UK ETS Aviation Verification

Frequently asked questions

What is the UK emissions trading scheme (UK ETS)?

The UK ETS is the United Kingdom's emissions trading system. It operates on the cap-and-trade principle whereby organizations need emission allowances to cover their carbon emissions.

Which aviation activities are covered by the UK ETS?

The system applies to flights departing from the UK to:
- The UK itself
- EEA countries
- Gibraltar
- Switzerland
- Offshore installations on the continental shelf of the UK or an EEA state

What is an Emissions Monitoring Plan (EMP)?

An Emission Monitoring Plan describes how an airline monitors, calculates and reports its emissions in accordance with ETS regulations. This plan must be approved by the competent authority.

When is the emissions report due?

Operators must submit their verified annual emissions report (AER) annually through METS by March 31 of the following year.

What are the key deadlines under the UK ETS?

The main deadlines are
- February 28 - application for approval of a virtual site visit by the verifier
- March 31 - submission of verified emissions report
- April 30 - surrender of allowances
- June 30 - if necessary, submission of an improvement report

Can sustainable aviation fuel reduce emissions under the UK ETS?

Yes. Airlines can reduce emissions by using Sustainable Aviation Fuel (SAF) and submitting an Emission Reduction Claim (ERC), provided the relevant conditions are met.

How can Normec Verifavia help with UK ETS compliance?

Normec Verifavia supports airlines with:
- Verification of emissions reports
- Assessment of monitoring plans
- Support with reporting through METS
- Compliance with ETS regulations.

Which flight routes are covered by "UK ETS aviation activity"?

The UK ETS includes the following flights for which allowances must be surrendered:
- Domestic flights within the UK.
- Flights from the UK to airports within the European Economic Area (EEA)
- Flights between the UK and Gibraltar
- Flights departing from the UK to Switzerland
- Flights from the UK to areas of EEA member states, such as Ceuta and Melilla (Spain), the Åland Islands (Finland) and Jan Mayen (Norway)
- Flights to offshore installations

Please note that flights departing from crown dependent territories such as the Isle of Man, Jersey and Guernsey are not subject to the UK's ETS reporting requirements.

Which flights are excluded from reporting under UK ETS?

The following types of flights are excluded from UK ETS reporting requirements:
- Military flights
- Flights to transport a reigning monarch, head of state or head of government (outside the UK) on an official mission
- Customs and police flights
- Search and rescue operations
- Firefighting flights
- Humanitarian flights
- Emergency medical flights
- Flights conducted under visual flight rules (VFR)
- Circling flights without stopover
- Training flights for the purpose of obtaining a pilot's license or type rating
- Scientific research flights
- Test and certification flights of aircraft or equipment
- Flights performed by aircraft with a maximum take-off weight of less than 5,700 kg

Public Service Obligation (PSO) flights are also outside the scope of the ETS in the UK.

Does UK ETS have its own registry account?

Yes. The UK ETS registry is used for registration:
- Allocation of free allowances.
- Annual verified aviation emissions.
- Transfer of allowances
- Surrender of allowances.

Once the Emissions Monitoring Plan (EMP) is approved by the regulator, the registry administrator opens an Aircraft Operator Holding Account (AOHA). The operator is responsible for:
- Managing this account
- Appointing at least two authorized representatives

What exemptions and thresholds apply under the UK ETS?

Airlines may be exempt if they fall below certain thresholds. Commercial operators are exempt if they:
- Operate fewer than 243 flights per period (three consecutive four-month periods), or
- Emit less than 10,000 tons of CO₂ per year.

Non-commercial operators are exempt if they:
- Emit less than 1,000 tons of CO₂ per year.

How can Sustainable Aviation Fuel (SAF) be claimed under the UK ETS?

When an airline wishes to use Sustainable Aircraft Fuel (SAF) to reduce emissions, the Emissions Monitoring Plan (EMP) must be amended to describe the procedures for using SAF.

For a valid Emission Reduction Claim (ERC), the following conditions, among others, must be met:
- SAF meets the sustainability criteria of the Renewable Transport Fuel Obligation (RTFO).
- The fuel was purchased in the relevant year or in the three months before
- SAF was actually delivered within the monitoring period
- No duplicate claim is made under other emission schemes

Operators must submit supporting evidence, such as:
- Proof of Sustainability (POS) documents
- RTFO certificate data
- Purchase invoices
- Product transfer documents (PTD)
- Fuel supplier reports

In addition, a signed statement confirming that the same SAF is not used elsewhere for emission reduction claims or financial benefits must be submitted. ERCs must be included in the Annual Emissions Report (AER), which must be submitted by March 31 (year n+1).

How long does the current UK ETS program run?

Currently, only phase 1 of the UK ETS has been established. This runs from 2021 to 2030.

Key milestones include:
- December 31, 2020 - Brexit
- 2021 - first UK ETS monitoring period.
- March 31, 2022 - first UK ETS reporting deadline
- 2023-2026 - first system review
- 2028-2031 - second system review
- 2030 - end of phase 1

What is the emissions cap for aviation under the UK ETS?

The UK authorities have set an emissions cap for the period 2021-2030, aligned with the national goal of net zero emissions by 2050.

From 2024, the maximum amount of free allowances for airlines cannot exceed 100% of their verified emissions. Any excess will be returned to the regulator.

What are the key compliance deadlines under the UK ETS?

Action || Deadline

Monitor emissions according to the EMP || 1 January - 31 December (year n)

Prepare emissions report || End of year n

Submit annual emissions report through METS || 31 March (year n+1)

Submit emission allowances || 30 April (year n+1)

Improvement report (if required) || 30 June (year n+1)

Report non-significant EMP changes || December 31 (year n)

Report significant EMP changes || at least 14 days in advance

How is the UK ETS linked to the Swiss ETS (CH ETS)?

Since Jan. 1, 2023, flights from Great Britain (England, Wales and Scotland) to Switzerland are covered by the UK ETS. Flights from Switzerland to the UK fall under the Swiss ETS (CH ETS).

From Jan. 1, 2025, flights from Northern Ireland to Switzerland are also covered by the UK ETS Aviation Activity.

Is an improvement report mandatory?

Yes. When a verification body has identified recommendations, nonconformities or deviations in the verification report, the operator must submit an improvement report. This report must be submitted no later than June 30 of the year following the reporting period (n+1).