United Kingdom Emissions Trading Scheme (UK ETS)
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Challenges Observed During GHG Reporting and Verification
Effective Greenhouse Gas (GHG) monitoring, reporting and verification are essential to ensure that aviation emissions data is credible, accurate, and compliant with regulatory requirements. Verifiers must gain reasonable assurance that reported emissions are complete and consistent, supporting both regulatory compliance and global climate commitments.
While monitoring, reporting and verification frameworks are well established, operators often encounter practical difficulties during the process. When not addressed promptly, these issues may increase the risk of misstatements in the final report and lead to delays in completing the verification.
This article outlines the common difficulties encountered during verification and highlights the importance of addressing them at an early stage.
The global scope of airline operations and the use of diverse internal systems and methods can introduce differing fuel units across stations and various data formats, which, if not harmonised, can create inconsistencies in flight and fuel records used for reporting and verification. Other derived common issues include formatting errors, different date formats, identification of ICAO codes, or confusion between flight time and block time, all of which can cause discrepancies in the emissions report.
Such variations represent an increased risk of misstatements and non-conformities and require extra time for clarification and reconciliation. Preparing data, combining the outputs of different sources and systems in a harmonised format, and applying periodic control activities prevent these issues, improving data quality and reducing the need for repeated reviews post data submission.
Beyond data inconsistencies, another frequent challenge lies in how operators consolidate vast amounts of information across departments. Airline operations are vast and complex, involving numerous departments and stakeholders monitoring diverse data streams. Limited coordination, communication, or collaboration among them can delay the timely extraction and consolidation of information, often resulting in late, partial, or multiple submissions of data for verification, disrupting the planned schedule. Such delays shorten the review window, leaving less time to resolve issues and increasing the risk of misstatements and non-conformities in the verification report.
Establishing clear data ownership, strengthening inter-departmental communication, and implementing centralised data management with defined timelines and responsibilities can mitigate these risks and support accurate, timely report submission.
Regulations and reporting requirements change frequently, from simple updates of formats to updates in the emissions factor and even reporting scopes. When these changes are not fully incorporated promptly, it often results in ongoing back-and-forth between operators and verifiers. Even small, overlooked details can cause significant delays and require resubmissions.
To minimise delays and improve accuracy, it is recommended to stay updated with evolving regulations and associated reporting templates, implement thorough internal reviews, and maintain clear communication with authorities and verifiers. Proactive adaptation to changes ensures a smoother, more efficient emissions reporting process.
Operators involved in wet lease operations may lack direct access to fuelling records, logbooks, or operational documents, many of which are managed by the lessor. The reliance on third-party records from other operators and the use of differing formats or languages can hinder timely document and data retrieval and review.
Better coordination between lessor and lessee, with clear terms for data and document sharing defined at the contract stage, enables timely data submission and sufficient review time, reducing the risk of misstatements and non-conformities in the report.
SAF claims are a complex aspect of GHG schemes such as the EU ETS, UK ETS, and CORSIA. Operators need to rely on their fuel suppliers to provide the necessary documentation required for claiming SAF, which includes Proof of Sustainability (PoS), Proof of Compliance (PoC), and Product Transfer Documents (PTDs). However, there are instances when suppliers are unable or ineligible to provide valid evidence to prove that the sustainability criteria have been met.
If documentation for supporting Sustainable Aviation Fuel (SAF) claims is delayed, unavailable, or fails to prove the sustainability criteria as per the relevant scheme requirements, operators will not be able to benefit associated with their SAF purchases. This also increases financial pressures due to the need for additional allowances or offsets.
Enhancing transparent tracking, timely communication, and collaboration across all stakeholders involved, including fuel suppliers, operators, authorities and verifiers, can help ensure a smoother reporting and verification process and timely recognition of SAF benefits under all relevant greenhouse gas schemes.
GHG monitoring, reporting and verification in aviation demand precision and efficiency to meet regulatory requirements and climate objectives. However, practical obstacles ranging from inconsistent datasets and coordination gaps to wet lease dependencies and SAF documentation hurdles often disrupt the process. By anticipating these challenges and strengthening internal controls, data governance and collaboration among stakeholders, including fuel suppliers, operators can streamline processes, minimise risks of misstatements and non-conformities, and ensure compliance with the relevant GHG regulations.
