The operator or aircraft operator must establish, document, implement and maintain an effective control system to ensure that the annual emission report and, where applicable, the tonne-kilometre report resulting from data flow activities does not contain misstatements and is in conformity with the monitoring plan and provisions of the M&R Regulation.


Guidance Document No. 1 clarifies that “risk” is a parameter which takes into account both, the probability of an incident and its impact. In terms if emission monitoring, the risk refers to the probability of a misstatement (omission, misrepresentation or error) being made, and its impact in terms of annual emissions figure.


As the Guidance Document No. 1 also indicates, when the operator carries out a risk assessment, he analyses for each point in the data flow needed for the whole installation’s emission monitoring, whether there would be a risk of misstatements. Usually this risk is expressed by qualitative parameters (low, medium, high) rather than by trying to assign exact figures. He furthermore assesses potential reasons for misstatements (such as paper copies being transported from one department to another, where delays may occur, or copy & paste errors may be introduced), and identifies which measures might reduce the found risks, e.g. sending data electronically and storing a paper copy in the first department; search for duplicates or data gaps in spreadsheets, control check by an independent person (“four eyes principle”).


Measures identified to reduce risks are implemented. The risk assessment is then re-evaluated with the new (reduced) risks, until the operator considers that the remaining risks are sufficiently low for being able to produce an annual emissions report which is free from material misstatement(s).


It is noteworthy that under the new M&R Regulation the operator or aircraft operator is under obligation to assign responsible persons for all data flow activities and for all control activities in a way to segregate conflicting duties. In the absence of other control activities, it must ensure for all data flow activities commen­surate with the identified inherent risks that all relevant information and data should be confirmed by at least one person who has not been involved in the determination and recording of that information or data.

The operator or aircraft operator must also manage the necessary competences for the responsibilities involved, including the appropriate assignment of responsibilities, training, and performance reviews.


The control system should consist of the following:

(a) an operator’s or aircraft operator’s assessment of inherent risks and control risks;

(b) written procedures related to control activities that are to mitigate the risks identified.


Written procedures related to control activities as referred above must at least include:

(a) quality assurance of the measurement equipment;

(b) quality assurance of the information technology system used for data flow activities, including process control computer technology;

(c) segregation of duties in the data flow activities and control activities as well as management of necessary competencies;

(d) internal reviews and validation of data;

(e) corrections and corrective action;

(f) control of out-sourced processes;

(g) keeping records and documentation including the management of document versions.


The operator or aircraft operator is under the obligation to monitor the effectiveness of the control system, including by carrying out internal reviews and taking into account the findings of the verifier during the verification of annual emission reports and, where applicable, tonne-kilometre data reports.


Whenever the control system is found to be ineffective or not commensurate with the risks identified, the operator or aircraft operator should seek to improve the control system and update the monitoring plan or the underlying written procedures for data flow activities, risk assessments and control activities as appropriate.


Referring to the point (d) above and based on the inherent risks and control risks identified in the risk assessment the operator or aircraft operator is required to review and validate data resulting from the data flow activities.


Such review and validation of the data should at least include:

(a) a check as to whether the data are complete;

(b) a comparison of the data that the operator or aircraft operator has obtained, monitored and reported over several years;

(c) a comparison of data and values resulting from different operational data collection systems, including the following comparisons, where applicable:

(i) a comparison of fuel or material purchasing data with data on stock changes and data on consumption for the applicable source streams;

(ii) a comparison of calculation factors that have been determined by analysis, calculated or obtained from the supplier of the fuel or material, with national or international reference factors of comparable fuels or materials;

(iii) a comparison of emissions obtained from measurement-based methodologies and the results of the corroborating calculation of annual emissions of each considered greenhouse gas for the same emission sources and source streams;

(iv) a comparison of aggregated data and raw data.


Criteria for rejecting data as part of the review and validation should be known in advance and laid down in the docu­mentation of the relevant written procedures.


Article 47(3) of the M&R Regulation exempts operators of installations with low emissions from submitting a risk analysis when submitting the monitoring plan for approval by the competent authority. However, operators will still find it useful to carry out a risk assessment for their own purposes.


The control activities are laid down in written procedures and referenced in the monitoring plan. The results of the risk assessment (taking into account the control activities) are submitted as supporting documentation to the competent authority when approval of the monitoring plan is requested by the operator.


Guidance document of 17 October 2012 relating to control system is available here

(the source of the Guidance document:



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