Before a refiner or trading house will contract with a new counterparty, it runs you through onboarding, and until that clears, nothing moves. In practice it is a document pack: company registration and ownership, VAT and tax identifiers, bank details confirmed by the bank rather than by email, identification of the people who own and sign for the company, a sanctions and adverse-media screen, and for this trade the certification and licences that cover what you are selling. Expect it to take weeks rather than days at a large buyer, and expect it to run alongside the commercial conversation instead of after it. The single most useful thing you can do is have the pack assembled before anyone asks: the delays we see are almost never refusals, they are a missing document and a person on holiday. Once you are through at one major, say so, being cleared elsewhere is a real reference and counterparties treat it as one.
- 1You send the facts
- 2We test the market
- 3We introduce
- 4You contract directly
- 5We stay reachable
We never take title, so the contract is always between you and the counterparty.
What is actually in the pack
The list varies by buyer, and a large refiner asks more than a regional biodiesel producer. What follows covers most of what gets requested, and having it in one folder turns a three-week exchange into a single email.
Two of these catch people out. Bank details are almost never accepted on an emailed letterhead any more, because that is exactly what invoice fraud looks like; expect a bank-issued confirmation or a verification call. And ownership goes further than the company register: the question is who ultimately owns and controls the company, which for a holding structure means walking up the chain.
- Company registration: an extract from the commercial register, recent rather than filed away from three years ago.
- Ownership and control: shareholders, and the ultimate beneficial owners behind any holding company.
- Identification of directors and authorised signatories, and evidence of who may sign what.
- Tax and VAT identifiers, valid and matching the entity that will invoice.
- Bank details, confirmed through the bank rather than by email.
- Sanctions and adverse-media screening, run by the buyer on the company and the people behind it.
- Certification in scope for the product and activity, ISCC, REDcert or another recognised scheme, with the annex that names the products.
- Licences and permits where the material is a waste stream: collection, transport and, for cross-border movements, the notification paperwork.
- Insurance and, for larger volumes, financials, recent accounts or a credit reference.
Why it stalls, and it is rarely a refusal
When onboarding drags, the cause is nearly always mechanical rather than a judgement about you. The three we see most:
The pattern behind all three is the same: nobody owns the process on the supplier side. One named person who keeps the folder current and answers within a day makes more difference than anything else.
- A mismatch between entities. The company on the offer is not the company on the certificate, or not the one that will invoice. Every such difference has to be explained, and each explanation costs a round trip.
- A document that has expired. A certificate renewed but not sent, a register extract from two years ago, a signatory who has left.
- Nobody chasing it. The buyer's compliance desk is not going to hunt you down. A form sitting half-completed in somebody's inbox is the most common reason a first cargo slips a month, and it shows up in our own correspondence in exactly those words.
Start it in parallel, not afterwards
The instinct is to agree the trade first and do the paperwork once there is something to paper. In this market that costs you the cargo, because the window on a parcel is shorter than the onboarding.
Ask early and directly: *what does your onboarding need from us, and how long does it normally take?* A buyer will tell you, and the answer lets you run the two tracks side by side. It also signals that you have done this before, which is itself part of what they are assessing.
Where a first parcel is time-critical, some buyers will accept a lighter check for an initial trade and complete the full file afterwards. That is their call, not yours, but it is worth asking rather than assuming.
Being cleared somewhere is worth saying
Onboarding is not transferable, every buyer runs its own, but it is a reference. A supplier who has passed the checks at a European major has demonstrably survived a serious file review, and counterparties read it that way.
So say it, plainly and without naming anything you are not free to name: which kind of counterparties have onboarded you, and roughly when. It shortens the conversation and it is the sort of thing a smaller supplier undersells. We have seen it written exactly like that in a first email, and it worked.
What the buyer is actually assessing
It helps to understand what the file is for. A compliance desk is answering three questions, and everything on the list serves one of them.
Notice what is not on that list: whether they like your price. Onboarding runs on a different track from the commercial conversation and is decided by different people, which is why pushing your trader contact rarely speeds it up.
- Are you who you say you are, and is the entity that signs the same one that ships and invoices?
- Is it lawful to trade with you, under sanctions rules and the buyer's own policy, including the people behind the company?
- Can you deliver what you claim, with certification that actually covers the product and the activity, that last part is where scope problems surface, see what your ISCC certificate covers.
Where we sit in it
We are not a compliance service and we do not vet anyone on a buyer's behalf. What we do is know what each type of counterparty asks for, so the question does not arrive as a surprise, and keep both sides moving while the file is with the compliance desk.
Practically: we tell you what to have ready before an introduction, we flag the entity and scope mismatches that stall files before they are sent, and when onboarding goes quiet we ask. That is unglamorous and it is where a fair number of first cargoes are saved.
Frequently asked questions
What documents do I need for KYC as a supplier?
Typically a recent commercial register extract, ownership down to the ultimate beneficial owners, identification of directors and authorised signatories, valid tax and VAT identifiers matching the invoicing entity, bank details confirmed through the bank, and your certification with the annex that names the products. For waste streams add collection and transport permits, and for cross-border movements the notification paperwork. Larger volumes often bring a request for recent accounts or a credit reference.
How long does onboarding take at a large buyer?
Weeks rather than days, and longer if anything has to be chased. The review itself is not slow; the round trips are. Every mismatch between the entity on the offer, the certificate and the invoice costs another exchange, and a half-completed form sitting in somebody's inbox costs the most of all.
Can I start trading while KYC is still running?
That is the buyer's decision, not yours. Some will accept a lighter check for a first parcel and complete the full file afterwards; others will not move at all. It is worth asking rather than assuming, and worth asking early, because the window on a parcel is usually shorter than the onboarding.
Why does the buyer want to know who owns my company?
Because sanctions rules and their own policy apply to the people behind a company, not only to its name. A company register shows the immediate shareholder; the question is who ultimately owns and controls it, which for a holding structure means walking up the chain until you reach people.
Does being KYC cleared at one buyer help with another?
It does not transfer, every counterparty runs its own, but it is a real reference. Passing a serious file review at a European major says something, and counterparties read it that way. Say so in a first email; smaller suppliers consistently undersell this.
Why is my bank letter not accepted?
Because an emailed letterhead with account details is exactly what invoice fraud looks like, and buyers have been burned. Expect a confirmation issued by the bank itself or a verification call to a number the buyer looks up independently. It is not a comment on you.
The company on my certificate is not the company that invoices. Is that a problem?
Yes, and it is the single most common reason a file stalls. It is usually explainable, a group structure, a trading entity alongside a production entity, but it has to be explained, in writing, with the relationship documented. Raise it yourself before the compliance desk finds it.
Can you get us through a buyer's onboarding?
No, and nobody outside that buyer can. Their compliance desk decides and it decides independently of the commercial conversation. What we do is tell you what they will ask before they ask it, flag the entity and scope mismatches that stall files, and keep the process moving when it goes quiet.
What if I am a small company with large volume?
Say so, with the volume and the counterparties that have already onboarded you. Size is not the test; the file is. Plenty of small companies move serious tonnage and clear onboarding at majors, and a compliance desk is looking at whether your documents hold together, not at your headcount.
Does certification replace KYC?
No. They answer different questions. Certification says the material and the chain meet a scheme's requirements; onboarding says the buyer knows who you are and may lawfully trade with you. You need both, and a certificate whose scope does not cover the product will fail the second check even though it passed the first.
Market news
Recent headlines from across the feedstock and renewable fuel sector. Nothing specific to this market has come through the wires lately, so this is the wider view. The links go to the publisher; we do not host or edit their reporting, and a headline here is not our endorsement of it. Scroll for more.
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18 headlines, updated automatically. Last refreshed .
Sources and further reading
Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.
Who to ask about KYC and onboarding
Just ask. Being onboarded and stuck on a question you cannot answer? Send us the form and we will tell you what they are actually asking for. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.
On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.
Happy to look at whatever you have, even if it is half an analysis and a question.
+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Ask about KYC and onboarding
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Or e-mail us directly: bart@sustainablecommodities.eu
Last reviewed 03 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.