How to Submit Attest Engagements

Below is a step-by-step process for attest auditors to submit attest engagement reports per Title 40 CFR part 1090 subpart S, 40 CFR 80.1464, and 40 CFR 80.1475.

Follow these steps to report.

STEP 1: Attest Auditors Must Register with EPA

Attest auditors must register their company in OTAQReg.

For more information, see: How to Register a New Company, Facility, or User for Part 80 Fuels Program.

STEP 2: Regulated Parties Must Associate with their Attest Auditor(s)

The regulated parties under 40 CFR part 80 and 40 CFR part 1090 must associate with their attest auditor(s) in OTAQReg. And attest auditor(s) mus approve regulated party associations.

For more information, see:

How to Associate Your Company with an Attest Auditor (pdf) (605 KB, February 2023, EPA-420-B-23-013)
How to Approve an Attest Auditor Association Request as Attest Auditor (pdf) (227 KB, February 2023, EPA-420-B-23-012)

STEP 3: Attest Auditor Users Must Have an Approved System Role to Submit Reports

The attest auditor must have a user that is registered and assigned the submitter role to submit attest engagement reports.

For more information, see: How to Become a Delegated User of a Registered Company in OTAQREG (pdf) (June 2018, EPA-420-B-18-032)

STEP 4: Determine Deadlines

Attest auditors must submit attest engagement reports by June 1.

Note: Attest engagements for obligated parties under the RFS program may have a different deadline. For more information, see: Reporting deadlines for Fuel Programs.

STEP 5: Read General Instructions for all Attest Engagements

Title 40 CFR part 1090 subpart S, and 40 CFR 80.1464 and 80.1475 contain attest engagement procedures and explain the qualifications of the attest auditor, applicable definitions, guidelines for sample sizes, and reporting and record retention requirements.

Attest auditors must include the following information in their attest engagement report:

The four-digit EPA company ID and company name of the regulated party
If the attest engagement report is specific to an individual facility (e.g., a gasoline refinery), include the five-digit EPA facility ID and facility name

EPA publishes updated registration information, including ID numbers, at Registered Companies and Facilities in Part 80 Fuel Programs.

For more information, see: 40 CFR part 1090 subpart S, 40 CFR 80.1464, and 40 CFR 80.1475.

STEP 6: Read Program-specific Instructions

In addition to the general instructions, each program has specific instructions. Attest auditors must conduct audits in accordance with the specific instructions outlined in the regulations.

For more information, click the tab above or go to: Program-specific instructions for attest engagements.

STEP 7: Attest Auditors Must Perform Attest Engagement

The attest auditor must perform attestation procedures and compile report(s).

STEP 8: Attest Auditors Must Submit Attest Engagement