A reference for EU importers and Member State competent authorities
The European Commission’s Recommendation on compliance solutions under Regulation (EU) 2024/1787 (the EU Methane Regulation, “EUMR”) sets out criteria Member State competent authorities should take into account when recognizing providers of compliance solutions (such as MiQ) and assessing information submitted to them under the importer requirements set out in Articles 27(1), 28(1) and (2) and 29(1) and (2). importers.
This document maps MiQ’s methane certification program and its Certificate Inter-Regional Import System (CIRIS) against those criteria – and shows that MiQ and CIRIS satisfy them.
- The Commission expressly recognises “certification” as a compliance-solution type in its own right (recital 13).
- The Recommendations confirm that the EUMR “does not require physical tracing of molecules, deliveries or cargoes” (recital 9). The CIRIS system can be used in both, certification (i.e., national/regional book and claim) and trace-and-claim systems.
- The Annex criteria are minimum standards for acceptance (recital 14). MiQ’s certification program meets these criteria: an operational, non-conflicted certification framework that is underpinned by mandatory independent third-party verification and supported by a single digital registry that prevents double-issuance and double-claiming.
For importers, MiQ and CIRIS offer a ready, defensible route to demonstrate compliance. For competent authorities, MiQ certification and the CIRIS framework provide a transparent, fraud-resistant and verifiable basis on which to accept that demonstration. MiQ is operational, with more than 100 verifications and certifications completed; its Standard and Verification (Audit) Protocol are both public and are equivalent to EUMR requirements.
The table below sets out the Recommendations to MiQ’s certification framework, criterion by criterion.
Criterion-by-criterion mapping
| Commission criterion (Annex, Section 1) | How MiQ certification & CIRIS satisfy it |
| A. Certificate data & traceability | |
| Criterion 1: (i–v). Required certificate content: registration/ID number and issuance date; validity period; country of origin; production-site identity, location, volume and production period; information proving compliance with Art. 27, 28(1-2), 29(1-2). | Each MiQ certificate (one certificate per MMBtu or BOE) carries a unique registration ID and issuance date, a defined validity period, the country of origin, the verified and certified production site, and methane intensity (MI) information. Emissions data on certificates will be compiled and provided in a CIRIS statement, to be presented by importer to competent authorities. The certificates evidence the producer’s verified methane performance against MiQ’s EUMR-equivalent Methane Performance Standard – including MRV requirements – supporting the Art. 27/28/29 import requirements. |
| Criterion 2: Submit all information necessary to demonstrate producer-level compliance. | MiQ certificates explicitly and implicitly contain required producer-level MRV information and are subsequently compiled in the CIRIS statement. The MiQ Methane Performance Standard includes requirements for activities, such as LDAR processes, that are included in the EUMR. These elements satisfy required Annex IX information to be submitted by importer to competent authority. Methane Intensity is already provided today under MiQ certification and will be ready for Article 29 requirements from 2028 onwards. |
| Criterion 3: Country-of-origin match: origin in the documents must match the origin of natural gas and crude oil physically placed on the Union market. | CIRIS permits only certificates from the country of origin (the export country) to be used, and only where the gas/oil has physically been imported into the EU – therefore ensuring the match. MiQ CIRIS is not a global book-and-claim system and instead complies with the country-of-origin match requirement. |
| Criterion 9: Where energy transits non-EU countries before final EU delivery, provide evidence of prior import to the EU. | CIRIS links certificates to actual physical export flows into the EU, supporting evidence of prior import where volumes transit third countries. |
| B. Registry integrity — anti-double-issuance & single-claim | |
| Criterion 4: Registry containing all Annex ‘point 1’ data on every certificate issued. For certification, include record of when a certificate is claimed. Confidential business information withheld from publication but available to the competent authority. | All MiQ certificates are stored in a secure digital registry, recording each claim. (The registry withholds confidential business information from publication while making it available to competent authorities, consistent with Art. 28(4) and 29(3).) |
| Criterion 5: Implement and publicly explain measures to prevent double issuance and double claiming. | The MiQ digital registry is designed to prevent both: it ensures GHG attribute can be claimed by only one party. The controls are publicly documented in the MiQ Program Guide, available online. |
| Criterion 6: On issuance, cross-check other Providers’ registries to prevent multiple issuances for the same producer/site/period. | MiQ’s single-registry model provides robust controls based on best practices. MiQ practices include contractual representations and warranties with MiQ-certified producers to ascertain no prior or parallel document exists for the same volume, site and period. MIQ lists all certified facilities and checks with other potential certification providers against double issuance. MiQ registry is interoperable and has API protocols to facilitate automated checks. |
| Criterion 7: A certificate may be claimed only once; once claimed it is recorded and can no longer be claimed by the same or another importer. | The MiQ registry tags a certificate that is claimed for import requirement purposes, and records it in the registry as imported, preventing any re-claim. |
| C. Independence & conflict of interest | |
| Criterion 8: The Provider must be legally and functionally independent from any energy production, supply, distribution, transmission or import entity, operating with full impartiality and separated accounts. | MiQ is a not-for-profit, non-conflicted organisation. It has no financial interest in any certification outcome, no financial relationship with the verifiers who conduct audits, and sells no emissions monitoring or measurement technology. It is a legally distinct, impartial provider. |
| D. Third-party audit & verifier accreditation | |
| Criterion 11: Certificates (documents of compliance) should be issued only after an external, third-party audit for conformity with the certification compliance solution has been successfully completed and an audit statement produced. | MiQ requires on-site independent third-party verification under its public Verification (Audit) Protocol resulting in a Verification (Audit) Report being submitted to the MIQ Registry. MiQ issues certificates only upon a positive audit result This fully reflects the audit-plus-statement requirement. |
| Criterion 14: For requirements needing independent third-party verification, Providers must not discriminate between verifiers accredited under Art. 9. | MiQ recognises any verifier (/auditor) meeting ISO 17029, 14065 and 14064-3 plus specific methane competences, and does not discriminate among qualified expert verifiers. It is ready to recognise Art. 9–accredited verifiers as accreditation scopes are established (see closing note). |
| E. Public transparency & methodology | |
| Criterion 10: Publicly available documentation explaining the functioning and methodology of the compliance solution, the responsibilities of all actors, and references to the relevant EUMR provisions. | MiQ’s Methane Performance Certification Standard, Program Guide (including the CIRIS framework), and Verification (Audit) Protocol are publicly available and are periodically updated with technical and scientific stakeholder input as methane science evolves. CIRIS documentation explains the roles of producers, verifiers, importers and MiQ, referenced to the EUMR requirements. (See below for references and links to these MiQ materials.) |
| F. Validity & durability of recognition | |
| Criterion 12 Once a competent authority recognises a type of compliance solution, such recognition remains valid as long as the terms of that compliance solution are not materially changed and changes shall be notified. | MiQ’s methane performance certification framework has been operational since 2021, is stable and documented, and supports recognition that persists across the contract term. MIQ engages in a clear process with stakeholders such operators, verifiers, academics and associations before implementing any changes. Any changes to the certification framework will be publicly noticed to member state competent authorities. |
| Criterion 13: A document’s validity should not exceed 24 months from the period of production certified until compliance is demonstrated. | In the context of marketing low methane-intensity gas and oil, MiQ certificates carry a defined validity periods of 36 monthsaligned to annual production and reporting cycles, consistent with a bounded validity window. MiQ will introduce a 24-month validity period for any EU-bound certificates, and is consulting with stakeholders whether to adjust the overall program to 24 months validity |
Equivalence today — and one systemic dependency
MiQ has updated its Methane Emissions Performance Standard and Verification (Audit) Protocol with the aim of full equivalence to the EUMR, and an independent expert assessment has confirmed that equivalence.
The EUMR requires the accreditation of verifiers who verify in non-EU (exporter) countries in an EUMR-equivalent manner (note: the EUMR requires accreditation by national accreditation bodies where verifiers operate in the EU). Accreditation bodies require standards against which they accredit verifiers. Such a standard will be the ISO standard on the quantification of methane emissions, once applicable. MiQ will reflect that standard once applicable. In the interim, MiQ will continue to recognize verifiers against the criteria set out in ISO 17029, 14065 and 14064-3 and specific methane competencies. We expect this approach to meet the EUMR’s equivalence requirements but welcome the Commission’s guidance on that aspect.
MiQ Documentation & References
MIQ Methane Performance Standard
MiQ Verification (Audit) Protocol
European Commission Documentation
Recommendation on optional model clauses on the reduction of methane emissions in the energy sector
Criterion references are to the Annex, Section 1 of the Commission’s Recommendation on optional model clauses and compliance-solution criteria under Regulation (EU) 2024/1787. Numbering follows the Recommendation format.