Guidance

UK Emissions Trading Scheme for aviation: how to comply

Guidance to help aircraft operators understand and meet their compliance obligations under the UK Emissions Trading Scheme (UK ETS).

From:
Environment Agency
Published
4 March 2021
Last updated
23 April 2024 — See all updates

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 also then surrender sufficient allowances 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.

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 UK sector of the continental shelf

  • 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, Switzerland, or outermost regions other than an excluded flight.

The EEA states are:

  • Austria

  • Belgium

  • Bulgaria

  • Croatia

  • Republic of Cyprus

  • Czech Republic

  • Denmark

  • Estonia

  • Finland (including Åland Islands)

  • France

  • Germany

  • Greece

  • Hungary

  • Ireland

  • Italy

  • Latvia

  • Lithuania

  • Luxembourg

  • Malta

  • Netherlands

  • Poland

  • Portugal

  • Romania

  • Slovakia

  • Slovenia

  • Spain (including Melilla and Ceuta)

  • Sweden

  • Norway (including Jan Mayen)

  • Iceland

  • Liechtenstein

The Basel-Mulhouse-Freiburg aerodrome (LFSB and LSZM) is in French territory.

The following are 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:

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 instructed (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 for 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:

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

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. The Environment Agency is currently the registry administrator for the whole of the UK.

The UK ETS Registry works in a similar way to an internet bank account. It is where UK ETS allowances are:

  • created

  • allocated

  • held

  • traded

  • surrendered

In particular, it records:

  • free allowance allocations

  • aviation emissions

  • surrenders

  • all other transactions involving allowances

The registry administrator will contact you to tell you how to get access to your AOHA.

You must name a primary contact who will nominate authorised representatives to operate the AOHA for the aircraft operator.

Your primary contact can nominate up to 2 authorised representatives free of charge. You will need to pay a fee if you want to nominate more than 2, or if you replace an authorised representative at a later date.

The registry administrator will request information about any nominated authorised representative. This is to make sure the person is fit and proper to carry out their proposed role. If the registry administrator is satisfied they are, it will approve the nomination and give the person access to the AOHA. This process can take up to 2 months (or longer in some cases).

It is your responsibility to maintain access to your AOHA and keep the details the registry administrator hold for you up to date. You must make sure your authorised representatives have the appropriate permissions to carry out actions needed on your AOHA - especially surrendering allowances.

The authorised representatives can have the following permissions on an AOHA:

  • propose actions

  • approve actions

  • approve actions proposed by another authorised representative

  • review account information only

  • surrender or return allowances

You will need to get approval from the registry administrator to change an authorised representative’s permissions.

Email the registry administrator helpdesk at etregistryhelp@environment-agency.gov.uk if you need help or have any queries.

You can also use your AOHA to carry out trading activities, for example, by selling allowances to another account holder. To transfer allowances out of your AOHA to another account holder without the need for approval by a second authorised representative, you must set up the other account holder’s registry account as a ‘trusted account’. This takes 4 working days to complete, provided you have authorised representatives in place able to perform this action.

For more information, check the UK ETS Registry.

Trading accounts in the UK ETS Registry

Any legal person, including an individual, can apply to have a trading account in the UK ETS Registry. A trading account can only be used to hold and trade in allowances. It is not possible to surrender from this account.

Information made public

Certain information in the UK ETS Registry is made available to the public in line with the requirements of the order.

The type of information that will be made public includes:

  • information about open accounts and their account holders

  • detailed information about accounts, their holdings and transaction information – including the names of account holders involved in transactions that are more than 3 years old

The following information is not made public:

  • information about authorised representatives and primary contacts

  • detailed information about accounts, their holdings and transaction information – including the names of account holders involved in transactions that are less than 3 years old

Allowances and surrender

One UK ETS allowance allows you to emit 1 tonne of CO2. The principle of the UK ETS is that you must:

  • monitor your aviation emissions for each scheme year

  • report your aviation missions by 31 March the following year

  • surrender allowances equal to your aviation emissions by 30 April the following year

For the purposes of calculating how many allowances you need to surrender for a scheme year, your aviation emissions figure will include:

  • your aviation emissions arising from your aviation activity in the scheme year

  • any emissions from a previous scheme year for which you failed to surrender allowances

If you do not comply with these and other obligations in the order, you may receive significant civil penalties.

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. This will be in line with the free allocation entitlement set out in the Aviation Allocation Table (AAT).

All free allocations and 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).

The UK ETS authority is made up of the UK government and devolved administrations. Together they oversee the UK ETS.

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, for a scheme year in which you were not an aircraft operator.

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:

  • from a trader with a trading account in the UK ETS Registry

  • from other UK ETS account holders

  • through an auction

Transactions in the UK ETS Registry are affected by automatic transaction windows and delays. It can take up to 9 working days to transfer allowances to your AOHA. To ensure you have sufficient allowances available in your AOHA in time for surrender, you should confirm with the supplier when you will receive the allowances into your account.

The regulator and registry administrator cannot recommend a person or organisation that sells allowances. But you may wish to contact a member of the International Emissions Trading Association. You can also do an internet search to find information about other sources.

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.

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. You will not be entitled to 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 above the relevant thresholds during a scheme year

  • your regulator identifies this 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 – 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 that are equivalent 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)

  • 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:

You will use the emissions data collected during your monitoring to produce 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:

  • 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:

  • your ERC will fail

  • 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 is 10 years from the date you submitted your report. So, you will also need to keep the data used in preparing the report even though it will be more than 10 years old.

Using simplified reporting procedures for small emitters

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, 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 use the small emitters tool populated with your own flight data, you must have your emissions report verified by an accredited independent verifier.

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.

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:

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:

You need to follow these steps to submit your annual emissions report to your regulator.

  1. 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.

  2. You must then submit your annual emissions report to your chosen verifier for verification.

  3. Once the verification process is complete, your verifier will return the verified annual emissions report to you using METS.

  4. 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

After the 31 March reporting deadline, your regulator will instruct the registry administrator to record the figure for your verified or determined aviation emissions in your AOHA.

You must surrender allowances equal to your aviation emissions by 30 April. You must do this even if:

  • the registry administrator has not recorded an aviation emissions figure in your AOHA

  • you think the figure entered is incorrect

It is your responsibility to make sure that the allowances you surrender are equal to your aviation emissions.

If you do not surrender sufficient allowances by 30 April in the year following the scheme year, you will receive a mandatory civil penalty.

Surrender allowances by 30 April

You must surrender allowances equal to your aviation emissions from your UK ETS Registry AOHA. You must do this by 30 April in the following scheme year.

Your surrender obligation is both:

  • your aviation emissions for that scheme year

  • any emissions from a previous scheme year for which you did not surrender allowances

You must make sure you have sufficient allowances available in your AOHA by 30 April to meet your surrender obligation.

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.

Any emissions you have not surrendered allowances for will be added to your aviation emissions figure for the following scheme year.

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. It’s helpful to provide details of the change and how it affects the information in your 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 regulator’s 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 ISO/IEC 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.

Updates to this page

Published 4 March 2021
Last updated 23 April 2024 + show all updates

  1. Updated the 'Appointing an independent verifier' section to explain how to assign a verifier in the 'Manage your UK Emissions Trading Scheme reporting’ service (known as METS).

  2. Updated to reflect: the expansion of scope of the UK ETS to include Switzerland; how to make emissions reduction claims from using sustainable aviation fuels; the introduction of new online system (METS) and processes to replace ETSWAP.

  3. Included a link to the Aviation Allocation Table.

  4. First published.

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