What are non-CO2 aviation effects?
Non-CO2 aviation effects include emissions like NOₓ, contrails, and water vapour that contribute to climate change beyond CO2 emissions.
Non-CO2 Aviation Effects
From 1 January 2025, aircraft operators subject to the EU ETS must comply with the monitoring, reporting, and verification (MRV) of non-CO2 aviation effects – climate impacts and atmospheric changes caused by substances other than carbon dioxide, including nitrogen oxides (NOₓ), water vapour, soot particles, sulphur oxides (SOₓ), contrails and induced cirrus clouds. The requirements are outlined in the Monitoring and Reporting Regulation (MRR) and the EU ETS Directive.
Aircraft operators subject to the EU ETS and flying jet-engine aircraft are subject to this new requirement. Operators must choose a geographical scope for reporting in 2025 and 2026:
From 2027, full scope reporting will be mandatory. The scope must be defined in the Annual Emissions Monitoring Plan (AEMP) and remain consistent during the reporting year. Any changes for the next year require updating the AEMP.
The first non-CO2 aviation effects report, including the NEATS-generated XML report, is due by 31 March 2026.
For the 2025 reporting year, operators must use the Non-CO2 Aviation Effects Tracking System (NEATS), developed by the European Commission. From 2026, alternative IT tools may be used and shall be included in the AEMP provided they meet the MRR requirements and are approved by the Commission.
Operators must choose a calculation method:
Operators must collect, at a minimum, primary data (measured data) for flight information (call sign, UTC flight date and time, origin and destination airports), and may opt to provide additional primary data (e.g., trajectory, engine unique identifier, etc.), if available.
The NEATS aims to simplify the MRV process. Until it is available, operators must monitor at least flight information and aircraft type per flight, regardless of the method used. With this information, the calculations will be performed at a later stage, once NEATS is live.
Operators must revise and submit their AEMP to include non-CO2 provisions using the latest template (February 2025). The AEMP must cover:
If not yet submitted, operators should urgently contact their Competent Authority.
Our commercial team engages with the client. Thereafter, a pre-contract is elaborated and sent to the client.
During the engagement stage, clear objectives are set with the client, which involves the comprehensive definition of the operational scope, ensuring that all relevant parties have a clear and shared understanding of the verification boundaries. The engagement is formalized through a contract, setting the stage for a structured and transparent verification process.
The verification activities are determined and planned based on the claims. An Audit Preparation Letter (APL) is sent to request all the required data and documents to begin the verification process. A strategic and risk analysis is performed to assess the risks and prepare a verification plan.
A thorough analysis of emissions data and supporting documents to verify accuracy, completeness, and consistency. The process ensures compliance with relevant regulations. It includes cross-checking flight and fuel data, reviewing monitoring methodologies, and validating control systems to confirm the integrity of the reported information.
An independent technical review is conducted in accordance with ISO 17029:2019 and ISO 14065:2020 standards. After achieving reasonable assurance, a verification report is issued, ensuring that the client’s report is free from any material misstatements.
If there is any significant information that comes to light after the verification opinion has been issued and if such information could impact the verification results, it may necessitate a reassessment or correction in the report.
Non-CO2 aviation effects include emissions like NOₓ, contrails, and water vapour that contribute to climate change beyond CO2 emissions.
From January 1, 2025, aircraft operators must monitor and report annually non-CO2 aviation effects.
All aircraft operators flying jet-engine aircraft under the EU ETS must comply.
Operators choose between reduce scope {flight within EEA States (including territories and OMRs)}, full scope (all EEA arrivals/departures), or in-between scope (reduced scope and other selected routes).
From 2027, all operators must report using the full geographical scope.
The Non-CO2 Aviation Effects Tracking System (NEATS) provided by the European Commission.
From 2026, other Commission-approved tools can be used if they meet standards set in the Monitoring and Reporting Regulation.
Method C (for all operators), Method D (for small emitters), or a combination for small emitters.
Aircraft eligibility, reporting scope, chosen method, IT tools, data collection, and data gap handling.
By March 31 of the year following the reporting period (e.g., March 31, 2026, for 2025 flight data)
Primary data is data that is measured and monitored by the aircraft operator (i.e. actual data). Secondary data is data that can be provided by the Non-CO2 Aviation Effects Tracking System (NEATS) without input from the aircraft operator.
Flight information, flight trajectory, aircraft properties (engine unique identifiers, aircraft mass along the trajectory and aircraft type), fuel flow, fuel properties, and aircraft performance (optional) will be required for the calculation of non-CO2 aviation effects. However, operators can opt to rely on secondary data and default values (available in NEATS).
* Until NEATS is available and operational, aircraft operators must monitor, as a minimum, flight information and aircraft type for each flight.
