ECGT / EmpCo and Tourism Sustainability Certification

Update No. 1 — Green Key transition on 1 October and findings through the morning of 2 October 2026

Japanese version → 日本語で読む

Related material | International Review and Overseas Response Summary →

Japan Sustainability Coordinator Association (JaSCA)

1. Position of this Update

On 25 September 2026, JaSCA published an interim review on ECGT / EmpCo and tourism sustainability certification. Ahead of the 27 September application date, the review identified six Open Questions based on publicly available information concerning certification schemes, third-party assurance, certification-data distribution, consumer-facing display by OTAs, and the Green Key transition from 27 September to 1 October.

Update No. 1 does not replace the 25 September Interim Review. It records changes in institutional arrangements, public information and OTA displays following the 27 September application date and the entry into effect of Green Key’s new criteria and certification process on 1 October.

2. Main developments confirmed since 25 September

(1) Application of EmpCo

The 27 September 2026 date for application of national measures implementing Directive (EU) 2024/825 has now passed. Travalyst’s current Certifications Initiative information has likewise moved to post-application wording stating that the Directive came into effect on 27 September.

(2) Entry into effect of the new Green Key system

Green Key’s 2026–2031 Criteria and new Certification Process took effect on 1 October. New applicants are to use the new criteria, while a transition has been published under which existing certified establishments continue under the 2022–2026 criteria until re-certification under the new criteria.

(3) More specific conformity-assessment structure

Green Key describes FEE as the Scheme Owner and states that independent third-party auditors are used for on-site certification audits. Audit Independer is identified as the independent Certification Body, with responsibilities including auditor approval and assignment, certification decisions, certificate issuance, surveillance, suspension and withdrawal, and appeals and complaints.

(4) More specific transition rules

For the period from 1 October, Green Key has published cases covering new applications, re-certification involving an on-site audit, and continuing certification through off-site surveillance / desktop review. Under the new system certificates are generally valid for two years, while some transition cases provide for a one-year extension.

3. The central issue emerging from the review — traceability and flattening of assurance information

Since 25 September, JaSCA has continued enquiries and public-source checks involving Scheme Owners, Certification Bodies, accreditation and conformity-assessment actors, data intermediaries, OTAs, researchers and industry organisations.

The central issue emerging from this work is not only whether individual certification schemes meet the conditions applicable to sustainability labels under EmpCo. It is whether granular assurance information created upstream is lost as certification data pass through intermediaries and OTAs, causing materially different assurance models to be flattened into the same generic consumer-facing presentation.

For convenience, this Update refers to this phenomenon as “assurance flattening”.

The chain to be examined is:

Scheme
→ Certification / Assurance
→ Data intermediary
→ Trader / OTA
→ Consumer

Upstream, granular assurance information may include criteria, scope, scheme version, certificate validity, who performs the audit, who makes the certification decision, and which standards or procedures substantiate the competence and independence of that body.

As information moves downstream, however, if relevant metadata are not retained, materially different assurance structures may ultimately be aggregated into generic categories such as “certified”, “sustainable” or “third-party sustainability certification”.

This is distinct from the question whether each actor individually has an appropriate procedure. Even if a Scheme Owner, Certification Body, data intermediary and OTA each accurately describe their own role, consumers may still be unable to distinguish meaningful differences in assurance if the chain as a whole flattens the information.

In other words:

Responsibility may be distributed among multiple actors in the chain, while the consumer-facing presentation is consolidated into a single interface. The allocation of responsibility for conformity should therefore be distinguished from the design question of which assurance information ultimately reaches the consumer.

4. Green Key as an assurance-traceability case

Green Key is used here not to rank the scheme, but as a real certification case through which assurance information can be traced from upstream arrangements to downstream consumer-facing display.

(1) Upstream — Scheme / Certification / Assurance

FEE is the Green Key Scheme Owner and Audit Independer is positioned as the Certification Body under the new system. Public information identifies the criteria, certification process, transition rules, and the respective roles of auditors and the Certification Body.

On 2 October, direct replies from DANAK and RvA updated the factual position concerning external substantiation.

DANAK confirmed that it had evaluated the Green Key certification scheme and found it aligned with ISO/IEC 17065:2012 and suitable for accreditation. DANAK also confirmed that it has not accredited any certification body for certification according to the Green Key scheme. It explained that accreditation of a certification body for a specific scheme is a separate assessment, for which prior scheme evaluation is required under ISO/IEC 17011:2016 clause 4.6.3.

DANAK does not issue public statements on scheme-evaluation results. JaSCA’s earlier observation that it could not identify a public primary record therefore remains accurate as an observation about publicly available information, while completion of the scheme evaluation is now confirmed directly by DANAK.

Separately, RvA, the Dutch National Accreditation Body, confirmed to JaSCA on 2 October that Audit Independer Group itself is not accredited by RvA.

The factual position currently established is therefore: (1) the Green Key scheme has completed DANAK evaluation; (2) DANAK has not accredited a certification body for certification according to the Green Key scheme; and (3) Audit Independer Group itself is not accredited by RvA.

The replies make clear that DANAK’s evaluation of the Green Key scheme itself and external substantiation of the competence and independence of the Certification Body actually carrying out certification are separate matters that need to be assessed separately.

Article 2(r)(iv) requires monitoring of a trader’s compliance with scheme requirements to be carried out by a third party whose competence and independence are based on international, Union or national standards and procedures. Recital 7 gives compliance with ISO 17065 and mechanisms under Regulation (EC) No 765/2008 as examples.

At present, DANAK has confirmed completion of the Green Key scheme evaluation but has not accredited any certification body for certification according to the Green Key scheme, while RvA has confirmed that Audit Independer Group itself is not accredited by RvA. The core question is therefore what, separately from scheme evaluation, externally substantiates that Audit Independer’s competence and independence as the operating Certification Body are based on the standards and procedures required by Article 2(r)(iv). On the information currently available, there is a significant question as to whether Green Key’s current assurance structure satisfies that requirement.

ISO/IEC 17065 accreditation is not, however, the only route expressly contemplated by the Directive. Other international, Union or national standards and procedures may provide the required basis. JaSCA therefore does not at this stage make a final determination of legal non-conformity and continues to seek clarification from FEE / Audit Independer as to any such alternative basis.

(2) Middle layer — certification data

BeCause has explained to JaSCA which structured fields it holds and which information it does not hold. This makes it necessary to distinguish information available at Scheme Owner level from information retained at the data-distribution layer.

Under Travalyst’s initiative, schemes self-assess / self-declare, while Travalyst states that it does not itself assess or review certification schemes for Directive conformity. Inclusion in the Travalyst list is therefore not equivalent to independent third-party verification of Directive conformity.

(3) Downstream — OTA display

On 1 October and again on the morning of 2 October, Green Key-certified Booking.com property pages available for review continued to display:

“This property has 1 third-party sustainability certification”
“Green Key (FEE)”

Booking.com has told JaSCA that it recognises different assurance models among certification schemes but does not currently distinguish different assurance levels in traveller-facing display.

On the searchable consumer-facing pages reviewed, the Green Key / FEE name was visible, while some assurance-related attributes distinguishable upstream were not visible. This observation is limited to searchable web display and does not determine what may be available in every interactive layer, app, API or other interface.

(4) Observation from the trace

In this case, multiple assurance-related facts and unresolved distinctions could be identified upstream, while the searchable consumer-facing display presented the certification generically as a “third-party sustainability certification”.

This observation does not itself determine legal compliance or non-compliance by Green Key or Booking.com. It records what remained visible when the same information chain was traced from upstream to the consumer-facing layer.

5. Potential minimum assurance metadata for further examination

The review suggests that consideration should be given to how far at least the following information should be retained and transmitted through the chain:

• scheme / certification name
• applicable criteria / scheme version
• certificate status
• certificate validity / expiry
• certification scope
• Certification Body
• audit / verification model
• status of CB accreditation or other external substantiation
• an identifier enabling the certificate or record to be uniquely checked
• transition status, where relevant

JaSCA is not at this stage presenting this as a legally mandatory dataset. Legal necessity, consumer relevance, implementation feasibility and data minimisation should be considered separately.

6. Update of the six Open Questions from 25 September

Q1. What do OTAs verify before displaying a sustainability label?
Status: Partly resolved.

European Commission FAQ material has made clearer the direction that the displaying trader should check the scheme’s publicly available terms. However, JaSCA has not yet fully established the evidence, criteria and procedures used by each OTA to verify the underlying Article 2(r) conditions for each scheme.

Q2. How much assurance metadata is retained and transmitted?
Status: Partly resolved.

BeCause has explained structured fields it holds and fields it does not hold, and examples confirm that detailed data exist at Scheme Owner level. A complete field-by-field trace from scheme / CB through intermediary to OTA and consumer has not yet been established.

Q3. How are different assurance levels treated in OTA / consumer-facing display?
Status: Partly resolved / consumer-facing differentiation remains limited.

Booking.com has told JaSCA that it recognises differences among assurance models but does not currently distinguish different assurance levels for travellers. The 1 October display observation likewise showed Green Key presented generically as a “third-party sustainability certification”. The minimum information needed for consumers to distinguish meaningful differences in assurance remains unresolved.

Q4. What supported continued Green Key certificate / label use during 27–30 September?
Status: Still open / transition-specific issue.

The new system and transition rules from 1 October are now more specific. However, the public information reviewed does not sufficiently identify which standards / procedures substantiated the competence and independence of the monitoring body, in relation to Article 2(r)(iv), for continued use of existing certificates / labels during 27–30 September.

Q5. How do DANAK scheme evaluation / approval, external substantiation of the new CB, and transition of existing certificates connect?
Status: Partly resolved / factual status clarified; significant conformity question remains.

DANAK’s direct reply of 2 October confirmed that evaluation of the Green Key certification scheme has been completed and that the scheme was found aligned with ISO/IEC 17065:2012 and suitable for accreditation. DANAK also confirmed that it has not accredited any certification body for certification according to the Green Key scheme. Separately, RvA confirmed that Audit Independer Group itself is not accredited by RvA. The factual distinction between scheme evaluation and CB accreditation is therefore now clear. In light of Article 2(r)(iv), which requires the third party’s competence and independence to be based on international, Union or national standards and procedures, the information currently available raises a significant question as to whether Green Key’s current assurance structure satisfies that requirement. Because ISO/IEC 17065 accreditation is not the only possible route contemplated by the Directive, JaSCA does not make a final determination of legal non-conformity at this stage and continues to seek clarification of any other applicable standards or procedures.

Q6. What transition guidance applies to Green Key-certified establishments in Japan?
Status: Still open.

JARTA continues to be listed as the Green Key National Operator for Japan and publishes Japanese certified establishments. In the public information reviewed, JaSCA did not identify specific Japan-facing guidance explaining label use, renewal, and transition from the former system after 27 September.

7. New questions arising as of 1 October

1. How should Green Key’s public descriptions of DANAK status now be updated and aligned with DANAK’s direct confirmation of 2 October?
2. Is further factual clarification needed on the timing and scope of DANAK’s completed scheme evaluation?
3. Which standards and procedures substantiate Audit Independer’s competence and independence for the purposes of Article 2(r)(iv)?
4. What minimum assurance metadata should be retained from Green Key / Audit Independer through to OTAs?
5. How should certificates issued under the former system be identified in downstream data during transition?
6. What transition guidance has been provided to Japanese certified establishments?
7. What underlying data support an OTA classification such as “third-party sustainability certification”?

8. Current significance — three conclusions

Three points are important at this stage.

First, determining whether a scheme is eligible for display is not the same as ensuring that consumers receive information enabling them to understand meaningful differences in assurance.

legal eligibility
≠
meaningful consumer information

Second, in the Green Key trace, some assurance-related information distinguishable upstream was not visible in the searchable consumer-facing display. This does not itself establish non-compliance, but it indicates the need to examine end-to-end traceability of assurance information.

Third, the next stage of review should examine not only individual scheme conformity but the full chain — Scheme → Certification / Assurance → Data intermediary → Trader / OTA → Consumer — to determine which assurance metadata are retained, updated and transmitted, and whether consumers can distinguish meaningful differences in assurance strength.

The 27–30 September Green Key transition period remains recorded because it was an Open Question established on 25 September, but it is treated as a transition-specific issue separate from the broader structural questions above.

9. Additional findings on the morning of 2 October

(1) Effective date and system reopening

Green Key’s 2026–2031 Criteria and new Certification Process apply from 1 October. Green Key International stated in an automatic reply that its worldwide offices were closed through 1 October and that the application tool would reopen on 2 October with the new criteria. This Update therefore distinguishes the institutional effective date from the practical reopening of the application system.

(2) FEE’s previously published plan

In its official year-end article of 15 December 2025, Green Key / FEE stated that in 2026 it would seek DANAK scheme approval and that FEE would seek accreditation of its certification body.

As of 2 October, Audit Independer is identified as the new Certification Body and the new certification process has begun. DANAK has now confirmed completion of the Green Key scheme evaluation and that it has not accredited any certification body for certification according to the Green Key scheme, while RvA has confirmed that Audit Independer Group itself is not accredited by RvA.

This means that Certification Body accreditation is not an issue introduced retrospectively by JaSCA; FEE itself identified it as part of its 2026 transition plan.

(3) Certified-establishments list

On the morning of 2 October, Green Key’s official certified-establishments list continued to display “last update 25 September 2026”. The page states that the list is updated monthly.

The public list therefore does not yet enable a downstream user to distinguish establishments certified under the former system from establishments that may subsequently be certified under the new system. This does not itself establish non-compliance, but it makes the questions of certificate provenance, scheme version and validity more concrete.

(4) Booking.com display

On the morning of 2 October, Green Key-certified property pages available for review on Booking.com continued to use the presentation “This property has 1 third-party sustainability certification” / “Green Key (FEE)”. The searchable display did not allow JaSCA to distinguish the former / new certification process, Certification Body, scheme version, certificate validity or accreditation status.

(5) Primary factual enquiries

On 1 October, JaSCA requested factual clarification from FEE / Audit Independer, DANAK and RvA. On 2 October, substantive direct replies were received from DANAK and RvA as described above. An automatic transition-related response was received from Green Key, while a substantive response from FEE / Audit Independer on external substantiation of the Certification Body remains under review.

10. Next checks

Following publication, JaSCA will continue checking the unresolved institutional, accreditation, Japan-transition, Travalyst, OTA-display and assurance-metadata questions identified in this Update.

This Update records differences identified from public information and information received by JaSCA through the morning of 2 October 2026. It should be read together with the Interim Review published on 25 September 2026.