Transparency & Trust: Aviation Emissions Verified

United Kingdom Emissions Trading System (UK ETS)

United Kingdom Emissions Trading System (UK ETS) 

The United Kingdom Emission Trading Scheme (UK ETS), established post-Brexit, drives the UK’s climate efforts by managing emissions across various sectors, including aviation. Focused on collaborative progress, the scheme involves stakeholder engagement and public consultations to enhance strategic approaches. With a strong emphasis on Sustainable Aviation Fuel (SAF), the UK ETS exemplifies the nation’s dedication to reducing aviation emissions and fostering a sustainable future. 

Why choose Normec Verifavia?

  1. Compliance Excellence: Normec Verifavia ensures strict adherence to flight compliance and reporting standards, backed by comprehensive documentation as per the ISO 14065 standards. 
  2. Unmatched Expertise: Normec Verifavia’s verification is conducted by expert auditors with aviation knowledge, ensuring a thorough verification of the airline’s emissions data. 
  3. SAF Emission Reduction: Normec Verifavia’s auditors provide objective verification of the airline’s reductions in emissions from Sustainable Aviation Fuel (SAF), emphasizing their commitment to sustainability within the framework of the UK ETS. 
  4. Regulatory Training: Normec Verifavia equips airlines with the knowledge to navigate evolving regulations, ensuring preparedness for UK ETS changes through focused training, and maintaining a dedicated emphasis on verification. 

The UK Emissions Trading Scheme (UK ETS) is a cornerstone of the UK’s strategy to achieve net-zero emissions by 2050, applying to various sectors including aviation. The scheme mandates immediate surrendering obligations for aviation routes within the UK and to European Economic Area (EEA) territories, with exceptions for flights to crown dependencies (Isle of Man, Jersey, and Guernsey) and certain EU outermost regions.  

Oversight and Adherence: The UK ETS ensures strict compliance, following timelines similar to the EU ETS. Operators comply by following detailed emissions monitoring plans (EMPs). A new reporting system is currently used Manage your UK Emissions Trading Scheme Reporting (METS). 

Emissions Reduction and SAF Focus: Acknowledging the crucial role of Sustainable Aviation Fuel (SAF) in cutting emissions, the UK government actively engages stakeholders. The UK ETS encourages SAF adoption, emphasizing substantial emission cuts and a commitment to greener aviation practices. 


  1. EMP Update: The operator needs to update their EMP to describe the procedures for implementing and monitoring SAF usage. 
  2. SAF Purchase: The SAF is derived from biomass which should meet the relevant RTFO criteria at the date of purchase and is delivered to the aircraft in the specific monitoring period. 
  3. Documents: Proof of sustainability (POS), Product transfer document (PTD), Purchase Invoice, Self-Declaration (To avoid double-counting) 
  4. SAF Reporting Method: Purchase record approach. 
  5. Emissions Reduction Claim: The operator needs to provide all the necessary document to the independent verifier through METS. 
  6. SAF Reduction: The independent auditor verifies the SAF documents and the SAF emissions reduction values mentioned by the airlines in the METS. 

List of feedstock fuels, accepted by the Renewable Transport Fuel Obligation (RTFO) scheme, from which RTFO renewable fuels can be made. The information provided includes: 

  • Name of the materials 
  • Descriptions of the materials 
  • when materials were accepted into the RTFO scheme 

The list should be used in conjunction with the RTFO guidance. 

Cap and Trajectory: The UK ETS sets an initial cap 5% below the UK’s expected share of the EU ETS cap for Phase IV. The cap reduces annually, ensuring alignment with environmental goals. The aviation component aligns with the EU ETS aviation cap, promoting efficiency and cost-effective abatement. 

Offsets: While initial UK ETS rules exclude offsets, future reviews may reconsider their inclusion. 

Exempted Flights: Schedule 1 of the Greenhouse Gases Emissions Trading Scheme Order 2020 specifies flights not mandatory for reporting. Operators with exempted flights must provide evidence to the verifier for verification before these flights can be considered exempt. 

Linking with Swiss ETS: Flights departing from Great Britain (England, Scotland, and Wales) heading to Switzerland will fall under the reporting obligation of the UK ETS. Conversely, flights departing from Switzerland to the UK will reporting obligation under the Swiss ETS.  

Wonder what we can do for you?

Contact us
  1. Engagement and Scope Definition

    The process begins with NORMEC VERIFAVIA’s commercial team engaging with the operator. This stage involves a detailed definition of the operational scope, ensuring all parties have a clear understanding of the verification boundaries. The engagement is formalized through a contract, setting the stage for a structured and transparent verification process. 

  2. Data and Documentation Submission

    Operators are required to submit all relevant data and documentation for verification. This includes emissions reports, monitoring plans, and any other pertinent information as specified by NORMEC VERIFAVIA. The submitted data undergo a comprehensive review to ensure accuracy and completeness, with operators promptly notified of any discrepancies or the need for additional clarification. 

  3. Site Visit (On-site or Virtual)

    Depending on the specific requirements set in the Greenhouse Gas Emissions Trading Scheme Order 2020 and guidance from the Environment Agency, a site visit is conducted. This can be either an on-site visit or a virtual visit, aimed at assessing the operational practices and verifying the accuracy of reported data in the context of actual operations. 

  4. Data Analysis and Verification

    Following the site visit, the verification team conducts an in-depth analysis of the provided data against the operational realities observed. This step is crucial for identifying any inconsistencies and ensuring the reported data accurately reflects the operator’s emissions.

  5. Technical Review and Verification Option Finalization

    An independent technical review is conducted on the entire verification process and findings. This review is in accordance with ISO  14065 standards and specific requirements of the UKETS. It serves to validate the verification work done and ensure compliance with all applicable standards. Based on this review, the final verification option is determined, indicating the level of assurance regarding the operator’s emissions data. 

  6. Verification Opinion Statement

    Upon successful completion of the technical review and finalization of the verification opinion, the report will be transmitted via METS. 


A J Walter Aviation

From my side, may I take this opportunity to pass on to you how easily and smoothly our Verifavia experience/approval has been. A considerable improvement from our last agency!


Find answers to the most commonly asked questions

Which flight routes will be included in the UK ETS reduced scopes or under “UK ETS Aviation Activity”?

Surrendering obligations under UK ETS will apply to the following routes 

  1. UK domestic flights 
  2. Flights departing from the UK to aerodromes within EEA states. 
  3. Flights between the UK and Gibraltar. 
  4. Flights departing from Great Britain and arriving in Switzerland. (Note: Great Britain comprises England, Wales, and Scotland). 
  5. Flight departing from the UK to territories of EEA member states, including Ceuta and Melilla (Spain), the Åland Islands (Finland), and Jan Mayen (Norway). 
  6. Additionally, flights to offshore installations will be included in the UK ETS.

Note: Flights departing from the crown dependencies Isle of Man, Jersey, and Guernsey are not included in the reportable scopes of UK ETS 

Which types of flights are excluded from the UK ETS reportable scope (UK ETS aviation activity)?

  1. Military flights 
  2. Flights performed exclusively for the transport, on an official mission, of a reigning Monarch and their immediate family, Heads of State, Heads of Government, and Government Ministers, of a country other than the United Kingdom 
  3. Customs and police flights performed by both civil registered and military aircraft 
  4. Search and rescue flights 
  5. Firefighting flights 
  6. Humanitarian flights 
  7. Emergency medical service flights 
  8. Flights performed exclusively under the visual flight rules set out in Annex 2 to the Chicago Convention 
  9. Flights terminating at the aerodrome from which the aircraft has taken off and during which no intermediate landing has been made. 
  10. Training flights performed exclusively for the purpose of obtaining a license, or a rating in the case of cockpit flight crew, provided that the flights do not serve for the transport of passengers or cargo. 
  11. Flights performed exclusively for the purpose of scientific research partially or totally performed in-flight 
  12. Flights performed exclusively for the purpose of checking, testing or certifying aircraft or equipment whether airborne or ground based. 

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. 

Does UK ETS have a separate Registry account?

Yes, the UK ETS registry is used to record the below information under UK ETS only: 

  • Free allowance allocations 
  • Annual verified aviation emissions 
  • Allowance transfers 

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. 

What are the associated exemptions and thresholds under the UK ETS?

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:

  • Operate fewer than 243 flights per period for three consecutive four-month periods, based on full-scope activity. The four-month periods are January to April, May to August, and September to December. 
  • Operate flights with total annual emissions below 10,000 tonnes of CO2 per year, based on full-scope activity. 

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.

What is the procedure for claiming Sustainable Aviation Fuels (SAF)/ biofuels under UK ETS?

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: 

  1. In UK ETS, SAF / biofuels can be claimed if they meet the sustainability criteria in the Renewable Transport Fuels Obligation (RTFO) order. 
  2. The fuel purchase needs to take place in scheme year or in the three months prior to the start of the scheme year. 
  3. The SAF is delivered to the aircraft in the specific monitoring period. 
  4. No double counting of the eligible SAF 
  5. The aircraft operator is required to present the following key documents to their independent verifier: 
    1. Evidence of sustainability 
      1. Proof of Sustainability (POS) documents 
      2. Details of RTFO certificate claims  
    2. SAF purchase and delivery 
      1. Product Transfer Document (PTD) 
      2. Invoices 
      3. Fuel supplier report.
    3. SAF Mandate: The fuel supplier letter along with the information about the sustainability batch certificate number to back tract the source of the SAF needs to be mentioned in the letter.
    4. Declaration  
      1. A signed declaration confirming that the SAF specified in the ERC is not sold to another person or used elsewhere to claim emissions reduction or financial benefits. 
      2. The ERCs must be included as a part of the Annual Emissions Report (AER) for the required monitoring period by 31st March (n+1 year). 

What is the duration for the implementation of the UK ETS?

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: 

  1. Brexit: 31st December 2020 
  2. First UK ETS Monitoring Period: 2021 
  3. EU ETS 2020 Compliance for UK Operators: 31st March 2021 
  4. UK ETS 2021 Deadline: 31st March 2022 
  5. First UK ETS Review: 2023-2026 
  6. Second UK ETS Review: 2028-2031 
  7. End of UK ETS Phase 1: 2030 

What is the UK ETS’s aviation cap on emissions?

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. 

What are the deadlines envisaged for compliance?

The UK ETS compliance deadlines would be aligned with EU ETS requirements. 

Would the UK ETS be linked with the CH ETS?

From January 1st, 2023, flights from Great Britain (England, Wales, and Scotland) to Switzerland will fall within the scope of the UK ETS. Conversely, flights from Switzerland to the UK (Great Britain and Northern Ireland) will be reported under CH ETS. 

Is an improvement report mandatory?

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).