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Data assimilation in conventional meteorological applications uses measurements in conjunction with a physical model. In the case of the ionised region of the upper atmosphere, the ionosphere, assimilation techniques are much less mature. The empirical model known as the International Reference Ionosphere (IRI) could be used to augment data-sparse regions in an ionospheric now-cast and forecast system. In doing so, it is important that it does not introduce systematic biases to the result. Here, the IRI model is compared to ionospheric observations from the Global Positioning System satellites over Europe and North America. Global Positioning System data are processed into hour-to-hour monthly averages of vertical Total Electron Content using a tomographic technique. A period of twelve years, from January 1998 to December 2009, is analysed in order to capture variations over the whole solar cycle. The study shows that the IRI model underestimates Total Electron Content in the daytime at solar maximum by up to 37% compared to the monthly average of GPS tomographic images, with the greatest differences occurring at the equinox. IRI shows good agreement at other times. Errors in TEC are likely due to peak height and density inaccuracies. IRI is therefore a suitable model for specification of monthly averages of Total Electron Content and can be used to initialise a data assimilation process at times away from solar maximum. It may be necessary to correct for systematic deviations from IRI at solar maximum, and to incorporate error estimation into a data assimilation scheme.