'Declaration of completeness audit guidelines' for the 2024 reference year
Last updated: 19 November 2024, applicable from the 2024 reference year
Declaration of completeness audit guidelines
Section 26 (1) no. 28 VerpackG (Packaging Act) authorises the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) to develop audit guidelines that auditors and experts must adhere to. The audit guidelines require approval from the German Federal Cartel Office. The Verpackungsgesetz (Packaging Act) calls for audits and/or confirmations by auditors or experts at various junctures.
To ensure that the audits and confirmations are consistent across auditor and expert groups, in terms of both audit process and audit level, the ZSVR has developed guidelines that have been approved by the German Federal Cartel Office.
Evolution of the declaration of completeness audit guidelines
The current declaration of completeness audit guidelines start taking effect with the 2024 reference year. These guidelines must be followed when auditing declarations of completeness, which need to be filed with the ZSVR by 15 May of the year following the reference year.
The audit guidelines provide clarifications to help auditors achieve reasonable assurance in their audit results. Front-loading audit activities helps to stagger the process and simplify substantive procedures conducted within a structural and functional audit of the relevant internal control system. This structure of front-loading and staggering is designed to support auditors in carrying out their work effectively.
The key updates to the content are:
- Restructured audit areas, including some additional specifications
- Structural and functional audit of internal control systems
Additions to audit activities concerning:
— Participation agreements (audit area B.1.2)
— Flagged year-on-year volume changes (audit area B.1.2)
— Volume transfers between producers (audit area B.1.2)
— Zero-sum volumes (audit area B.3.1)
— Retrospective volume transfers (audit area B.1.2)
— Packaging volumes pursuant to section 15 VerpackG (Packaging Act) (audit area B.1.3)- Specifications added to audit reports (C.2)
- Updates to the glossary (appendix 1).
Declaration of completeness audit guidelines
Pursuant to section 11 (3) VerpackG, the ZSVR has published standard operating procedures concerning the electronic filing procedure in the form of the 'declaration of completeness technical guidelines'. These guidelines require the use of certain electronic forms and input screens as well as access to the LUCID Packaging Register. The requirements set out in these guidelines must be complied with when making filings.