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FAQ

Question 51.1 Annual witness for EU ETS

Background:

The AVR in art. 50 states that :

1. The national accreditation body shall carry out an annual surveillance of each verifier to which it has issued an accreditation certificate.

The surveillance shall at least comprise the following:

(a) a visit to the premises of the verifier with a view to carrying out the activities referred to Article 48(1)(b);

(b) witnessing the performance and competence of a representative number of the verifier’s staff in accordance with Article 48(1)(c).

Question:

Does that mean that the NAB has to perform at least one witness every year?

March 2026

YES. According to Art. 50 of the AVR, at least one witnessing assessment shall have to be carried out in the context of the annual surveillance. The AVR as currently stated does not allow for any derogation in this respect, nor does any EC Guidance document provide for a different reading of this requirement of the AVR such that it can be fulfilled by alternative means i.e. performing lesser witnessing assessments within the accreditation cycle while ensuring coverage of a representative sample of the scope of accreditation and verifier’s staff.