EU ETS2 Verification

EU ETS2 verification for fuel suppliers

EU ETS2 makes fuel suppliers accountable for CO₂ emissions in buildings, road transport, and small industries. If you place fuel on the EU market, you are a regulated entity. Your emissions data must be monitored, reported, and independently verified every year – and the first deadline is 30 April 2026*.

 

*For entities reporting to France, the administering authority (DGEC) has exceptionally agreed to postpone the deadline for submission of verified ETS 2 reports by one month, to 1 June. This extension applies to the first reporting year only. 

ETS2 timeline: Key dates you cannot miss 

Date Milestone
1 Jan 2025 Greenhouse gas emissions permit and approved monitoring plan required
1 Jan 2025 Monitoring of annual emissions begins
30 Apr 2026 First verified emissions report due (covering 2025 data)
2027 ETS2 becomes fully operational – allowances auctioned, trading begins
31 May 2028 First allowance surrender deadline (covering 2027 verified emissions)
2030 Emissions cap tightens – 42% reduction target vs. 2005 levels

Why Normec Verifavia?

Normec Verifavia has operated under accredited EU ETS verification standards across aviation and maritime for over a decade. The framework, the regulatory rigour, the verification programme, all established, all applied now to ETS2.

  • Fast turnaround when it matters most: With the first verified report due April 2026, time is critical. Our streamlined verification process is designed for speed without compromising accuracy. We engage quickly and deliver on time.
  • Proven EU ETS verification expertise: Over 10 years verifying emissions under EU ETS. We know the Monitoring, Reporting and Verification framework inside out. We have verified hundreds of entities across aviation and maritime sectors.
  • Full-cycle MRV support: From readiness assessment to post-verification assistance, we guide you through the entire compliance cycle. One partner, no gaps.
  • Established verification programme: For the EU ETS 2, we have established a Verification Program (reference: EU ETS 2 Verification Program v.1 – Feb 2026), which is shared with our clients prior to the engagement phase.
  • Strict auditor impartiality: We verify. We do not consult. When we issue a verification statement, it carries the independence that regulators and your stakeholders expect. 

Accreditation status: Normec Verifavia is accredited under ISO/IEC 17029:2019 to perform EU ETS2 verification activities in accordance with applicable accreditation requirements.

Does EU ETS2 apply to you?

If your company places fuel on the EU market for combustion in buildings, road transport, or small industrial installations, you are a regulated entity under EU ETS2. 

Fuel importers & distributors

You import or distribute petrol, diesel, heating oil, natural gas, LPG, coal, or coke for the EU market. You must hold a GHG emissions permit, maintain an approved monitoring plan, and submit verified annual emissions reports.

Energy providers serving non-ETS installations

You supply fuels for combustion in buildings, small industries, or road transport that fall outside the original EU ETS scope. You are now brought into the carbon pricing framework through ETS2.

Blenders & companies releasing fuels for consumption

You blend, process, or release fuels for consumption in the EU. If you are defined as a debtor of the energy tax under national law, you are a regulated entity under ETS2.

What happens if you do not comply?

EU ETS2 shifts regulatory responsibility upstream to fuel suppliers. Underreporting, late submission, or failure to surrender allowances exposes you to significant financial and reputational risk.

  • €100 per tonne of CO for each tonne of emissions without a surrendered allowance – adjusted for inflation. Plus the obligation to purchase and surrender the missing allowances on top. 
  • Public naming of non-compliant entities. 
  • Additional national penalties as defined by each Member State for other forms of non-compliance.

The penalty structure is deliberate. The EU wants accurate data. If you cannot demonstrate compliance, the financial consequences are immediate and public. 

Explore further

Gain exclusive access to our recorded ETS2 webinar session held on 26th November 2025, where Normec Verifavia experts explain the key requirements, scope, and next steps for operators and regulated entities.

Complete the form below to receive temporary access to the webinar recording for a period of one week.

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Contact our experts directly

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Our service covers the full verification cycle as defined by the Accreditation and Verification Regulation (AVR).

What we offer: EU ETS2 verification services

  1. Pre-Engagement

    Collecting client informationincluding locations, scope and objectives, relevant data and reports and any other required information. Reviewing of the received information for engagement decision. 

  2. Engagement

    Establishing a contract that defines the scope, objectives, timeline, and responsibilities. 

  3. Planning

    Developing a detailed plan that outlines methodologies, tools, and resources needed for the assignment and selecting a competent team.  

  4. Execution

    Execution of verification activities to evaluate data accuracy, traceability, and compliance with regulatory requirements. 

  5. Review

    Conduct an independent internal technical review of the verification findings and of the compliance with the verification process to ensure accuracy and completeness before finalizing the report.  

  6. Reporting

    Issuance of a formal verification statement in accordance with AVR Article 67 for submission to the Competent Authority. 

  7. Facts Discovered after the Opinion statement

    Managing any significant information that comes to light after the verification opinion has been issued. If such information could impact the verification results, it may necessitate a re-verification or correction in the verification statement 

  8. Records

    Keeping detailed records of all documentation and communication throughout the verification process for 10 years.  

Find answers to the most commonly asked questions

What is EU ETS2?

EU ETS2 is a new, separate emissions trading system established under the 2023 revision of the EU ETS Directive. It targets CO emissions from fuels used in buildings, road transport, and small industrial sectors. Unlike the original EU ETS, which regulates large industrial emitters directly, ETS2 regulates fuel suppliers upstream  the companies that put fuel on the EU market. 

How does ETS2 differ from ETS1?

ETS1 covers large industrial installations and power plants directly. ETS2 targets upstream fuel suppliers who place fuels on the EU market for buildings, road transport, and small industries. The regulated entity changes from the end-user to the fuel supplier. The two systems operate independently with separate allowance pools. 

Who must comply with EU ETS2?

Any entity that places fuel on the EU market for combustion in buildings, road transport, or small industrial installations. This includes fuel importers, distributors, blenders, wholesalers, and energy providers serving non-ETS installations. In practice, it is the entity defined as the energy tax debtor under national law.

When is the first verified emissions report due?

The first report covering 2025 emissions must be submitted by 30 April 2026. This is the first year requiring independent verification by an accredited verifier. Prior to 2026, reporting could be unverified. 

When do I need to surrender allowances?

Allowance surrender begins from 31 May 2028, based on 2027 verified emissions. The system becomes fully operational in 2027, with allowances distributed exclusively via auction. During 2027, a 30% higher volume of allowances will be auctioned to provide market liquidity. For the first three years, if the allowance price exceeds €45 (in 2020 prices, adjusted for inflation), additional allowances may be released from the market stability reserve. 

What are the penalties for non-compliance of ETS2?

Regulated entities face an excess emissions penalty of €100 per tonne of CO for each tonne without a surrendered allowance, adjusted for inflation. On top of that, you must still purchase and surrender the missing allowances. Non-compliant entities are publicly named. Member States may impose additional national penalties. 

What fuels are covered by ETS2?

The main fuels covered include petrol, diesel (gasoil), heating oil, natural gas, liquefied petroleum gas (LPG), coal, and coke. Essentially any fossil fuel used for combustion in the covered sectors. Agricultural use, military, private non-commercial aviation and shipping, and certain other sector-specific uses are excluded.

Can the start of ETS2 be delayed?

The Directive includes a provision that if energy prices are exceptionally high in 2026, the full operational start of ETS2 could be postponed to 2028. However, the monitoring, reporting, and verification obligations for 2025 and 2026 data remain in force regardless. 

Can Normec Verifavia verify my ETS2 data now?

Normec Verifavia is accredited for EU ETS2 verification activities in accordance with ISO/IEC 17029:2019 and applicable accreditation requirements. Normec Verifavia is fully operational and already engaging with regulated entities under its established EU ETS verification programme (v.1 – Feb 2026), ensuring a transparent and structured verification process from day one.