Practical support for businesses dealing with F-Gas reporting, HFC documentation, declarations of conformity and independent verification.
Compliance with the EU F-Gas framework can involve considerably more than submitting an annual report.
For businesses importing or trading in hydrofluorocarbons or importing products and equipment containing HFCs, compliance may involve the F-Gas Portal, HFC quota authorisations, customs documentation, declarations of conformity, annual reporting and independent verification.
Clear Mind can assist businesses in understanding these requirements and, where applicable, provide the independent auditor verification required under the EU F-Gas framework.
The first step is determining how Regulation (EU) 2024/573 applies to the company’s actual activities. A company may have obligations if it:
The obligations differ considerably depending on whether the company is importing bulk gases or products and equipment in which HFCs are already contained. Clear Mind can review the company’s circumstances and help identify the reporting and verification requirements relevant to its activities.
Certain businesses must submit annual information concerning their F-Gas activities through the European Commission’s reporting system. Before verification begins, it is important that the quantities reported can be reconciled with the company’s underlying records.
Clear Mind can review the information supporting the F-Gas report, including where relevant:
This helps identify inconsistencies before the final verification is completed.
Under Article 26 of Regulation (EU) 2024/573, certain companies are required to have the information reported to the European Commission independently verified.
| Independent verification Where a business reports placing 1,000 tonnes of CO₂ equivalent or more of HFCs on the market during the previous calendar year, the report must generally be verified by an independent auditor at a reasonable level of assurance. The verification must be completed by the applicable deadline and processed through the F-Gas reporting system. |
Independent auditors carrying out F-Gas verification must satisfy the eligibility requirements established by the Regulation and must be registered in the European Commission’s F-Gas Portal.
Additional requirements apply to companies importing certain equipment or products that have already been charged with HFCs. This commonly includes:
The auditor’s work may include checking whether the HFCs contained within imported products or equipment have been properly accounted for within the quota system. Under the current verification framework, the auditor may need to examine:
Commission Implementing Regulation (EU) 2025/2155 specifically requires the independent auditor to assess the consistency, accuracy and completeness of the relevant documentation and declarations of conformity and, where applicable, verify the availability of sufficient quota authorisations or delegations.
One of the most important elements of F-Gas verification is ensuring that the information reported to the European Commission is consistent with the company’s actual commercial activity. Our verification procedures can include reconciliation of reported quantities to:
Supplier invoices – To confirm the products or gases purchased and the quantities involved.
Customs documentation – To confirm imports into the European Union and identify relevant products and equipment.
Product specifications – To determine the type and quantity of HFC contained in individual units.
Sales and inventory records – To understand movements of goods and reconcile opening stock, purchases, sales and closing stock where relevant.
F-Gas Portal information – To verify relevant quota authorisations, delegations and regulatory information.
The objective is to establish a clear audit trail from the underlying commercial transaction to the quantities ultimately included in the F-Gas report.
Importers of relevant pre-charged products and equipment may also be required to prepare and retain a Declaration of Conformity confirming that the HFCs contained in those products or equipment have been properly accounted for under the quota system.
The current requirements for these declarations are established by Commission Implementing Regulation (EU) 2025/2155. As part of the independent verification process, Clear Mind can examine the declarations and supporting documentation and assess whether they are consistent with the information reported through the F-Gas system.
F-Gas verification is increasingly digital. The European Commission requires relevant reporting and verification to be carried out through the F-Gas Portal and associated Business Data Repository reporting system.
The independent auditor records the relevant verification conclusions through the system in accordance with the applicable procedure. The Commission’s current guidance requires auditors to assess whether relevant reported HFC information is accurate, complete and free from material misstatement and to report the verification outcome through the electronic system.
Companies should avoid leaving the verification process until shortly before the reporting deadline. Having the appropriate records available can significantly improve the efficiency of the process.
Depending on the company’s activities, useful documentation may include:
Where possible, this information should be reconciled before it is provided for independent verification.
Clear Mind provides practical support to businesses affected by the EU F-Gas reporting and verification requirements. Our services can include:
Our approach is focused on ensuring that the information reported can be clearly supported by the company’s underlying records and that the verification process is completed in accordance with the applicable EU requirements.
The revised F-Gas framework has increased the level of regulatory oversight surrounding HFCs and equipment containing them. For importers in particular, F-Gas compliance now interacts directly with customs procedures, quota management, annual reporting and independent verification.
Contact Clear Mind Financial Services Ltd. for tailored support with accounting, auditing and Cyprus tax matters.
