About this guidance
You will need to comply with the UK ETS as soon as you become an aircraft operator. This guidance will help aircraft operators understand and comply with their obligations under the UK ETS. These obligations are set out in full in The Greenhouse Gas Emissions Trading Scheme Order 2020 No.1265 the Order. If you need to comply with the UK ETS, you must
monitor your aviation emissions for each scheme year, which runs from 1 January to 31 December
report your aviation emissions by 31 March in the following year
Aviation emissions are emissions of carbon dioxide CO2 arising from an aviation activity within the scope of the UK ETS. You must then surrender a number of allowances equal to your aviation emissions by 30 April in the following year. This guidance explains how to carry out these steps. If you do not comply with the UK ETS requirements you may have to pay significant civil penalties. If you are not sure about your obligations, or any aspect of this guidance, please contact your regulator. If you are or expect to be regulated by the UK under the Carbon Offsetting and Reduction Scheme for International Aviation CORSIA, you should also refer to the guidance for the CORSIA. Work out if the UK ETS applies to you
You will need to work out whether you are an aircraft operator under the UK ETS. You will be an aircraft operator if you are performing an aviation activity and have annual emissions from full-scope flights above the threshold that applies to you. There are different thresholds for commercial or non-commercial air transport operators. If you use the Eurocontrol Small Emitters Tool SET to determine if your full-scope flight emissions are above the relevant threshold, you must use the SET in line with the guidance produced by Eurocontrol. In particular, the distance entered for each aerodrome pair in the SET must be the most accurate measurement of actual ground flight track distance. It is not appropriate to apply the great circle distance plus 95 kilometres method for all your flights when assessing the emissions from your full-scope activity using the SET. Your regulator has access to the Eurocontrol Support Facility ETS-SF, which uses the most accurate distance data available. Your regulator will use the ETS-SF when assessing whether you have an obligation under the UK ETS. Aviation activity
An aviation activity is a flight, other than an excluded flight, that departs from an aerodrome in the UK and arrives in an aerodrome in
the UK England, Northern Ireland, Scotland, and Wales
an European Economic Area EEA state excluding outermost regions
Gibraltar
an offshore structure in the continental shelf of the UK
an offshore structure in the continental shelf of an EEA state
Switzerland
An aviation activity also includes any flight arriving at an aerodrome in the UK from an aerodrome in Gibraltar. See The Greenhouse Gas Emissions Trading Scheme Order 2020 for full details about aviation activities and excluded flights.
Full-scope flights
Full-scope flights are those departing from or arriving in an aerodrome in the UK, Gibraltar, an EEA state including its outermost regions or Switzerland other than an excluded flight. The EEA states are
The Basel-Mulhouse-Freiburg aerodrome LFSB and LSZM is in French territory. The following are the EEA states outermost regions
the Canary Islands
French Guiana
Guadeloupe
Mayotte
Martinique
Réunion
Saint-Martin
the Azores
Madeira
Threshold for commercial air transport operators
You are not an aircraft operator during a scheme year if you either
operated fewer than 243 full-scope flights in a 4-month period, for 3 consecutive 4-month periods
operated full-scope flights with total annual emissions of less than 10,000 tonnes of CO2
Threshold for non-commercial air transport operators
You are not an aircraft operator if during a scheme year you operated full-scope flights with total annual emissions of less than 1,000 tonnes of CO2. Excluded flights
Flights by both fixed-wing and rotary-wing aircraft are excluded if the aircraft have a certified maximum take-off mass of less than 5,700 kilograms. Several other types of flights are excluded from UK ETS, including military, search and rescue, firefighting and humanitarian flights. The full list of excluded flights is set out in schedule 1 of the Order. Contact your regulator if you are unsure whether you are an aircraft operator. If you think you may be an aircraft operator and have obligations under the UK ETS, you must first contact your regulator. You must submit an emissions monitoring plan application within 42 days of the date you became an aircraft operator. If you miss this deadline you should contact your regulator as soon as possible. UK ETS regulators
There are 4 regulators for aircraft operators regulated under the UK ETS. You are assigned a regulator based on the location of your registered office or place of residence. For
England and outside the UK the Environment Agency is the regulator, email etaviationhelpenvironment-agency.gov.uk
Northern Ireland the Northern Ireland Environment Agency is the regulator, email emissions.tradingdaera-ni.gov.uk
Scotland the Scottish Environment Protection Agency is the regulator, email emission.tradingsepa.org.uk
Wales Natural Resources Wales is the regulator, email ghghelpcyfoethnaturiolcymru.gov.uk
If your registered office or place of residence is outside the UK, you may be transferred to another UK ETS regulator other than the Environment Agency. This will depend on the location of the departure aerodromes for the flights that generated most of your aviation emissions during the 2023 and 2024 scheme year. Any such transfer will happen at the start of the 2026 scheme year, following the end of the first allocation period on 31 December 2025. When you contact your regulator, you will need to provide the
aircraft operator name full legal entity name, or individual
aircraft operator code this is your Central Route Charges Office CRCO number
You will also need to provide the following details for your primary contact responsible for UK ETS compliance
first name and surname
telephone number
email address
Your METS online account
Once you have provided the information your regulator needs, they will set up your account in the Manage your UK Emissions Trading Scheme reporting service known as METS. When this is done, METS will provide you with login instructions. Your regulator manages applications, variations and report submissions through METS. METS
allows you to send notifications to and receive them from your regulator
sends you reminders of actions you must or may need to take
allows you to submit your annual emissions report, and if required, your verification report
allows you to submit your improvement report if required
allows you to make applications to vary change your emissions monitoring plan
The forms in METS are designed to help aircraft operators provide the required information. They include guidance on how to complete specific fields within the forms. Where available, the forms also provide references to additional guidance documents or legislation. Apply for an emissions monitoring plan
This section is only relevant if you need to apply for an emissions monitoring plan. If you were administered by the UK under the EU ETS and you hold an EU ETS emissions monitoring plan, you must not apply for one in METS, unless you have been told to do so by your regulator. If you think you have UK ETS obligations please contact your regulator as soon as possible. If you do need to apply for an emissions monitoring plan, access your account in METS using the login details provided by your regulator. The task to complete your emissions monitoring plan application will appear in your work queue. You must use the online form to complete and submit your emissions monitoring plan. Guidance in the form will help you provide the right information. You must submit your emissions monitoring plan application within 42 days of becoming an aircraft operator. If you cannot meet or have missed this deadline, you must contact your regulator. If you are submitting your emissions monitoring plan application after the deadline, you must explain why in the application form. You can find more detailed guidance about emissions monitoring plans in the Monitoring and Reporting Regulation as amended by schedule 4 of the Order.
Paragraph 26 in schedule 4 provides additional details if you intend to use a fuel use monitoring method. Submitting applications to your regulator
You must submit any application to your regulator
through METS this will ensure you provide the information needed
with payment of any fee required
Any application you submit to your regulator is not duly made until you have
provided all the information required
submitted the application form
paid any fee required
You can find the fees for each UK ETS regulator on their website
England Environment Agencys ETS charges
Scotland Scottish Environment Protection Agencys ETS charges
Wales Natural Resources Wales ETS charges
Northern Ireland Northern Ireland Environment Agencys ETS charges
Your regulator must usually determine an application within 2 months of the date it was duly made, unless you agree to a longer period. After submitting your application
Once you have submitted your application, METS tells you about the application fee and how to pay. Your regulator will assess your application and contact you if they need more information. Issue your emissions monitoring plan
Once your regulator has approved your application, they will issue your emissions monitoring plan. It details how you must monitor and report your aviation emissions in line with the requirements of the Order. You must comply with the conditions of your emissions monitoring plan. It is important that you read and understand your emissions monitoring plan. The introductory note and conditions will help you comply with UK ETS requirements. Changes to your emissions monitoring plan
You must tell your regulator about any non-significant changes to your emissions monitoring plan through METS. You must do this by 31 December in the year the change was planned or has happened. If you want to make a significant change to your emissions monitoring plan, you must apply to your regulator through METS to vary it. You must do this at least 14 days before you make the change.
If this is not practicable, you must do it as soon as possible afterwards. See the section on Making changes. Opening your aircraft operator holding account in the UK ETS Registry
The UK ETS Registry is where UK ETS allowances are allocated, traded and surrendered. All these transactions are recorded in the UK ETS Registry. The UK ETS Authority is the central administrator of the UK ETS Registry. Day-to-day administration is carried out by the registry administrator a role currently performed by the Environment Agency. The UK ETS Authority is made up of the UK government and the other national authorities. Together they oversee the UK ETS. Once your regulator has issued your emissions monitoring plan, they will instruct the registry administrator to open your aircraft operator holding account AOHA in the UK ETS Registry. Once your AOHA is open, the registry administrator will send you an email with your account details and assist you to appoint a primary contact and at least one authorised representative. The charge for your emissions monitoring plan application includes the costs of appointing one authorised representative with a permission to surrender allowances or return any over-allocated free allowances. You can apply to the registry administrator to expand the permission of your initial authorised representative or appoint additional authorised representatives.
This would be subject to a fee. Free allocation of allowances
Aircraft operators that are entitled to free allowances during the 2021 to 2025 allocation period will receive their allocation in their AOHA by 28 February in each scheme year in line with the free allocation entitlement set out in the Aviation Allocation Table AAT. There will be no free allocation of allowances to aircraft operators in the allocation period which starts on 1 January 2026. The free allocation entitlements set out in the AAT are approved by the UK ETS Authority. Any change to your free allocation entitlement in the AAT must be approved by the UK ETS authority for example, if there is a business reorganisation.
You are not entitled to receive a free allocation for a scheme year in which you were not an aircraft operator. You must return any allowances that you should not have received, for example
Complete your compliance tasks
You must complete your UK ETS compliance obligations by any deadlines specified in the Order or your emissions monitoring plan. If you do not, you may have to pay a civil penalty. Not an aircraft operator in a scheme year
You are not an aircraft operator in a scheme year if
you have not performed an aviation activity during the scheme year
your full-scope number of flights or emissions are below the applicable thresholds
This means you will have no monitoring, reporting or surrender obligations for that scheme year. If the AAT shows that you have a free allocation entitlement you will not receive any free allowances for that scheme year. Your regulator will change the status of your reporting requirements in your METS account to exempt if
you inform your regulator that you have not performed an aviation activity or are below the relevant thresholds during a scheme year
your regulator identifies you are exempt using Eurocontrol data
If you think that the change in your account status is incorrect, you must inform your regulator as soon as possible. Annual tasks and compliance deadlines
1 January start monitoring your emissions for the current scheme year
by 28 February if required, apply to your regulator to allow your verifier to carry out a virtual site visit for the previous scheme year
28 February receive any free allowances you are entitled to for the current scheme year
by 31 March submit your verified annual emissions report for the previous scheme year using METS your regulator will then instruct the registry administrator to record the verified aviation emissions figure from your annual emissions report in your AOHA
by 30 April surrender a number of allowances equal to your aviation emissions in the previous scheme year
by 30 June submit an improvement report if applicable
July consider appointing your verifier for the current scheme year if applicable
October if reporting using simplified reporting procedures, consider applying for your data from Eurocontrol
31 December notify your regulator about any non-significant changes to your emissions monitoring plan
31 December complete your monitoring for the current scheme year
Monitor your emissions
You must monitor emissions from your aviation activities from 1 January to 31 December in each scheme year in which you are an aircraft operator. Your monitoring requirements are set out in
your emissions monitoring plan including any supporting written procedures
the Monitoring and Reporting Regulation as amended by schedule 4 of the Order
Emissions data collected during your monitoring is used when preparing your verified annual emissions report. You must submit this report by 31 March in the following scheme year. Prepare your annual emissions report
You should start to prepare for the reporting process during the final quarter of the scheme year. You must submit your report by 31 March in the following year. Preparing early should
give you enough time to choose and appoint an independent verifier if required
allow your verifier enough time to perform the verification
enable you and your verifier to address any errors or misstatements
submit your report and verification report to your regulator by the 31 March deadline
The task to compile your annual emissions report will appear in your METS reporting work queue on 1 January in the following year. This task contains the emissions report form.
You should round all data, as specified in article 72 of the Monitoring and Reporting Regulation as amended by schedule 4 of the Order. Making an emissions reduction claim
If you have compliance obligations in a scheme year and are purchasing eligible sustainable aviation fuels SAF, you may be able to reduce both
your aviation emissions figure
the corresponding number of allowances you are required to surrender
You can do this by making an emissions reduction claim ERC when you submit your annual emissions report to your regulator in METS. Before you make an ERC, your emissions monitoring plan must be varied. Contact your regulator, who will send you
additional guidance
an emissions reduction claim methodology form for you to complete and attach to your emissions monitoring plan variation application
To make a successful ERC, you must be able to show that you have met all the following criteria
the fuel you have purchased is eligible SAF
the purchase has taken place in the scheme year or in the 3 months before the start of the scheme year
the eligible SAF has been delivered to an aerodrome fuelling system or one of your aircraft before the 31 March reporting deadline for the scheme year
the eligible SAF has not been used by you to obtain an emissions reduction or financial benefit in any other scheme or been sold by you to a third party
your ERC has been verified
If your regulator is not satisfied that you have met these criteria
part, or all of your ERC will be rejected
they will determine your aviation emissions for the scheme year
Record keeping and audits
Regulators can carry out periodic audits of annual emissions reports. You must keep records of all relevant data and information for at least 10 years to comply with article 67 of the Monitoring and Reporting Regulation as amended by schedule 4 of the Order. In practice this requirement runs for 10 years from the date you submit your report and includes data used in preparing the report even though this will be more than 10 years old. Using simplified reporting procedures
To compile a verified report of aviation emissions you have the option to use simplified reporting procedures instead of appointing an independent verifier if your emissions are either or both
less than 25,000 tonnes of CO2 per year from full-scope flights
less than 3,000 tonnes of CO2 per year from aviation activities
If you are using the simplified reporting procedure, you must
purchase a draft report of your emissions from the Eurocontrol Support Facility ETS-SF
compare the report with your own flight records, and, if it is correct, use the data from the ETS-SF to populate your report in METS
When you use flight data from the ETS-SF, it is your responsibility to check that it is accurate, using your own internal flight records. If the ETS-SF data is incorrect, you must contact Eurocontrol and ask them to correct any errors in the data before you use it for the simplified reporting procedures. To make sure there is enough time for any necessary changes before the reporting deadline, you should request a draft emissions report from Eurocontrol in October of the scheme year. They will tell you about any updates to data in the ETS-SF. If you wait for Eurocontrol to release the data in the February following the scheme year, there may not be enough time to correct any errors in the ETS-SF data. You may then need to use an independent verifier to avoid the risk of reporting an inaccurate aviation emissions figure, and failing to surrender sufficient allowances as a result. If you qualify as a small emitter, alternatively you can also use the Eurocontrol Small Emitters Tool SET populated with your own flight data to calculate your aviation emissions. A small emitter is an aircraft operator who has either
Using the SET may be appropriate where ETS-SF data does not accurately reflect your aviation activity. If you use the SET, you must have your emissions report verified by an accredited independent verifier. If you use the SET, you must use it in line with the guidance produced by Eurocontrol. In particular, the distance entered for each aerodrome pair must be the most accurate measurement of actual ground flight track distance. Appointing an independent verifier
You must appoint an independent verifier to verify your emissions unless you are eligible to use simplified reporting procedures and choose to do so. You must always use an independent verifier to verify any ERC. Your chosen verifier must be accredited by the United Kingdom Accreditation Service UKAS for the regulated activity you are reporting. You must provide your verifier with all the information they need to perform the verification.
Your verifier will be able to explain what they need, but you can also find a list of the minimum information required in article 10 of the Accreditation and Verification Regulation as amended by schedule 5 of the Order. When verifying your annual emissions report, your verifier will assess your
monitoring methods
information, data and calculations
procedures
They are checking to make sure that the emissions data in your annual emissions report accurately represents the emissions that you are required to monitor. They are also checking that your reporting complies with your emissions monitoring plan and the Monitoring and Reporting Regulation as amended by schedule 4 of the Order. To help make sure you are ready to report your emissions by 31 March, you should appoint a verifier by July in the scheme year. This means your verifier can start the verification process as soon as possible. They can start to check the data you will need for compliance from the first 6 to 9 months of the scheme year.
This avoids a heavy workload in January or February the following year and possible delays in completing the verification process. There is a list of UKAS accredited verifiers in METS. If you are using a verifier that already has an account in METS, you can assign them to your METS account under the Users and contacts section and from the Select verification body drop-down list. If you are using a verifier that does not have an account in METS, please notify your regulator so they can be added to the system and you can assign them to your account. Find more information on verification and a list of UKAS accredited verifiers for UK ETS at
Participating in the UK ETS
UKAS
Site visits by your appointed verifier
Site visits are an important part of the annual verification process. Without a site visit, your verifier may not be able to give a positive verifier opinion statement. The Accreditation and Verification Regulation as amended by schedule 5 of the Order, defines a site as locations where the monitoring process is defined and managed, the locations where relevant data and information are controlled and stored. Site visits are about gathering evidence. They may involve interviewing staff and testing the effectiveness of internal processes and control procedures. Your verifier will carry out a risk analysis and decide how best to conduct the site visit. This means that your verifier does not necessarily need to visit every aircraft or aerodrome in person because the data is often centralised. It may be possible for your verifier to carry out a virtual site visit instead of attending in person. If you and your verifier would like a virtual site visit to be used for a scheme year, you must submit an application and provide supporting evidence to your regulator by 28 February in the year following the scheme year. If your regulator approves your application, it may impose conditions. If you are a small emitter your verifier may, based on their risk analysis, decide that a site visit is not required.
You can find more information about this in article 33 of the Accreditation and Verification Regulation as amended by schedule 5 of the Order. Submit your annual emissions report
By 31 March, you must submit your verified annual emissions report for the previous scheme year to your regulator using METS. If you have used an independent verifier, you must also submit their verification report containing their verification opinion statement using METS by 31 March. Both the annual emissions report and the verification report must meet the requirements of both the
Monitoring and Reporting Regulation as amended by schedule 4 of the Order
Accreditation and Verification Regulation as amended by schedule 5 of the Order
You need to follow these steps to submit your annual emissions report to your regulator. Complete the annual emissions report in METS. If you are eligible and have chosen not to use an independent verifier, go straight to step 4. You must then submit your annual emissions report to your chosen verifier for verification. Once the verification process is complete, your verifier will return the verified annual emissions report to you using METS. You must then submit your annual emissions report and the verification report to your regulator using METS. If you need to amend the emissions report after it has been verified, you will need to re-submit it to your verifier for re-verification before submitting it to your regulator. Your report has not been formally submitted until you have completed step 4. METS will provide you with step by step guidance to help you complete and submit your emissions report. If you do not submit a verified annual emissions report by 31 March that meets all the requirements of the Monitoring and Reporting Regulation as amended by schedule 4 of the Order, your regulator will determine your aviation emissions in line with the Order. They are entitled to recover their costs for doing this work. You may also receive a civil penalty. Aviation emissions recorded in the UK ETS Registry
If you reported correctly by the 31 March reporting deadline, your verified aviation emissions figure will be recorded in your AOHA
If you do not report by the deadline, or there are errors in your report or they way you reported, your regulator will determine your emissions and this figure will be recorded in your AOHA within one month of the date of the notice of determination of emissions. Surrender allowances by 30 April
You must surrender allowances by 30 April in the year following a scheme year in which you were an aircraft operator with a surrender obligation. For each scheme year you must surrender a number of allowances equal to your aviation emissions in that scheme year. It is your responsibility to make sure the required number of allowances are available in your AOHA so that your authorised representative or representatives can surrender sufficient allowances by the 30 April deadline. You must surrender allowances equal to your aviation emissions by 30 April even if
If you fail to surrender allowances equal to your aviation emissions by the 30 April surrender deadline you will be liable to civil penalties. In preparation for surrender, you should
If you need to buy allowances, you should contact your supplier early enough to make sure that allowances are available in your AOHA in time for you to surrender by the 30 April deadline. You must allow time for
The delivery of allowances to your AOHA by your supplier will be affected by automatic transaction windows and delays over which the registry administrator has no control. It is only possible to start or complete a transfer of allowances during the transaction window, which is
You should also be aware that
You should check with your supplier when the allowances will reach your AOHA. The transaction window and transaction delay do not apply to surrender transactions, which can be made at any time. Buying allowances
If you do not have sufficient allowances available to meet your surrender obligation, you must buy the allowances you need on the carbon market. You can buy them
A list of UK ETS Registry Account Holders from whom you may be able to purchase allowances can be found in the UK ETS Public Reports. Auctions take place at set dates each year. The most up to date information about auctioning is in the guidance about participating in the UK ETS. Civil penalties
If you do not surrender the required number of allowances by 30 April for the previous scheme year, you will receive a mandatory excess emissions penalty of 100 per tonne of CO2 multiplied by the inflation factor. This penalty will apply even if you surrender in full after the 30 April deadline. Paying the excess emissions penalty does not release you from the requirement to surrender a number of allowance equal to your aviation emissions in a scheme year.
The regulator may also impose civil penalties if you do not comply with other obligations under the Order.Annex 2 of the Environment Agency enforcement and sanctions policy has more information on civil penalties. Improvement reports
You must submit a verifier recommended improvement report if your verification report
recommends improvements
identifies non-conformities with your emissions monitoring plan
METS will automatically generate an improvement report task if this is the case. You must submit your improvement report by 30 June in the year you submitted the annual emissions report. The improvement report must describe how and when you will
address the non-conformities
implement the recommended improvements
It may be necessary for you to vary your emissions monitoring plan. If you think the recommended improvements would not improve the monitoring methodology or would result in unreasonable costs, you must explain why. You must also provide supporting evidence for your reasons in your improvement report. Making changes
This section explains when you need to apply to vary your emissions monitoring plan because of changes you have made or are going to make to your aviation operation, and the steps you need to take. You should regularly check your emissions monitoring plan to
make sure it reflects the nature of your aviation operations
assess whether you can improve the monitoring methodology
You should also regularly review your internal risk assessment processes to check whether
the risks that you initially identified have changed
control measures you have put in place are still effective
If you are intending to make one of the following significant changes, you must apply to vary your emissions monitoring plan to your regulator in METS at least 14 days before
changing the emission factor values
changing the methodology you use to calculate an emissions factor
changing your fuel use monitoring methodology
changing from a fuel use monitoring methodology to an estimation methodology or the other way around
introducing a new fuel type, including a sustainable aviation fuel
changing your small emitter status or crossing a threshold that is relevant for determining whether you can use simplified reporting procedures
You must also apply to your regulator in METS at least 14 days before
changing the name of your legal entity
changing your registered office address
You may need to pay a fee for making a significant change. You must inform your regulator about any other changes that affect your emissions monitoring plan by 31 December in the year the change was made or planned. Please contact your regulator if you have made or are planning any other changes to your aviation operations, monitoring methodology or procedures as set out in your emissions monitoring plan. Its helpful to provide details of the change and how it affects the information in your emissions monitoring plan. Your regulator will then be able to advise whether you should apply to vary your emissions monitoring plan. You can monitor and report on the basis that your emissions monitoring plan contains your proposed variations before they are approved by your regulator if
the proposed change is not significant
your current emissions monitoring plan would lead to incomplete emissions data
If you are concerned that your current emissions monitoring plan would lead to incomplete emissions data, you must monitor and report based on both
your current emissions monitoring plan
an emissions monitoring plan containing the proposed variations
You must make sure all your emissions monitoring is documented until your regulator has approved the proposed variation to your emissions monitoring plan. Business reorganisation
You must notify your regulator and the registry administrator as soon as possible if the aircraft operator has gone through, or is going through, a business reorganisation. Business reorganisation refers to any change in corporate structure that results in the transfer of the aviation business of an existing aircraft operator to another new or existing aircraft operator. This includes any
split
merger
acquisition
consolidation
Following a business reorganisation
you may need to vary an existing emissions monitoring plan or apply for a new emissions monitoring plan
any free allocation you may be entitled to may need to be adjusted or transferred
Unhappy with a decision
If you are unhappy with a decision your regulator has made, please discuss it with them first. Where you have a right of appeal against the regulators decision, this will be set out in the notice containing the decision. The notice will also provide information about how to appeal. In the case of an appeal against a decision of
the Scottish Environment Protection Agency the appeal body is the Scottish Land Court
the Chief Inspector Northern Ireland the appeal body is the Planning Appeals Commission
any other regulator the appeal body is the first-tier tribunal
If you are unhappy with the performance or any decision of your verifier, please discuss it with them first. Clause 7.12.11 of EN ISOIEC 17011 requires national accreditation bodies to allow the accredited verifier the opportunity to deal with complaints before the national accreditation body intervenes. If you are still not satisfied, you should contact UKAS and also inform your regulator.