Scopes for determining inclusion in the EU ETS and CORSIA
The EU ETS, CH ETS, and CORSIA each have distinct scopes for monitoring and reporting obligations. These systems operate in parallel, imposing various requirements. Specifically, the EU ETS includes three different scopes that aircraft operators must consider, as detailed below.
The extended full scope is conclusive for the determination if an aircraft operator exceeds the de-minimis threshold and therefore is included in the EU ETS. The extended full scope refers to all flights departing from or arriving at an aerodrome located in the European Economic Area (EEA, consisting of EU Member States, Iceland, Liechtenstein, and Norway). Flights from Switzerland and the United Kingdom into the EEA are included in the extended full scope, even though they are subject to the CH ETS or UK ETS.
The full scope is conclusive for the determination if an aircraft operator is considered a ‘small emitter’. For a detailed definition of a small emitter please refer to (link small emitter page). The full scope refers to all flights departing from or arriving at an aerodrome located in the European Economic Area (EEA, consisting of EU Member States, Iceland, Liechtenstein, and Norway). Flights from Switzerland and the United Kingdom to the EEA are not included in the full scope, as they fall under the scope of the CH ETS or UK ETS, respectively.
The reduced scope is conclusive for the scope of flights for which CO2 emissions reporting and allowance surrendering apply. The reduced scope refers to all flights departing and arriving at an aerodrome located in the European Economic Area (EEA, consisting of EU Member States, Iceland, Liechtenstein, and Norway), including international flights between an EEA State and an outermost region located in another EEA state, and flights departing from the EEA and outermost regions to Switzerland and the United Kingdom.
A temporary exemption from the EU ETS is granted until 31 December 2030 for emissions from flights between an aerodrome in an outermost region of a Member State and an aerodrome in the same Member State outside that region, as well as flights between aerodromes within the same outermost region or different outermost regions within the same Member State.
The new CORSIA EU scope came into effect with Commission Implementing Regulation (EU) 2024/622 of 22 February 2024, which outlines the list of States considered to be applying CORSIA for the purposes of Directive 2003/87/EC of the European Parliament and the Council for emissions in 2023. This list, which defines the scope of routes requiring offsetting under CORSIA, will be updated and published annually. Counties in the European Economic Area (EEA, consisting of EU Member States, Iceland, Liechtenstein, and Norway), Switzerland, and the United Kingdom are excluded from this list because routes between these countries fall under the scope of the EU ETS, CH ETS, and/or UK ETS.
The CORSIA scope covers international flights between participating states of CORSIA (EEA and third countries). These routes are monitored, reported and subject to offsetting obligations. Intra-EEA flights are excluded from the offsetting obligation under CORSIA for European aircraft operators as they are already covered by the EU ETS.
Helpful guidance
Further helpful guidance for determining if you have obligations under the EU ETS and CORSIA is available here (applicable for emissions in the years 2024, 2025 and 2026):
