Cap-and-invest third-party verification

In 2022, the Greenhouse Gas (GHG) Reporting regulation was updated to include a broader group of industries and to align with the requirements of the cap-and-invest program. It was also updated to include an additional quality-assurance mechanism: third-party emissions verification.

Emissions reports submitted to us are reviewed and verified by our staff. Under the updated rule, certain reporters must also contract with a third-party verifier. These independent verifiers will review each entity's annual emissions reports and send us a statement each year indicating whether or not the reports are accurate.

How do I know if my business needs to hire a third-party verifier?

All businesses that are subject to, or are voluntary participants in, the cap-and-invest program are required to have their emissions reports verified by a third-party verifier. However, other businesses reporting emissions under Chapter 173-441 may also be required to do so, depending on their emissions levels:

Threshold for reporting emissions: 10,000 metric tons
Threshold for third-party verification: 25,000 metric tons
Threshold for coverage under cap-and-invest: 25,000 metric tons after accounting for exemptions set in state law.

In addition, any reporter that drops below the 25,000 MT CO₂e threshold must still have its emissions reports verified for the first year.

Resources for reporters

How do I find a third-party verification body?

We are in the process of setting up a program for third-party verification bodies to become certified in Washington. Washington-certified verification bodies will be listed here soon.

In the meantime, we anticipate significant overlap with both the California-accredited verification bodies and Oregon-certified verification bodies. We encourage you to reach out to them with questions about their processes.

Upcoming trainings

Upcoming third-party verification trainings for emissions reporters will be listed here, once scheduled. Please email GHGReporting@ecy.wa.gov to be added to an email list for announcements about upcoming trainings.

For trainings on how to report emissions, see our Emissions page.

Forms for reporters and third-party verifiers are currently in development and will be available through the GHGReg website for registered reporters and verifiers.

Verification tips for reporters

The process of third-party verification takes several months, so we recommend that reporters contact a Washington-certified verification body as soon as possible. At the start of the verification process, reporters will need to submit documentation to us declaring the third-party verification contract and certifying there are no conflicts of interest.

These declaration forms are in development and will be available through the GHGReg website once finalized. Once these forms are available, reporters will be able to submit them through the same GHGReg platform that is used to submit annual emissions reports.

It's important to note that reporters can't use the same verification body for more than six consecutive years, and must wait at least three years before contracting with a previous verification body again.

A verification team consists of a lead verifier, supporting verifiers, and may include a sector specialist.

Full verification will require a site visit and interviews with key personnel, so reporters should work with their verifiers to ensure compliance.

After reviewing emissions reports, verifiers may submit a list of correctable errors. These issues must be resolved and a corrected report submitted by the deadline to receive a positive verification statement.

Verifiers will treat all data as confidential business information. However, they cannot provide advice. Reporters should contact GHGReporting@ecy.wa.gov with any questions about third-party verification requirements or process.

Verifiers may ask for other types of information, but being able to provide the following documentation can help the verification process go smoothly:

GHG Monitoring and Reporting Plan – Verifiers will ask for documentation of overall procedures as well as details about:
- Process and methods to collect emissions data
- Quality assurance, maintenance, calibration and repair of instruments used to provide reported data
- Raw data used to calculate emissions.
Records pertaining to emissions calculations, including:
- Documentation of fuel and electricity transactions
- Documentation of instrument maintenance
- Greenhouse gas collection data
- Previous emissions reports and supporting documentation
  - Your verifier will have access to all reports submitted to us via the WEDGE application.
- Note: it is recommended that reporters retain this information for at least 10 years.

Resources for verifiers

Both verification bodies and individual verifiers must meet certain requirements to be certified in Washington, including:

Active accreditation in California
Demonstration of sufficient knowledge of Washington's regulations, Chapter 173-441 WAC and Chapter 173-446 WAC.

Individual verifiers must also complete the Washington third-party verification training. Both lead verifier and specialized sector certification require demonstration of additional work experience and corresponding certification.

All eligible verifiers and verification bodies are invited to register in Washington using our GHGReg application.

Upcoming trainings

Upcoming verifier trainings will be listed here once scheduled. Please email GHGReporting@ecy.wa.gov to be added to an email list for announcements about upcoming trainings.

Forms for reporters and third-party verifiers are currently in development and will be available through the GHGReg website for registered reporters and verifiers.

Conflict of interest

The purpose of the third-party verification requirement is to ensure submitted emissions reports are accurate. To serve this purpose, it is important that verifiers be impartial when reviewing reporter submissions. This requires avoiding any potential conflict of interest as outlined in Chapter 173-441-085 (7)(c)

Conflict of interest can be:

Low: verification relationship will be approved
Medium: verification may proceed with an approved mitigation plan
High: verification relationship will not be approved.

Contact information

Katie Kaku
Third Party Verifier Program Specialist
GHGReporting@ecy.wa.gov
360-706-3902

Claire Boyte-White
Cap-and-Invest Policy Relations
claire.boyte-white@ecy.wa.gov
360-764-6124

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Cap-and-invest third-party verification

How do I know if my business needs to hire a third-party verifier?

Resources for reporters

How do I find a third-party verification body?

Upcoming trainings

Verification tips for reporters

Resources for verifiers

Upcoming trainings

Conflict of interest

Related links

Contact information