organisation, information which is in the public domain or that which is made available to us from an independent source.

Impartiality

LR has established a Conflict of Interest, Independence, Impartiality and Integrity Policy and procedure. It is essential to the success of our organisation that stakeholders can be confident that we provide these services with impartiality and integrity.

This means we must identify, avoid or appropriately manage, any situation in which our ability to make an independent and impartial judgement or decision may be put at risk by a conflict of interest. We have therefore determined, documented and applied controls for managing conflict of interest. LR encourages clients to raise any queries, concerns they may have regarding the impartiality of our services. 

Complaints & Appeals

At various stages during assessment, verification activities, disputes over findings occasionally arise. All Complaints and appeals will be managed according to the LR Group policy and procedure. To formally initiate the complaints process, issue an appeal or leave any feedback either positive or negative use the online Feedback form alternatively, write to your local LR office.

Upon receipt of feedback, you will receive an acknowledgment within 24 hours with an expected resolution date. Complaints and appeals will be managed by LR in a confidential and impartial manner. The decision resolving the complaint or appeal shall be made by, or reviewed and approved by, personnel not involved in the activities related to the complaint or appeal.

When we receive negative feedback, an investigation is undertaken, the outcome of which we will communicate to you. Where the response does not resolve the issue or your dissatisfaction, you may request further appeal review with relevant justification.

We shall take any subsequent action needed to resolve the complaint or appeal and shall give you formal notice of the end of the appeal.