Cathay Pacific Airways Limited Cathay Pacific Airways Limited
I work relatively closer with the verification team and commercial team, the service is very satisfactory overall.
United Kingdom Emissions Trading System (UK ETS)
The UK ETS, established post-Brexit, supports UK climate goals through a cap-and-trade system covering various sectors, including aviation. Aircraft operators must monitor, report annual emissions, and surrender allowances equal to their verified emissions. The Greenhouse Gas ETS Order 2020 No.1265 (the Order) establishes the ‘Aviation Activity’ scope that’s applied for reporting, while the ‘Full-scope’ determines thresholds for obligations and eligibility for simplified procedures. Enforcement is ensured via four Regulators.
Aviation Activity includes flights departing from the UK and arriving in:
It also includes flights from Gibraltar to the UK.
Full-scope flights are those departing from or arriving in the UK, Gibraltar, an EEA state (including its outermost regions) or Switzerland.
The following flights are excluded:
Commercial operators are exempt if, considering the full-scope, they:
Non-commercial operators are exempt if they emit less than 1,000 tCO₂ annually from full-scope flights.
Both operators are exempted if they do not operate ‘Aviation Activity’ flights.
Aircraft operators emitting less than 25,000 tCO₂ annually or operating fewer than 243 full-scope flights in each of 3 consecutive 4-month periods, are considered small emitters and can use the Small Emitters Tool (SET) to estimate their emissions. Reports generated using the SET require independent verification.
Operators must monitor emissions from 1 January to 31 December annually following an approved Emissions Monitoring Plan (EMP). The verified Annual Emissions Report (AER) must be submitted via METS by 31 March of the reporting year.
Operators using Sustainable Aviation Fuel (SAF) may reduce the aviation activity emissions by making an emissions reduction claim (ERC). To do so, the EMP must be updated with the associated procedures and approved before submitting the ERC, which should be done via METS. Eligibility criteria include:
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.
Cathay Pacific Airways Limited Cathay Pacific Airways Limited
I work relatively closer with the verification team and commercial team, the service is very satisfactory overall.
Widerøe Widerøe
All the teams were helpful.
TACV Cabo Verde Airlines TACV Cabo Verde Airlines
Everyone gave us good support.
Surrendering obligations under the UK ETS will apply to the following routes
Note: Flights departing from the Crown Dependencies Isle of Man, Jersey, and Guernsey, are not included in the reportable scopes of UK ETS.
Flights performed by aircraft with a certified maximum take-off mass of less than 5,700 kilograms.
Note: Public Sector Obligation flights are not part of UK ETS aviation activity.
Yes, the UK ETS registry is used to record the below information under UK ETS only:
Allowance surrenders
The registry administrator will open an Aircraft Operator Holding Account (AOHA) in the UK ETS registry after the UK ETS regulator has issued and confirmed the Emissions Monitoring Plan (EMP). The administrator will contact the aircraft operator accordingly. This is the aircraft operator’s responsibility to maintain the AOHA and nominate two authorized representatives for the AOHA.
Commercial and non-commercial aircraft operators would not be subject to any obligations if they meet some criteria.
Commercial aircraft operators will not have any obligations if they meet any of the following criteria:
Non-commercial aircraft operators will not have any obligations if they operate flights with total annual emissions below 1,000 tonnes of CO2 per year, based on full-scope activity.
If an aircraft operator aims to use sustainable aviation fuels (SAF) / biofuels in the near future, the operator must update their Emissions Monitoring Plan (EMP) to describe the procedures for implementing and monitoring SAF use.
To make a successful emission reduction claim the operators is required to follow the below mentioned criteria:
Only Phase 1 of the UK ETS has been announced as of now and it is slated to run from 2021 to 2030, with two full system reviews.
Key Dates:
The Authority have decided to reset the UK ETS cap for 2021-2030 to make the UK ETS consistent with UK’s trajectory towards Net Zero by 2050.
Starting in 2024, the regulatory body has made the decision to set a cap on aircraft operators’ free allocation entitlement. The maximum entitlement will be restricted to 100% verified emissions. Any surplus-free allowances allocated to operators beyond this cap will be returned to the regulatory authority.
The UK ETS compliance deadlines would be aligned with EU ETS requirements.
| Action | Timeline |
|---|---|
| Monitor aviation emissions in line with the EMP | Between 1 January and 31 December in year n |
| Start preparing the annual emissions report (with time for verification, if required) | Towards the end of year n |
| Submit the annual emissions report via METS | By 31 March of year n+1 |
| Surrender allowances equal to your reported emissions | By 30 April of year n+1 |
| Improvement report (if applicable) | By 30 June of year n+1 |
| Notify the regulator of any non-significant changes to your EMP | By 31 December of year n |
| Notify the regulator of any significant changes to your EMP | At least 14 days before the proposed change to the EMP |
Since January 1st, 2023, flights from Great Britain (England, Wales, and Scotland) to Switzerland have been reported under the UK ETS aviation activity. Conversely, flights from Switzerland to the UK (Great Britain and Northern Ireland) are reported under the CH ETS. Starting January 1st, 2025, flights from Northern Ireland to Switzerland have also been included in the UK ETS Aviation Activity.
Yes. If a verification body has issued a recommendation, non-compliance and/or non-conformity in their verification report, the aircraft operator must submit an improvement report by 30 June (n+1 year).
