Bodies Validating Carbon Emissions ISO 14065

» Purpose and Scope of ISO 14065:2020

• The standard specifies principles and requirements for bodies that perform validation and verification of environmental information statements.

• It applies to bodies validating or verifying:

  • greenhouse gas (GHG) statements and carbon inventories;

  • environmental footprints (e.g. carbon footprint of products);

  • environmental performance indicators;

  • environmental information in sustainability reports;

  • information linked to green bonds, climate finance and other financial instruments.

• ISO 14065 is a sector application of ISO/IEC 17029, adding environmental and climate-specific requirements to the generic framework for validation/verification bodies.

• Bodies can be first-, second- or third-party and may provide:

  • validation only;

  • verification only;

  • both validation and verification;

  • agreed-upon procedures (AUP) without issuing an opinion.

In short, ISO 14065 defines how bodies that sign off on carbon and environmental data must operate, so that their conclusions can be trusted by regulators, investors and other users.

» Key Terms and Concepts

ISO 14065 relies on a set of defined terms that structure environmental validation and verification:

• Environmental information – qualitative or quantitative information related to environmental conditions or environmental performance (e.g. GHG emissions and removals, environmental footprints, environmental reports).

• Environmental information statement – a declaration of environmental information, which may relate to a single point in time or a period, and must be clearly identifiable and suitable for evaluation against criteria.

• Environmental information programme – rules and procedures that govern how environmental information statements are prepared and, where applicable, validated or verified.

• Client – organisation or person requesting validation or verification.

• Responsible party – person(s) responsible for the environmental information statement and supporting information.

• Intended user – individual or organisation that relies on environmental information for decisions (for example regulators, investors, public authorities, customers).

• Terms linked to validation and verification activities include:

• Verification – evaluation of an environmental information statement based on historical data to determine whether it is materially correct and conforms to defined criteria.

• Validation – evaluation of the reasonableness of assumptions, methods and limitations supporting environmental information about future outcomes (e.g. projections).

• Level of assurance – degree of confidence intended users can place in the statement (commonly “limited” or “reasonable” assurance).

• Materiality / material misstatement – whether errors or omissions could influence decisions of intended users.

• Criteria – policies, procedures or requirements used as a reference against which the environmental information statement is assessed (e.g. ISO 14064-1/-2/-3, programme rules, laws, internal procedures).

• Validation/verification opinion – formal written declaration on the statement (unmodified, modified, adverse, or, in some cases, disclaimed). Annex A lists opinion types and links them to different programmes.

• Report of factual findings – documented output of an AUP engagement where no opinion and no assurance are provided; Annex C gives examples.

» Principles for Validation and Verification Bodies

The standard follows the general principles of ISO/IEC 17029 and adds two explicit concepts:

• Conservativeness – when bodies assess comparable alternatives, they choose the option that is cautiously moderate.

• Professional scepticism – an attitude that recognises circumstances which can cause material misstatements and demands critical assessment of evidence.

These principles support objectivity, impartiality, consistency and reliability throughout the validation/verification process.

» General, Structural and Resource Requirements

General requirements

Bodies must:

• be a clearly defined legal entity with documented legal status and, where applicable, ownership and control;

• take responsibility for validation/verification opinions and AUP reports they issue;

• manage impartiality through mechanisms independent of operational activities, identifying and addressing conflicts of interest;

• address liability in line with ISO/IEC 17029.

Structural requirements

The organisation must have:

• a documented organisational structure, including top management roles and responsibilities;

• processes for operational control, ensuring that activities at all locations follow the standard and relevant programmes.

Resource requirements

ISO 14065 sets detailed expectations for people and support resources:

• Personnel – verifiers, validators, technical experts, reviewers and others must meet competence, ethical and experience requirements defined by the body and relevant programmes.

• The body must maintain a management process for competence, including:

  • defining required competencies per programme and sector;

  • ensuring teams collectively have all necessary skills;

  • periodic monitoring of performance;

  • access to internal or external expertise where needed.

• Validation/verification teams must be able to:

  • understand applicable programmes and eligibility rules;

  • assess activities, technologies, data, monitoring methods and reporting;

  • evaluate data systems, risks, misstatements and nonconformities;

  • communicate effectively with clients and intended users.

• The team leader must be capable of managing the team, planning and executing engagements, and leading audit-style activities.

• Outsourcing is permitted under ISO/IEC 17029, but the body remains responsible and must control outsourced work.

» Validation Programme

Bodies may operate under one or more environmental information, validation or verification programmes (e.g. GHG schemes, green bond programmes, ESG disclosure frameworks). ISO 14065 requires them to follow the programme rules in addition to this standard and ISO/IEC 17029.

Programmes can be international, regional, national, sector-specific or organisational, and may themselves be based on sets of standards that together meet ISO 14065 requirements.

» Process Requirements (Clause 9)

ISO 14065 adopts the process structure of ISO/IEC 17029 and adds sector-specific details.

Pre-engagement

• The body checks whether it can accept the engagement and whether the statement and criteria are suitable.

• The type of engagement (verification, validation, AUP, or a combination) must be identified.

Engagement

• A formal engagement agreement (often a contract) is concluded.

• The client must inform the body about any facts that may affect the validity of the opinion.

Planning
The team prepares a validation/verification plan and an evidence-gathering plan, including:

• strategic analysis of the environmental information statement;

• assessment of the risk of nonconformity with criteria;

• defined level of assurance and materiality;

• approval of plans by the team leader and formal control of any amendments (e.g. if scope, timing or evidence sources change).

Execution

• Evidence is gathered and evaluated in line with ISO/IEC 17029 and, for GHG work, ISO 14064-3 (via Annex E).

Review

• A review is conducted by persons not involved in planning or execution of the engagement.

• The review confirms:

  • team competence;

  • adequacy of planning (objectives, scope, materiality, risk assessment, evidence plan);

  • treatment of significant findings (misstatements, nonconformities);

  • appropriateness of the draft opinion;

  • whether the environmental information statement is fairly stated and conforms to criteria.

Decision and issue of the opinion

• The decision on the opinion is taken by personnel independent of planning and execution; this may be the reviewer.

• Possible outcomes include:

  • unmodified opinion (environmental information materially correct and conforms to criteria);

  • modified opinion (material but not pervasive issues, or programme-specific requirements);

  • adverse opinion (pervasive misstatements);

  • disclaimed opinion where sufficient appropriate evidence cannot be obtained. Annex A links misstatement type and extent to opinion type.

• For verification of historical information, an opinion providing assurance must be issued unless disclaimed or engagement is AUP. For validation of future-oriented information, an opinion on the reasonableness of assumptions, methods and limits is required unless disclaimed.

• The opinion document must identify:

  • the environmental information activity (organisation, project, product, investment etc.);

  • the responsible party;

  • the criteria used for preparing and for validating/verifying the statement;

  • for forecasts, a note that actual results can differ from estimates.

After issuance, appeals, complaints and records

• The body must handle:

  • facts discovered after issuing the opinion;

  • appeals relating to its decisions;

  • complaints regarding its activities;

  • records that demonstrate conformity to ISO 14065 and programme requirements.

» Information, Communication and Use of Marks

Clause 10 describes how information is managed:

• Certain information must be publicly available, such as services offered and procedures for complaints and appeals.

• The body must be able to confirm the status of opinions (identity of issuer, issue date, revision status).

• Clients must receive adequate information on process and results, including description of the validation/verification process where required.

• Reference to validation/verification and use of marks must not mislead:

  • clients must not use opinions, reports, marks, logos or labels in a way that could mislead intended users or damage the body’s reputation;

  • short-form references (e.g. “verified”) must be linked to long-form references that explain scope and level of assurance, as illustrated in Annex B.

• Confidentiality obligations must be maintained consistent with ISO/IEC 17029 and any programme rules.

Management system requirements

Bodies must operate a management system that supports quality and consistency:

• regular management reviews (at least annually, with no more than 15 months between reviews);

• internal audits at similar intervals;

• corrective actions in response to nonconformities;

• processes to address risks and opportunities;

• controlled documented information.

This system can be integrated with existing quality or environmental management systems, provided that ISO 14065 and ISO/IEC 17029 requirements are met.

» Annexes with Specific Applications (GHG, Green Bonds, Climate Finance)

ISO 14065 contains several annexes particularly relevant to carbon accounting and climate-related work:

• Annex A (informative) – types of opinions and how misstatements and materiality link to opinion forms.

• Annex B (informative) – rules and examples for references to validated/verified statements and use of marks, including product lifecycle cases and mixed engagements (verification + AUP).

• Annex C (informative) – sample reports of factual findings for AUP engagements (e.g., destruction of ozone-depleting substances, green bonds).

• Annex D (normative) – additional requirements for green bond and green loan validation/verification and AUP, including:

  • application of ISO 14030-4 for competence and process;

  • the option to use ISO 14030-4 with ISO 14064-3 or to use ISAE 3000/ISRS 4400.

• Annex E (normative) – additional requirements for greenhouse gas validation/verification and AUP, covering:

  • competencies under ISO 14066;

  • team knowledge of GHG programmes, eligibility, legal requirements;

  • expertise on projects, organisations and products, including baselines, additionality, leakage, permanence;

  • specific rules for verifying carbon footprint of products following ISO 14067;

  • mandatory use of ISO 14064-3 for GHG opinions and conditions for outsourcing.

• Annex F (normative) – additional requirements for investments and financing activities related to climate change, requiring reference to ISO 14097 and giving options to use ISO 14097 with ISO 14064-3 or ISAE 3000/ISRS 4400.

These annexes connect ISO 14065 directly to carbon emissions validation, carbon footprint verification, green bond labelling and climate-related financial disclosures.

Adaptation Notice under the ISO – International Organization for Standardization

This text has been adapted in accordance with the guidelines set forth by the ISO – International Organization for Standardization. In our efforts to ensure transparency, accountability, and alignment, we have carefully reviewed and incorporated ISO. This adaptation process reflects our commitment to high-quality, accurate, ensuring that the information presented adheres to internationally recognized standards.