Compliance with the EU Emissions Trading System · Directive 2003/87/EC
Your EU ETS compliance measured by theme, and costed into an action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Compliance with the EU Emissions Trading System · Directive 2003/87/EC
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Directive 2003/87/EC, as amended by Directive (EU) 2023/959 (EU ETS phase 4) assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, one level, a higher level, and the action that links the two, that turns a finding into a trajectory.
Is the monitoring plan kept up to date at the pace of installation changes?
- N1
The approved monitoring plan has not been reviewed since submission. Equipment changes are not cross-checked against its content.
- N2
Significant changes are notified, but the review happens at reporting time and gaps are found by the verifier.
- N3
A periodic plan review is scheduled. Significant and non-significant changes are logged, documented and notified according to their nature.
- N4
Any project affecting a flow, meter or fuel triggers an impact analysis on the plan before commissioning, with traceable validation.
- N5
The process is measured through indicators, update lead time and number of gaps found at verification, and revised based on lessons learned across the portfolio.
Action to move from L2 to L3
Put a monitoring plan review on the agenda of the first-quarter HSE meeting, with a change log kept by the ETS lead and a mandatory "monitoring plan impact" field in the works management process.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Directive 2003/87/EC has governed the EU ETS since 2005. An operator of a covered installation holds a permit to emit greenhouse gases, applies a monitoring plan approved by the competent authority, reports annual emissions under Implementing Regulation (EU) 2018/2066, has that report verified by an accredited verifier under Regulation (EU) 2018/2067, then surrenders a number of allowances equal to its verified emissions. Free allocation, where it applies, depends on reported activity levels and product benchmarks.
In practice, the difficulty is not understanding the mechanism, it is keeping it aligned over time on industrial sites that keep changing. Does the monitoring plan still reflect the actual flows after a meter is replaced or a new line comes online? Are non-significant changes tracked and notified, or discovered by the verifier? Who actually holds the activity data, emission factors and laboratory analyses, and in what format are they kept? Is the surrender timeline actively managed, or dealt with at the last minute.
Phase 4 has moved several levers. Directive (EU) 2023/959 extends the scope to maritime transport, creates a separate system for buildings and road transport, and tightens the cap trajectory. One confusion comes up often: the EU ETS and the carbon border adjustment mechanism do not replace one another, they work together, and the quality of the emissions data produced for the ETS shapes the quality of CBAM declarations. Another point: ETS reporting does not cover the scope of a corporate carbon footprint.
A compliance audit ends with a binary finding: the report is verified without qualification, or it contains misstatements and non-conformities. The maturity assessment asks a different question: at what level of control do monitoring, data management, allowance governance and verification readiness currently sit, and what specific action moves each theme up to the next level. The two complement each other: the assessment prepares and prioritises, the verification validates.
In Datamensio, the framework is ready to use and stays yours. The AI adjusts the themes, questions and levels to your sector, extraction, cement, metallurgy or combustion, or builds a variant from your monitoring plan and internal procedures.
Reference standard: Directive 2003/87/EC, as amended by Directive (EU) 2023/959 (EU ETS phase 4)
The themes assessed
Scope and permit to emit
Identification of installations and activities covered by Annex I, content and currency of the permit, management of capacity thresholds, cases of exclusions and small emitters.
Monitoring plan
Approval by the competent authority, description of sources and flows, methodology tiers used, justification of derogations, updates following significant or non-significant changes.
Collection and quality of activity data
Measuring instruments, uncertainties, calibration and maintenance plan, sampling and laboratory analyses, handling of missing data and substitute values.
Emissions calculation
Emission and oxidation factors, biomass fractions, consistency of units and calorific values, calculation checks, management of transferred CO2 flows.
Internal control and audit trail
Written procedures, segregation of duties, data review before submission, retention of supporting evidence, traceability of corrections and versions.
Annual report and verification
Meeting reporting deadlines, preparing the accredited verifier’s visit, handling misstatements and recommendations, follow-up on non-conformities from previous years.
Free allocation and activity levels
Allocation request, annual reporting of activity levels, applicable product benchmarks, adjustments linked to changes in capacity and production.
Allowance and registry management
Union Registry accounts, authorisations and authorised representatives, allowance position, purchasing and surrender strategy, meeting the surrender deadline.
Governance, roles and competencies
Appointment of an ETS lead, coordination between site and head office, training of contributors, continuity in case of absence or departure.
Emissions reduction and regulatory alignment
Decarbonisation trajectory, consistency with energy efficiency and the environmental management system, data reused for CBAM and sustainability reporting.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does this assessment replace verification by an accredited body?
No. The annual emissions report must be verified by an accredited verifier under Regulation (EU) 2018/2067. Datamensio measures the maturity of your set-up and prepares you for that verification, it does not issue any certificate.
How is this different from an EU ETS compliance audit?
An audit records the presence or absence of a requirement and concludes with a non-conformity or a misstatement. The assessment places each theme on a five-level maturity scale and identifies the action that moves it up a level. The first validates, the second builds the trajectory.
How long does the assessment take?
The short version takes 20 to 30 minutes for an environment manager to complete. The full version, run collaboratively with the site, the laboratory and finance for the allowance part, generally takes one to two weeks, most of the time spent gathering supporting documents.
Can the framework be adapted to our activity?
Yes. You can change the questions, levels and themes, or start from your own documents. The AI adapts the framework to the activity covered, ore extraction and processing, combustion, lime or metallurgy, and refines the wording of the levels according to the CMMI method.
How does this fit with CBAM?
Both mechanisms rely on the same type of emissions data. A solid monitoring set-up under the ETS provides a reusable basis for CBAM declarations. The cross-cutting roadmap allows both assessments to be cross-referenced without duplicating actions.
Can several installations within the same group be compared?
Yes. The same framework is rolled out to each site, and scores by theme can be compared across business units and over time. The AI groups common gaps into a consolidated group-level roadmap.
Does answering require technical metrology expertise?
The questions cover management and control practices, not instrument configuration. Some do require input from a metrologist or the laboratory: the collaborative mode allows these questions to be assigned to the right person.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.