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Key Updates to EU ETS Flight Reporting and Compliance for the 2024 Monitoring Period

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04 October 2024

Key Updates to EU ETS Flight Reporting and Compliance for the 2024 Monitoring Period

As the European Union Emissions Trading System (EU ETS) evolves to advance its environmental goals, significant changes in the scope of covered sectors will come into effect for the monitoring period 2024. The verified reports need to be submitted to the authority by 31 March 2025 along with the first ReFuelEU verified reports for those operators with obligations under ReFuelEU.

This article aims to highlight changes to the monitoring scope and their impact on flights within and beyond the European Economic Area (EEA). It also introduces adjustments to emissions factors and seat counts for Public Service Obligation (PSO) flights.

Kindly refer to the below table for the Outermost Regions (OMRs) of the EEA member states:

Member State Outermost Regions (OMRs)
France	Reunion, Mayotte, Saint Martin, French Guyana, Guadeloupe, Martinique
Portugal	Azores and Madeira
Spain	Canary Islands

The key changes to the EU ETS reduced scope are detailed below:

Flights between the OMRs of one Member State and OMRs of different Member States:

Flights between the OMRs of one Member State and the OMRs of another Member State are now considered under the EU ETS reduced scope. Examples include flights between the Canary Islands (Spain OMR) and the Azores (Portugal OMR).

Flights between the OMR of one Member State and another Member State (mainland EEA):

Flights between aerodromes located in OMR of one member state and aerodromes located in different Member States will need to be reported. Examples include flights from the Canary Islands (Spain OMR) to Germany

Flights between an OMR and the same Member State (mainland EEA):

Flights between the aerodrome in an OMR and the aerodrome in the same Member State will be exempt from reporting. This means that a flight from a French OMR to mainland France, for instance, will not require reporting. For example, the Flights between the Canary Island (Spain OMR) to Barcelona (Spain).

Flights between aerodromes within the same OMR:

Flights that both start and end within the same OMR, such as a flight within the Canary Islands, will continue to be exempted from reporting.

Flights between different OMRs of the same Member State:

Flights between two different OMRs of the same Member State will continue to be exempted from reporting under EU ETS. For example, the flights between Guadeloupe (France) and Martinique (France) will be exempted from reporting under EU ETS.

Flights Involving Switzerland and the UK:

Any flights from Switzerland to an OMR will be reported under CH ETS and any flights from an OMR to Switzerland will be reportable under the EU ETS.
Any flights from the OMR of an EEA member state to the United Kingdom are now subject to reporting under the EU ETS. However, this requirement does not extend to flights from the United Kingdom to an OMR under the UK ETS.

Additional Updates:

Emissions Factor Update

From the 2024 monitoring period, the emissions factor for Jet A/Jet A1 fuel will be adjusted to 3.16 for flights reported under EU ETS as well as CORSIA for aircraft operators (EEA & Non-EEA Operators) with EU ETS reporting obligations.

PSO Flight Seat Count:

In the context of the European Union, Public Service Obligation (PSO) is

established by governments to maintain air connectivity, particularly in remote or less accessible areas. PSO thresholds are used to determine which flights or air routes qualify for this special regulatory treatment under the EU ETS, which exempts them from the reporting requirement. These are:

PSO Flights performed on routes within outermost regions; and
PSO flights on routes where the capacity offered does not exceed 50 000 seats per year.

In the latter, the 50 000 offered seats per year replace the old figure of 30 000 from 2024 onwards. The PSO seat count of 50,000 refers to the planned capacity, not the actual number of seats operated.

Allowance Surrender:

The deadline for surrendering EU ETS allowances to the Union Registry is changed from 30 April to 30 September (N+1). This will apply for the first time on 30/09/2024. The deadline for entering emissions remains unchanged on 31st March (N+1).

These updates are crucial for aircraft operators involved in the EU ETS monitoring, reporting, and verification to consider and prepare their reports accordingly. The aircraft operators can check the applicable PSO sectors, obtain necessary approvals from Competent Authorities, and start the preparation of their draft emissions reports under EU ETS and CORSIA.

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