INS Gap Analysis Checklist
Based on the Italian National Sustainability Certification Scheme (INS) — implementing RED II/III sustainability criteria. 10 Requirement Areas with 58 Audit Criteria. Check items that have been implemented and documented at the assessed entity.
📋 Assessment Information — Fillable in the Field
INS Gap Analysis Results
Maturity score based on the 10 INS requirement areas. Scores are weighted per area reflecting regulatory criticality under RED II/III and INS scheme requirements.
Overall Maturity Score — INS Biofuels & Bioliquids
Per Requirement Area — INS
INS Maturity Scale — Biofuels & Bioliquids Sustainability
Non-Compliant / Initial
Developing
Managed
Proactive
Best Practice
Recommendations per Maturity Level — INS Sustainability
Strategic action plan based on gap analysis results against INS requirements implementing RED II/III. Applicable to all biofuel and bioliquid operators regardless of feedstock type or supply chain position.
▶ PRIORITY ACTIONS — 0–12 MONTHS
- Establish and formally sign a Sustainability Policy covering commitment to RED II/III compliance, land use exclusions, GHG targets, and social standards — distribute to all relevant staff and key suppliers
- Appoint a designated Sustainability Manager with clear authority and resources to oversee INS compliance; create a sustainability function with defined responsibilities across all supply chain roles
- Build a comprehensive Legal Register: EU RED II/III, Italian Legislative Decree transposing RED, INS scheme rules, GSE (Gestore Servizi Energetici) applicable guidelines, and national environmental/labour law
- Commission land use and carbon stock assessments for all feedstock supply areas — establish evidence of no conversion of HCV/HCS/peatland/wetlands after January 2008 (satellite imagery + on-ground verification)
- Implement an initial GHG calculation for each fuel pathway using RED II Annex V methodology — verify that GHG savings meet the applicable threshold (50%/60%/65%)
- Set up a basic mass balance system — even a spreadsheet-based approach — to track sustainable and non-sustainable quantities separately, with monthly reconciliation
- Conduct supplier mapping: identify all direct suppliers, request certificates (INS or equivalent recognized scheme), collect signed sustainability declarations for each supply origin
- Review and update employment contracts and labour records to document compliance with ILO core labour standards, fair wages, and working hours
- Create a document control system: register all sustainability documents, assign version control, establish minimum 5-year record retention policy
- Develop an emergency action plan with a timeline to achieve certification readiness within 12–18 months, including milestone checkpoints and assigned owners
▶ AREA-SPECIFIC PRIORITIES — LOW MATURITY
🛢️ GHG & Land Use (Areas 3–4)
- ›Step 1: Map all feedstock origins with GPS coordinates and obtain satellite imagery baseline for Jan 2008 land-use status
- ›Step 2: Run first GHG calculation using RED II default values where actual values unavailable — document all assumptions
- ›Step 3: Identify any supply origins that cannot immediately pass land use screening — quarantine or exclude from INS scope until verified
- ›Step 4: Engage a technical consultant for HCV/HCS assessment methodology if in-house capacity is insufficient
⚖️ Mass Balance & Supply Chain (Areas 5–6)
- ›Priority 1: Establish mass balance records immediately — track all incoming sustainable/non-sustainable volumes, even manually
- ›Priority 2: Request INS / equivalent certificates from all direct suppliers; flag uncertified suppliers as non-conforming risk
- ›Priority 3: Include sustainability clauses in all new supplier contracts — do not renew contracts without sustainability declarations
- ›Priority 4: Designate a supply chain compliance officer responsible for certificate validity monitoring and supplier communication
👥 Social & Governance (Areas 1,7)
- ›Action 1: Conduct a social compliance self-assessment against ILO core conventions — identify and remediate any non-conformances immediately
- ›Action 2: Establish a grievance mechanism accessible to all workers — it does not need to be complex at this stage; a logged register is sufficient
- ›Action 3: Ensure top management formally endorses the sustainability policy — without this, no other INS requirement can be credibly fulfilled
- ›Action 4: Allocate budget for sustainability compliance in the upcoming financial year; document the allocation formally
▶ CONSULTANT ROLE — NON-COMPLIANT CONDITION
- ①Full INS Gap Assessment (all 10 areas): Consultant maps all gaps against INS requirements, identifies critical legal risks (e.g. missing land use evidence, absent GHG calculations), and produces a prioritized remediation roadmap
- ②GHG Calculation Setup from Scratch: Consultant builds pathway-specific GHG calculation models (RED II Annex V), trains internal staff, and establishes data collection processes for primary activity data
- ③Land Use & HCV/HCS Assessment: Coordinates satellite imagery analysis and on-ground verification for all supply origins — generates exclusion maps and compliance declarations
- ④Mass Balance System Implementation: Designs and deploys a fit-for-purpose mass balance system (software or structured spreadsheet), trains users, and validates initial balances
- ⑤Documentation & Management System Build: Drafts sustainability policy, procedures for key INS areas, record retention protocols, and supplier declaration templates
- ⑥Roadmap to Certification in 18 Months: Develops a structured action plan with monthly milestones, KPIs, and escalation points to achieve INS certification readiness
▶ PRIORITY ACTIONS — 6–18 MONTHS
- Upgrade GHG calculations to primary data: Progressively replace default values with actual primary data (agricultural inputs, processing energy, transport distances) — this improves GHG savings margin and strengthens certification standing
- Formalize mass balance into a dedicated software system: Migrate from spreadsheets to a certified or auditable software platform; ensure all incoming/outgoing lots are recorded in real time with sustainability attributes
- Conduct comprehensive supplier audit programme: Schedule risk-based supplier audits covering the top 80% of supply volume; document findings, issue corrective action requests, and track closure
- Strengthen land use monitoring: Establish an annual satellite imagery review protocol for all supply origins; update land use exclusion maps and refresh supplier declarations on schedule
- Implement internal audit programme (all 10 INS areas): Schedule and execute annual internal audits; ensure auditors are independent of the audited function and have documented INS competence
- Formalize social compliance monitoring: Establish a structured worker interview programme, regular wage verification, and community engagement records — go beyond policy to evidence of active compliance
- Set environmental performance KPIs: Define measurable targets for energy efficiency, water consumption, waste generation, and emissions — track and report quarterly against baselines
- Develop a training matrix for all INS roles: Map required competencies per function, identify gaps, and schedule INS-specific training (especially GHG methodology and mass balance operation)
- Commission a pre-certification mock audit: Engage an experienced INS auditor to conduct a simulated certification audit against all 10 INS areas — identify residual gaps before the real audit
- Establish a regulatory monitoring process: Designate a person responsible for tracking RED III developments, INS scheme updates, and GSE guidance — ensure internal procedures are updated within 90 days of any regulatory change
▶ AREA-SPECIFIC FOCUS — MEDIUM MATURITY
📊 GHG & Documentation (Areas 2, 4)
- ›Replace default values in the highest-impact pathway steps (cultivation/agriculture, processing energy) with primary data — minimum target: ≥3 primary data points per pathway
- ›Implement a document management platform (even SharePoint/cloud-based) — enforce version control, approval workflows, and searchability
- ›Introduce annual GHG data verification by an internal reviewer before submission — create a four-eyes review step for all calculated values
- ›Document GHG uncertainty range per batch — demonstrates analytical rigour to certification body auditors
🔗 Mass Balance & Traceability (Area 5)
- ›Enable lot-level traceability in mass balance: every outgoing delivery must link back to specific incoming supply lots with full sustainability attributes
- ›Monthly mass balance reconciliation: compare physical stocks with system balances; investigate and document any variance above threshold (e.g. 0.5%)
- ›Conduct an end-to-end mass balance walkthrough with staff annually — verify that all understand how to record and transfer sustainability attributes correctly
- ›Test mass balance data integrity for a sample month: independently recalculate from source documents and compare with system outputs
🌿 Environment & Social (Areas 7, 8)
- ›Launch a structured social compliance audit of own operations: worker interviews (at least 10% sample), payroll spot-checks, workplace inspection, grievance mechanism effectiveness test
- ›Establish a community engagement register: log all interactions with local communities, land use consultations, and any complaints received with resolution status
- ›Set baseline environmental data: measure and document current energy consumption, water withdrawal, and waste generation — these become the baseline for continuous improvement tracking
- ›Verify all operating permits (water discharge, air emissions, waste handling) are valid — create a permit renewal calendar with advance notifications
▶ CONSULTANT ROLE — MEDIUM MATURITY
- ①Detailed Gap Audit against all INS Criteria: Consultant performs a thorough review of all 10 INS areas — produces a gap matrix identifying specific deficiencies preventing certification, with severity ratings and remediation priorities
- ②GHG Model Optimization & Primary Data Collection: Supports transition from default-based to primary data–based GHG calculations; designs data collection protocols for each pathway step; validates improved GHG savings calculations
- ③Mass Balance System Upgrade: Reviews current mass balance setup, identifies weaknesses in attribute transfer or reconciliation, recommends software solutions, and supports implementation and staff training
- ④Supplier Audit Programme Design & Execution: Develops risk-based supplier audit protocol, conducts sample supplier audits, identifies systemic supply chain risks, and supports CAPA management
- ⑤Pre-Certification Mock Audit: Simulates a full INS third-party audit using official audit criteria — provides detailed findings report replicating what a certification body auditor would identify
- ⑥Certification Coordination Support: Assists in selecting and liaising with an accredited INS certification body, prepares documentation packages, coaches management for the certification audit interview, and supports CAPA closure post-audit
▶ PRIORITY ACTIONS — ONGOING
- Maintain INS Certificate: Engage the certification body proactively; respond promptly to scheme updates; maintain surveillance audit readiness year-round with no seasonal preparation spikes
- Advance GHG performance beyond minimum thresholds: Set internal GHG savings targets exceeding regulatory minimums (e.g. 70%+ savings target); publish performance data in sustainability reports
- Deploy digital sustainability management platform: Integrate mass balance, supplier management, GHG calculations, and document control into a single digital platform — reduce manual error risk and enable real-time compliance monitoring
- Expand scope to RED III requirements proactively: Monitor RED III implementation timeline; anticipate upcoming changes (RFNBO, SAF requirements, additional feedstock restrictions) and adapt systems in advance
- Industry leadership on sustainability transparency: Publish an annual biofuel sustainability report aligned with GRI Standards or ISCC reporting framework; disclose GHG savings, land use commitments, and social performance metrics
- Supply chain development programme: Move beyond compliance auditing — actively support suppliers in improving their own INS compliance, GHG performance, and social standards through capacity building programmes
- Benchmark against other voluntary schemes: Conduct a comparative analysis against ISCC EU, REDcert², RSB — identify best practice elements not currently in INS scope that could further strengthen the sustainability system
- Innovation in GHG reduction: Invest in process improvements delivering measurable GHG reductions (precision agriculture, renewable energy in processing, optimized logistics routes) — document and verify reductions
- Stakeholder engagement excellence: Establish an annual stakeholder dialogue covering sustainability performance, emerging risks, and improvement plans — include communities, NGOs, customers, and regulators
▶ AREA-SPECIFIC FOCUS — HIGH MATURITY
📈 GHG Leadership (Area 4)
- ›Implement product carbon footprint labelling on certified biofuel deliveries — differentiate in market by demonstrating superior GHG savings
- ›Explore insetting projects: invest in on-farm carbon sequestration, reforestation, or renewable energy in your supply base — generate verifiable Scope 3 reductions
- ›Conduct pathway-level GHG optimization analysis — identify the 2–3 highest-impact pathway steps and invest specifically in reducing those emissions
- ›Publish third-party verified GHG savings data — external verification adds credibility for institutional buyers and ESG investors
🤝 Supply Chain Excellence (Areas 5, 6)
- ›Introduce supplier sustainability scorecards: rank suppliers on GHG performance, land use risk, social standards, and data quality — use scores to guide procurement decisions
- ›Launch a supplier capacity-building programme: offer training on GHG calculation, land use documentation, and social compliance — position as a premium sustainability partner
- ›Implement blockchain or IoT-enabled traceability for high-risk supply chains — real-time origin verification adds an additional layer of assurance beyond document review
- ›Conduct Tier 2 supply chain risk mapping — go beyond direct suppliers to understand sustainability risks two layers upstream
🌍 Social & ESG Leadership (Areas 7, 8)
- ›Align sustainability reporting with GRI Standards 301/302/303/305/408/409 — achieve third-party assurance of social and environmental claims
- ›Set a science-based target for Scope 1+2+3 GHG reductions aligned with 1.5°C pathway — submit to SBTi validation
- ›Implement a nature-positive strategy: beyond HCV/HCS protection, actively restore degraded habitats in supply landscapes — quantify and report biodiversity outcomes
- ›Position for CSRD compliance: align sustainability data collection with EU Corporate Sustainability Reporting Directive requirements, anticipating mandatory disclosure timelines
▶ CONSULTANT ROLE — HIGH MATURITY / BEST PRACTICE
- ①Multi-Scheme Alignment (ISCC EU / REDcert² / RSB): Gap analysis against additional recognized voluntary schemes — supports market access to multiple national markets and institutional buyers requiring scheme diversification
- ②RED III Preparedness Assessment: Detailed analysis of incoming RED III obligations (RFNBO expansion, new GHG thresholds, deforestation regulation alignment) — develops adaptation roadmap 12–24 months ahead of implementation dates
- ③Digital Transformation of Sustainability Management: Designs and implements an integrated digital platform for mass balance, GHG tracking, supplier management, and reporting — eliminates manual processes and enables real-time compliance dashboards
- ④Science-Based Target & ESG Reporting: Supports development of science-based GHG targets, alignment with GRI/CSRD disclosure frameworks, and investor-grade sustainability report preparation
- ⑤Supply Chain Sustainability Transformation: Designs and facilitates supplier capacity building programmes — from compliance audit to collaborative improvement, building a resilient and transparent supply network
- ⑥Benchmarking & Industry Leadership Positioning: Comparative analysis against sector peers and voluntary scheme leaders — identifies best-practice gaps and develops a roadmap to recognized sustainability leadership