Aircraft operators are not required to hold an EU ETS permit. Inclusion in the EU ETS, CH ETS, and CORSIA is based on CO2 emissions thresholds from the routes flown and the specific scope of each emissions reduction system. Each year, aircraft operators must assess whether they exceed the ‘de-minimis’ thresholds for each system. Once inclusion is determined, operators must identify which emissions from which flight routes need to be reported. Emissions must be calculated according to procedures in an aircraft operator’s emissions monitoring plan.
Aircraft operators that depart or arrive in an aerodrome located in the European Economic Area (EEA: EU member states, Iceland, Norway and Liechtenstein) are subject to the EU ETS, if they carry out aviation activities as defined in Annex I of the ETS Directive. This means that aircraft operators based outside the EU or EFTA countries can also be subject to inclusion in the ETS.
Exempted flight activities include:
Flights by aircrafts with a maximum take-off weight below 5.700 kg;
Military flights, search and rescue flights and scientific flights;
For the full list of exempted activities check Annex 1 of the EU ETS Directive.
Additionally, aircraft operators are excluded from the EU ETS if they are below the de-minimis threshold:
Commercial aircraft operators are excluded from the EU ETS if they operate flights included in the ‘extended full scope’ emitting less than 10.000 tonnes CO2 per year or operate less than 243 flights in one three consecutive four-month period (January – April, May – August, September – December).
Non-commercial aircraft operators are excluded from the EU ETS if they operate flights included in the ‘extended full scope’ with less than 1.000 tonnes CO2 per year. This exemption is until 31 December 2030.
The EU ETS and the Swiss Emissions Trading System (CH ETS) became linked in January 2020. As a result, aircraft operators conducting flights between the European Economic Area (EEA) and Switzerland, including domestic Swiss flights, need to report these flights through a single verified emissions report to only one competent authority, either in Switzerland or a Member State. This streamlines the reporting process and reduces the administrative burden, ensuring that operators are never required to report in both jurisdictions. Aircraft operators included in the EU ETS must report their CH ETS emissions in their annual emissions report.
For aircraft operators holding an aircraft operator licence (AOC) or operating license from The Netherlands, the administration of both the EU ETS and CORSIA is handled by the NEa. Additionally, the monitoring plan and annual emissions report are consolidated into joint templates for both schemes.
Aircraft operators whose aircrafts have a maximum take-off weight of more than 5.700 kg and emit annually more than 10.000 tonnes CO2 in the CORSIA scope (international flights between participating CORSIA states; EEA and third countries) are subject to CORSIA. Since 1 January 2024, CORSIA is implemented in Europe in the EU ETS Directive with additional European implementing regulations.
