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EU MRV GAP-Analysis

A GAP-Analysis audit assesses the ship operator for EU MRV readiness. The audit highlights any weakness in processes and systems, and identifies any gaps between what the ship operator has in place and the requirements of the Regulation.

The benefit of this audit is that, if carried out early, it can identify any compliance and system design issues, enabling correction by the ship operator in a timely manner.

Important note #1: as independent and impartial verifiers, under no circumstances can we offer technical assistance or consultancy services to shipping companies, as this is expressly prohibited by accreditation regulations and standards. A GAP-Analysis does not constitute consulting or technical assistance, and its conclusions do not include any recommendations.

Important note #2: the conduction of a GAP-Analysis does not imply that the legal assessment audit that will follow will be simpler, easier, faster or less expensive. According to the accreditation rules, the legal assessment team must be different from the team conducting the GAP-Analysis audit.


To ensure that companies are MRV-ready, Verifavia Shipping is conducting GAP-Analysis audits for ship operators across the world. Conducting an audit of your company's procedures and data against the requirements of the Regulation will enable you to accurately identify any gaps in your ability to achieve compliance ahead of time.

If the audit finds your company in compliance with the Regulation, we will issue you with an 'MRV-Ready certificate', providing genuine reassurance that your company is geared up for compliance.

Advantages of GAP-Analysis for ship operators


Compliance Review

Verifavia assesses the existing data collection and transformation procedures and systems against the requirements of the EU MRV Regulation to identify any potential issues and non-compliance.
We also review the ship operator's operational documentation as well as an example of a monitoring plan (if it exists) to determine if they contain sufficient details for the implementation of the allowed fuel consumption monitoring methods and other key procedures.
In addition, the following elements are considered:
  • The nature, scale and complexity of the ship operator's operations and MRV processes
  • The complexity of IT systems used to handle fuel data and other information
  • The existence of an environmental or a quality management system
  • The existence of quality control and assurance processes related to data monitoring
  • The organisational structure of MRV and how it is integrated into the business
  • The availability of information and data in terms of access, completeness and accuracy
The compliance review is based on interviews, document review, observation of systems and processes, and corroboration of information.

Data Analysis

Verifavia conducts a thorough analysis of fuel and activity data of at least one representative ship to identify data gaps, perform plausibility checks and cross-check against ship-tracking data.
The data analysis allows the identification of potential problems with the data or with the calculation methods so that the operator can undertake corrective actions if necessary.
Verifavia also performs audit trails on selected data to check the robustness of the data collection and transformation processes.
The data analysis considers not only the fuel and emissions data but also the other activity data such as cargo carried, time at sea and distance sailed.


Throughout the audit, Verifavia maintains an Issues Log that lists all issues arising (non-conformities, misstatements and observations).
Finally, we draft a GAP-Analysis audit report that identifies any gaps between the ship operator's MRV processes and the legal requirements, assessing the readiness of the company for the Regulation. This enables the company to address any issues and be confident that it has the systems and processes in place to achieve compliance ahead of time.

The GAP-Analysis audit in three phases


MRV-Ready Certificate

In case there are no gaps between the ship operator's procedures and the requirements of the EU MRV Regulation, and if the ship operator is able to produce a Monitoring Plan for at least one representative ship that is in compliance with the Regulation, Verifavia can issue an MRV-Ready certificate.


Regulations & Criteria

Verifavia conducts the GAP-Analysis audit according to the following regulations and criteria:
  • Regulation 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport ('EU MRV Regulation') amended by the Delegated Regulation (EU) 2016/2071 as regards the methods for monitoring carbon dioxide emissions and the rules for monitoring other relevant information
  • ISO 14065:2013 on the Requirements for greenhouse gas validation and verification bodies for use in accreditation
  • Commission Implementing Regulation (EU) 2016/1928 on determination of cargo carried for categories of ships other than passenger, ro-ro and container ships pursuant to EU MRV Regulation
  • Commission Implementing Regulation (EU) 2016/1927 on templates for monitoring plans, emissions reports and documents of compliance pursuant to the EU MRV Regulation
  • Commission Delegated Regulation (EU) 2016/2072 on the verification activities and accreditation of verifiers pursuant to the EU MRV Regulation
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