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FuelEU report and partial FuelEU report template
1. Companies shall use an electronic template of the FuelEU report based on the template included in Annex II, and submit the information in FuelEU Database. 2. Verifiers shall record a version of the FuelEU report in FuelEU Database after the verification, based on the information submitted by the company.
Information to be provided by companies
1. Before the start of the verification of the FuelEU report and partial FuelEU report, companies shall provide the verifier with at least the following supporting information: (a) a list of voyages and port calls carried out by the ship in question during the reporting period or, as far as partial FuelEU reports are concerned, the period during which the ship was under the responsibility of the company, pursuant to Article 15 of Regulation (EU) 2023/1805; (b) where data gaps occurred during the reporting period: — the number of voyages for which data gaps occurred, and the circumstances and reasons for data gaps that apply; — the estimation method for surrogate data applied; — the amount of energy calculated based on surrogate data; (c) a copy of the FuelEU report from the previous year, where the same verifier did not carry out the verification for that report; (d) a copy of the monitoring plan or plans applied, including evidence of the conclusions from the assessment carried out by an accredited verifier, where appropriate. 2. Once the verifier has identified the specific documents or sections of documents deemed relevant for the purpose of its verification, companies shall also provide the following supporting information: (a) copies of the ship’s official logbook and of the oil record book, where it is separate; (b) copies of bunkering documents as complemented pursuant to Annex I to Regulation (EU) 2023/1805; (c) copies of any relevant certificates concerning fuels, including the proof of sustainability document of non-fossil fuels issued in the name of the fuel/bunker supplier (indicated in the ‘recipient’ field of the relevant sustainability certificate document); (d) copies of electricity delivery documents as complemented pursuant to Annex I to Regulation (EU) 2023/1805; (e) copies of relevant documents to provide information on distance travelled and time spent at sea for the ship’s voyages during the reporting period; (f) relevant ice charts or equivalent supporting documents, if the ship has requested to exclude emissions from sailing in ice conditions; (g) assumptions, references, emissions, reward factors and their data/information sources taken into consideration to produce the FuelEU report; (h) any other document relevant for the scope of the verification. 3. Additionally, and if applicable on the basis of the monitoring method applied, verifiers may ask the company to provide: (a) an overview of the IT landscape showing the data flow for the relevant ship; (b) evidence of the maintenance and accuracy or uncertainty of measurement equipment and flow meters, including calibration certificates; (c) an extract of fuel-consumption data from flow meters; (d) an extract of consumption data from other meters of sources of energy; (e) copies of evidence of fuel-tank meter readings; (f) an extract of activity data from direct emissions measurement systems; (g) any other information relevant to the verification of the FuelEU report and partial FuelEU report. 4. In the event of a change of company, the companies involved shall exercise due diligence to provide the verifier, upon its request, with the supporting documents or information relating to the voyages performed under their respective responsibilities. 5. Companies shall retain the information referred to in paragraphs 1, 2 and 3 of this Article for at least 5 years pursuant to Article 7(4) of Regulation (EU) 2023/1805.
Strategic analysis
1. At the beginning of the verification, the verifier shall assess the likely nature, scale and complexity of the verification tasks by carrying out a strategic analysis of all activities relevant to the ship. 2. For the purposes of understanding the activities carried out by the company, the verifier shall collect and review the information needed to assess that the verification team is sufficiently competent to: (i) carry out the verification; (ii) determine that the time allocation indicated in the contract has been set correctly; and (iii) ensure that it is able to conduct the necessary risk assessment. The information shall include at least: (a) the information referred to in Article 11(1) and (2); (b) the information obtained from the verification in previous years if the verifier is carrying out the verification for the same company. 3. When reviewing the information referred to in paragraph 2, the verifier shall at least assess the following aspects: (a) the ship’s engines and fuel types used as well as the number of voyages carried out by the ship in question during the reporting period; (b) the monitoring plan as assessed by the verifier; (c) the data-flow activities and the control system. 4. When carrying out the strategic analysis, the verifier shall verify the following: (a) whether the monitoring plan presented to it is the most recent version; (b) whether there have been any modifications to the monitoring plan during the reporting period as referred to in Article 9(2) of Regulation (EU) 2023/1805.
Risk analyses to be carried out by verifiers
1. In addition to the elements referred to in Article 13(1), (2) and (3) of Regulation (EU) 2023/1805, the verifier shall identify and analyse all of the following risks: (a) the inherent risks; (b) the control risks; (c) the detection risks. 2. When identifying and analysing the elements referred to paragraph 1, the verifier shall consider the findings of the strategic analysis referred to in Article 12. 3. When performing the risk analysis, the verifier shall consider areas of higher verification risk and at least the following areas: (a) voyage data; (b) fuel consumption; (c) emission factors. (d) amount of energy obtained/derived from substitute sources of energy; (e) aggregation of data in the FuelEU report. 4. When identifying and analysing the elements referred to in paragraph 3, the verifier shall consider the existence, completeness, accuracy, consistency, transparency and relevance of the information reported. 5. Where appropriate in the light of the information obtained in the course of the verification, the verifier shall revise the risk analyses and modify or repeat the verification activities to be performed.
Verification plan
The verifier shall draft a verification plan reflecting the information obtained and the risks identified during the risk assessment. The verification plan shall include at least: (a) a verification programme describing the nature and scope of the verification activities and the time and manner in which they are to be carried out; (b) a test plan setting out the scope and methods of testing the control activities as well as the procedures for control activities; (c) a data-sampling plan setting out the scope and methods of data sampling relating to data points underlying the fuel and electricity consumption or other relevant information in the FuelEU report and partial FuelEU report.
Verification activities concerning the FuelEU report and partial FuelEU report
1. The verifier shall implement the verification plan and, on the basis of the risk assessment, verify whether the monitoring and reporting systems, as described in the monitoring plan that has been assessed as satisfactory, exist in practice and are properly implemented. 2. For the purposes of paragraph 1, the verifier shall consider carrying out at least the following types of procedure: (a) enquiries with relevant staff; (b) document inspection; (c) observation and walkthrough procedures. 3. The verifier shall verify the following: (a) the data-flow activities and the systems used in the data-flow, including information technology systems; (b) whether the control activities are appropriately documented, implemented, maintained and effective to mitigate the inherent risks; (c) whether the procedures listed in the monitoring plan are effective to mitigate the inherent risks and control risks and whether the procedures are implemented, sufficiently documented and properly maintained. 4. For the purposes of paragraph 3, point (a), the verifier shall track the data-flow following the sequence and interaction of the data-flow activities from primary source data to the compilation of the FuelEU report and partial FuelEU report. 5. For the purposes of paragraph 3, points (b) and (c), the verifier may use sampling methods specific to a ship provided that, based on the risk assessment, sampling is justified.
Verification of reported data
1. The verifier shall verify the data reported in the FuelEU report or partial FuelEU report by the following means: (a) detailed testing, including by tracing them back to the primary data source; (b) cross-checking them with external data sources, including ship-tracking data; (c) performing reconciliations; (d) checking thresholds as regards appropriate data; and carrying out recalculations. 2. As part of the data verification referred to in paragraph 1, the verifier shall verify: (a) the attribution of fuel consumption and the use of other sources of energy to voyages and at berth; (b) the reported fuel-consumption data and related measurements and calculations; (c) the choice and the employment of emission factors; (d) the use of onshore power supply or the presence of exceptions recorded in the FuelEU database in accordance with Article 6(9) of Regulation (EU) 2023/1805; (e) the information required pursuant to Article 10(3) of Regulation (EU) 2023/1805; (f) the completeness of the list of fuel consumers as described in the monitoring plan; (g) the completeness of the data, including those on voyages reported pursuant to Regulation (EU) 2023/1805; (h) the consistency between reported aggregated data and data from relevant documentation or primary sources; (i) the consistency between aggregated fuel consumption and data on fuel purchased or otherwise supplied to the ship in question, where applicable; (j) the reliability and accuracy of the data.
Verification of methods applied for missing data
1. Where methods laid down in the monitoring plan as assessed by the verifier have been used to supplement missing data, the verifier shall verify whether the methods used were appropriate for the specific situation and whether they have been applied correctly. 2. Where the methods referred to in paragraph 1 were not assessed beforehand, the verifier shall verify whether the approach used by the company to supplement the missing data ensures that the emissions are not underestimated and that that approach does not lead to material misstatements.
Materiality level
For the purposes of verifying fuel and electricity consumption, and other relevant information on distance travelled and time spent at sea and at berth in the FuelEU report and partial FuelEU report, the materiality level shall be 5 % of the respective total reported for each item in the reporting period.
Site visits
1. The verifier shall carry out site visits in order to gain sufficient understanding of the company and the ship’s monitoring and reporting system as described in the monitoring plan. 2. The verifier shall determine the location or locations for the site visit on the basis of the results of the risk assessment and after taking into consideration the place where the critical mass of relevant data is stored, including electronic or hard copies of documents, and the place where data-flow activities and control activities are carried out. 3. On the basis of the outcome of a site visit to an onshore location, where it concludes that an onboard verification is needed to reduce the risk of material misstatements in the FuelEU report or partial FuelEU report, the verifier may decide to visit the ship. 4. The verifier shall also determine and communicate to the company the activities to be performed and the time needed for the site visit. 5. The company shall provide the verifier access to its sites, including to its relevant onshore locations and relevant ships. 6. The verifier may carry out a virtual site visit provided that, on the basis of the outcome of the risk assessment, one of the following conditions is fulfilled: (a) the verifier has sufficient understanding of the ship’s monitoring and reporting systems, including their existence, implementation and effective operation by the company; (b) the nature and level of complexity of the ship’s monitoring and reporting system are such that a physical site visit is not required; (c) the verifier is able to obtain and assess remotely all requisite information, including correct application of the methodology described in the monitoring plan and verification of the data reported in the FuelEU report or partial FuelEU report; (d) where serious, extraordinary and unforeseeable circumstances, outside the control of the company, prevent the verifier from carrying out a physical site visit and where those circumstances cannot, after using all reasonable efforts, be overcome. The verifier shall take measures to reduce the verification risk to an acceptable level to obtain reasonable assurance that the FuelEU report or partial FuelEU report is in conformity with Regulation (EU) 2023/1805. The decision to carry out a virtual site visit shall be made after determining that the conditions for carrying out a virtual site visit are met. The verifier shall inform without undue delay the company of the decision to carry out a virtual site visit and that the conditions for carrying out a virtual site visit are met. 7. With the exception of paragraph 6, point (d), the verifier shall not carry out a virtual site visit where no physical site visit has been carried out in the three reporting periods immediately preceding the current reporting period. The 3-year period shall only cover verifications of FuelEU reports performed for the company after the date of entry into force of this Regulation. 8. The decision to carry out a virtual site visit shall be made after determining that the conditions for carrying out a virtual site visit are met. The verifier shall inform the company thereof without undue delay. 9. The verifier may decide to waive a site visit or a virtual site visit as referred to in paragraphs 1 and 6 respectively provided that all conditions set out in paragraph 6, points (a), (b) and (c), are fulfilled. 10. A site visit and a virtual site visit as referred to in paragraphs 1 and 6 respectively shall not be waived in either of the following situations: (a) where the FuelEU report of a ship is verified for the first time by the verifier; (b) where a verifier has not carried out a site visit in two reporting periods immediately preceding the current reporting period. 11. The decision to waive a site visit shall be made after determining that the conditions for waiving site visits are met. The verifier shall inform the company thereof without undue delay. 12. Where the verifier carries out a virtual site visit pursuant to paragraph 6 or waives a site visit pursuant to paragraph 9, it shall provide justification for doing so in the internal verification documentation.
Addressing misstatements and non-conformities in the FuelEU report and partial FuelEU report
1. Where the verifier identifies misstatements or non-conformities in the course of the verification of the FuelEU report or partial FuelEU report, it shall inform the company thereof without undue delay and request relevant corrections within a reasonable deadline. 2. The company shall correct any communicated misstatements or non-conformities. 3. The verifier shall document in the internal verification documentation, marking them as resolved, all misstatements or non-conformities that have been corrected in the course of the verification. 4. Where the company does not correct the misstatements or non-conformities referred to in paragraph 1, the verifier shall, before issuing the verification report, ask the company to explain the main causes of the misstatements or non-conformities. 5. The verifier shall assess whether the uncorrected misstatements, individually or together with other misstatements, have an impact on the total reported emissions or other relevant information and whether that impact leads to material misstatements. 6. The verifier shall assess whether the uncorrected non-conformity, individually or together with other non-conformities, have an impact on the total reported emissions or other relevant information and whether that impact leads to material misstatements. 7. The verifier shall consider misstatements or non-conformities which, individually or together with other misstatements, are below the materiality level set in Article 18 as material misstatements where that is justified by their scale and nature or by the particular circumstances of their occurrence.
Conclusion of the verification of the FuelEU report and partial FuelEU report
To complete the verification of the FuelEU report and the partial FuelEU report, the verifier shall: (a) confirm that all verification activities have been carried out; (b) perform final analytical procedures on the aggregated data to ensure that they are free of material misstatements; (c) verify whether the information in the report satisfies the requirements of Regulation (EU) 2023/1805; (d) prepare the internal verification documentation and the draft report and submit them to the independent reviewer in accordance with Article 24; (e) authorise a person to authenticate the report on the basis of the conclusions reached by the independent reviewer and the evidence of the internal verification documentation, and notify the company thereof.
Recommendations for improvement
1. The verifier shall communicate to the company recommendations for improvement in relation to uncorrected misstatements and non-conformities not leading to material misstatements. 2. The verifier may communicate other recommendations for improvement that it finds relevant, in the light of the outcome of the verification activities. 3. When communicating recommendations to the company, the verifier shall remain impartial vis-à-vis the company, the ship and the monitoring and reporting system. It shall not jeopardise its impartiality by giving advice or elaborating on parts of the monitoring and reporting process pursuant to Regulation (EU) 2023/1805. 4. During a verification made following a year in which recommendations for improvement were made in a verification report pursuant to paragraphs 1 and 2, the verifier shall verify whether and how the company has implemented those recommendations for improvement. Where the company has not implemented those recommendations, the verifier shall assess whether that increases or may increase the risk of misstatements.
Verification report
1. On the basis of the information collected, the verifier shall issue a verification report to the company on each FuelEU report or partial FuelEU report subject to verification and record it in the FuelEU database. For that purpose, verifiers shall use the template for the verification set out in Annex II. 2. The verification report shall be accessible to the administering State in the FuelEU database. 3. The verification report shall state whether the FuelEU report or partial FuelEU report have been verified as satisfactory or not satisfactory. The FuelEU report or partial FuelEU report shall be verified as satisfactory only where they are free of material misstatements. The FuelEU report or partial FuelEU report shall not be verified as satisfactory if they contain material misstatements that were not corrected before the report was issued. 4. The verifier shall describe the misstatements and non-conformities in sufficient detail in the verification report, including the following aspects: (a) the size and nature of the misstatement or non-conformity; (b) why the misstatement has or has not a material effect; (c) to which element of the company’s report the misstatement refers, or to which element of the monitoring plan – or to which legal requirement – the non-conformity refers.
Independent review of the FuelEU report and partial FuelEU report
1. The independent reviewer shall review the internal verification documentation and the draft verification report to verify that the verification process has been conducted in accordance with this Regulation and that due professional care and judgment have been exercised. 2. The scope of the independent review shall encompass the complete verification process laid down in this Section and recorded in the internal verification documentation. 3. After the FuelEU report or the partial FuelEU report has been authenticated in accordance with Article 21, point (e), the verifier shall include the results of the independent review in the internal verification documentation.
Verification of partial FuelEU reports in the event of the transfer of a ship
1. In the event of the transfer of a ship from one company to another, the transferring company shall send to the verifier a partial FuelEU report for the time during which it had assumed the responsibility for the operation of the ship in accordance with Article 15(4) of Regulation (EU) 2023/1805. 2. The partial FuelEU report referred to in paragraph 1 shall be verified and recorded in the FuelEU database in accordance with Article 16 of Regulation (EU) 2023/1805 and the rules set out in this Section, by the verifier that performed verification activities for the ship under the transferring company.
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Source: EUR-Lex (Publications Office of the EU), © European Union, reuse permitted under Commission Decision 2011/833/EU.