Content:

1. ISCC EU

2. ISCC CORSIA

3. Auditor Rotation

4. ISCC Requirement of Uploading the List of Sites Covered by a Certificate and Sourcing Contacts for All ISCC Certification Schemes 

The System Update is mandatory for all ISCC System Users, ISCC Auditors and cooperating Certification Bodies.

1. ISCC EU

1.1 Clarification on the Calculation of the Sample Size for Points of Origin

This clarification outlines the methodology for calculating the sample size for non-individually certified Points of Origin generating waste or residues.

The sample size must be determined based on all non-individually certified Points of Origin that have generated, on average, more than 5 metric tons per month (or more than 60 metric tons per year) of a specific type of waste or residue and which have signed the self-declaration within twelve months prior to the audit. 

Note: The calculation is based on the amount generated during the previous twelve months, not the amount supplied as sustainable to the next element in the supply chain (e.g., a Collecting Point).

In addition, the requirement to calculate the sample size and conduct sample audits for non-individually certified Points of Origin also applies to initial audits.

The requirements for sample auditing for Points of Origin are defined in the ISCC EU System Document 203 “Traceability and Chain of Custody” (v4.2), chapter 3.4.6, 3.4.7 and 3.5.5.

1.2 Certification of Co-processing Set-ups

In addition to the previous System Update from 12 June 2025, the following aspects shall be considered:

• The possibility to get certified based on a pathway presented to the auditor on how to reach compliance with the requirements of Delegated Regulation 2023/1640 shall only be granted once; specifically for the first re-certification after introducing the ISCC Document 203-01 “Guidance for the Certification of Co-Processing” (v2.0). For all future re-certifications and for any initial certification, full compliance with ISCC 203-01 Guidance (v2.0) is mandatory.

• While certification is still based on the pathway on how to reach compliance, the output listed in the annex of the certificate must state “Compliance with DR 2023/1640 is pending”. Once all required measurements and documentation have been provided, and the auditor approved the set-up, the certificate annex shall be amended accordingly.

1.3 Clarifications Relating to ISCC Requirements under ISCC EU 102 Governance (v4.2) 

Clarifications regarding current ISCC requirements under ISCC EU System Document 102 “Governance” (v4.2) are provided as follows:

 1. The example of a major non-conformity by a CB stated as “Entering inaccurate or false information in the ISCC HUB…” is expanded to include the incorrect or flawed use of the ISCC HUB in contravention of ISCC requirements and the ISCC HUB Manual, and demonstrated failures to respond to open tasks in the ISCC HUB within the designated timeframe. 

2. The example of a minor non-conformity of a CB stated as “Certification documents submitted to ISCC are delayed or incomplete” is expanded as follows: “Certification documents submitted to ISCC are delayed, incomplete or incorrect.” 

3. We have included the following examples of major non-conformities of System Users with ISCC requirements: 

a) Demonstrated failure to keep registration information (e.g. contact person/s, address etc.) updated in the ISCC HUB.

b) Demonstrated failure to respond to open tasks in the ISCC HUB in the designated timeframe.  

c) Demonstrated failure to respond to communications from the responsible CB, related to ISCC requirements. 

2. ISCC CORSIA

2.1 Clarification on Verification of Compliance against ICAO CORSIA Themes 10, 11, 12 and 13, 14 

We remind all cooperating Certification Bodies (CBs) and ISCC CORSIA System Users of the correct procedures for verifying compliance against ICAO CORSIA Themes 10, 11, 12 (Human and labour rights, Land use rights and land use, and Water use rights), and ICAO CORSIA Themes 13, 14 (Local and social development, and Food security).

2.1.1 Verification of compliance against ICAO CORSIA Themes 10, 11, 12 

Under ISCC CORSIA, compliance against ICAO CORSIA Themes 10, 11 and 12, can be verified through one of the following two options:

• Option 1: Audit against ISCC Principles 3, 4, and 5;

or

• Option 2: The System User may obtain a National Attestation from a relevant state authority (e.g. the associated ministry or department). There is no defined format or minimum required content for this attestation; this is defined by the State. For reference, see Q20 of the ICAO CORSIA FAQ.

Note: Under ISCC CORSIA PLUS, full compliance with ISCC Principles 1 to 6 is required. This means, that acquiring a National Attestation is not necessary.

If Option 2 is chosen, the CB must provide the National Attestation to ISCC as part of the ISCC CORSIA certification documents. 

2.1.2 Verification of Compliance against ICAO CORSIA Themes 13, 14 

Under both ISCC CORSIA and ISCC CORSIA PLUS, compliance against ICAO CORSIA Themes 13 and 14 must be demonstrated by the System User through the submission of a List of Actions to the CB. Under ISCC CORSIA PLUS, this is a requirement in addition to the full compliance with ISCC Principles 1 to 6.

The Sustainability Certification Scheme (SCS) is given no authority to review or judge the set of actions taken, and no detailed requirements have been provided. Therefore, there is no minimum requirement or format that the economic operator has to provide. The provided List of Action is considered valid as long as there is an indication of actions being taken to comply. For reference, see Q21 of the ICAO CORSIA FAQ. 

Note: The CB must provide the List of Action to ISCC as part of the ISCC CORSIA certification documents.

2.2 Clarification on Bionaphtha and Intermediate/Final Fuels for Non-aviation Sector(s) 

We would like to remind all cooperating Certification Bodies (CBs) and ISCC CORSIA System Users that, under the ICAO CORSIA framework, only feedstocks, intermediates, and final fuels that are intended exclusively for use in aviation are eligible for certification.

Any intermediate or final fuel that is not intended for use as aircraft fuel cannot be certified under ISCC CORSIA, nor can it be counted toward ICAO CORSIA compliance.

As an example, bionaphtha used for non-aviation purposes such as solvent applications, petrochemical feedstock, or gasoline production is not eligible for certification or recognition under the ICAO CORSIA framework. However, if bionaphtha is used as an intermediate for the production of SAF (as CEF under ICAO CORSIA), it can be certified under ISCC CORSIA.

Note: In accordance with this requirement, we have updated the ISCC CORSIA List of Eligible Materials by adding the notation “Only as intermediate” next to bionaphtha.

2.3 Clarification on Surveillance Audits under ISCC CORSIA 

The information stipulated within the ISCC CORSIA System Document 204 “Audit Requirements and Risk Management”, chapter 3.4 ‘Mandatory Surveillance Audits’ applies to all System Users after the first (initial) certification under the ISCC CORSIA system. 

This provision remains applicable regardless of previous certification under another ISCC certification system, such as ISCC EU or ISCC PLUS. Mandatory surveillance audits according to the frameworks outlined within the ISCC CORSIA 204 thereby also apply to System Users that have previously undergone surveillance audit(s) under other ISCC certification systems. 

This clarification is effective as of 17 July 2025.

3. Auditor Rotation

The principle of auditor rotation is defined in the respective ISCC System Documents for each applicable ISCC certification scheme outlined in the “Requirements for Certification Bodies and Auditors”.

In order to address questions received on this topic and to ensure consistent implementation of this rule among Certification Bodies, we would like to clarify the scope of application of the auditor rotation principle: 

• The rotation principle applies to all qualified auditors, namely all members of the audit team that conduct and/or participate in the audit of a System User, who are qualified to perform audits without supervision from a lead auditor.
• The rotation principle applies to GHG experts, as they participate in the audit.
• The rotation principle does not apply to technical reviewers, as they do not participate in the audit.
• The rotation principle does not apply to auditors in training until they qualify to conduct audits without supervision, even if the auditors in training are part of the audit team.

4. ISCC Requirement of Uploading the List of Sites Covered by a Certificate and Sourcing Contacts for All ISCC Certification Schemes

The following requirements are effective as of 17 July 2025.

4.1 List of Sites Covered by a Certificate

The List of Sites Covered by a Certificate consists of two tables: 

• Table 1: Sites Covered by the Certificate, and 
• Table 2: Site Specific Information. 

Both tables must reflect the status quo of all sites as applicable (main site, dependent collecting points and external storage facilities) and associated with the respective operational unit at the time of the audit. Furthermore, the List of Sites Covered by a Certificate must be updated continuously on the ISCC HUB until the certificate expires. 

This is of particular importance for ISCC EU certificates to ensure a smooth onboarding and continuous updating of certificates to the Union Database (UDB). Missing site information in the ISCC HUB will lead to transaction data failures in the UDB. 

This requirement ensures that the CB is notified – through automated tasks triggered by the ISCC HUB – about any changes to sites or materials intended to be covered by a certificate.  System Users may only start operating under the new site or changed conditions for an already listed site once the respective changes have been approved by the CB on the ISCC HUB.

4.2 Sourcing Contacts 

A complete List of Sourcing Contacts must be provided as part of the certification documents submitted to ISCC via the ISCC HUB upon issuing a certificate.

Whilst System Users must continuously manage and document their Sourcing Contacts in line with the present ISCC requirements, they do not have to update their Sourcing Contacts continuously on the ISCC HUB – neither between audit and certificate issuance, nor subsequently during the certificate validity period. 

However, for all audits (e.g., surveillance audits or scope extensions), the List of Sourcing Contacts must be updated on the ISCC HUB to reflect the state of the Sourcing Contacts as given during the audit. 

The indicated number of Sourcing Contacts must also be updated in the audit report and must match the information provided on the ISCC HUB.

Note: These requirements may be subject to change, particularly for ISCC EU in the context of the UDB requirements. Any changes will be announced in a timely manner.

Adding/Removing Sourcing Contacts in the ISCC HUB:

• To remove a contact, enter a date in the “Date of removal” column
• To add a contact, add all mandatory details and the “Date of adding” in the respective column. Sourcing Contacts can be added at any time between the audit and certificate issuance, as well as after certificate issuance.

For further guidance, please refer to the ISCC HUB website.