Milestones and Compliance Tasks

All aircraft operators that must participate in the EU ETS, CH ETS and CORSIA must first have an approved monitoring plan prior to submitting an emissions report. Therefore it is important to monitor flight activities to determine if you will exceed the EU ETS de-minimis threshold. The emissions monitoring plan template is available for download from the European Commission.

Helpful links:

• More information on the monitoring of SAF can be found on the dedicated webpage: Sustainable aviation fuels (SAF) 
• More information of the monitoring of non-CO₂ aviation effects can be found here: Non-CO₂ aviation effects
• Template No. 2: Monitoring plan for the emissions of aircraft operators for EU ETS and CORSIA
• Submit your Monitoring plans through the EU ETS Reporting Tool

All aircraft operators that must participate in the EU ETS and CH ETS must have a registry account with up to date contact persons.

Helpful link:

EU ETS registry

You can appoint a verifier in the ETS Reporting Tool. On the 'Organisations' details page, you can click on 'Add preferred verifier'. A list of all active verifier organisations registered in the system is displayed. Here you can appoint an organisation of your choice and click 'Assign'.

Helpful link:

EU ETS registry

If you exceed the annual EU ETS de-minimis threshold, then you must prepare your annual emissions report and have it verified by an accredited verifier. The emissions reporting template is available for download from the European Commission. You can also use Eurocontrol’s EU ETS support facility to help corroborate monitored flights and determine a reporting obligation. If considered a small emitter, than you can use Eurocontrol’s small emitter tool SET without verification by an accredited verifier. If CORSIA also applies to you, and the NEa is your administrator, than you must also submit a verified CORSIA emissions report as a part of your EU ETS emissions report.

Helpful links:

• More information of the reporting of SAF can be found on the dedicated webpage: Sustainable aviation fuels (SAF)
• Template No. 5: Annual emissions report of aircraft operators for EU ETS, Swiss ETS, and CORSI
• Eurocontrol EU ETS Support Facility
• Eurocontrol small emitter tool

Submit your (verified) annual emissions report (EU ETS, CH ETS, and / or CORSIA) by 31 March in the EU ETS Reporting Tool.

Helpful link:

• EU ETS Reporting Tool

An EU ETS registry account representative must enter emissions data into the EU ETS Registry. If the figures entered correspond to the data in the (verified) emissions report, the national administrator will approve the figures.

Helpful links:

• Download Checklist Account Representative EU ETS Registry Aviation here
• More information is available here (in Dutch) EU ETS-register 2021-2030.

Surrender sufficient allowances in the EU ETS registry for each tonne of CO₂ emitted. The new deadline for surrendering emissions is 30 September from 2024 onwards.

Helpful link:

• EU ETS registry

If monitoring changes are made throughout the year, including changes in contact details, an updated monitoring plan must be submitted to the NEa. Please submit monitoring plan changes via the ETS Reporting Tool. Edit your monitoring plan in the Monitoring Plan details page and click ‘Edit’ (right bottom of the page). Choose in the drop-down menu under ‘Revision type’ whether the change entails a significant or non-significant modification of the monitoring plan and upload the new version. For additional guidance on whether a monitoring plan change is considered significant or not, please consult the guidance document from the Commission.

Helpful link:

• EU-ETS Reporting tool - User Manual (europa.eu)

If there are any changes in contact persons or contact details, please update this in the ETS Reporting Tool on the ‘Organisations’ details page. Here you can add or delete organisation members under ‘Member list’. New members will receive an e-mail notification when the approval process is complete. Additionally, you must change your monitoring plan accordingly and submit the updated monitoring plan to the NEa via the ETS Reporting Tool.

Helpful link:

• EU-ETS Reporting tool - User Manual (europa.eu)

When your total final CO₂ offsetting requirement is above zero, you shall submit to the NEa an emissions unit cancellation report that is verified and a copy of the associated verification report by 30 April 2028 for the CORSIA period 2024 to 2026. 

Based on your annual emissions report and the CORSIA annual sector growth factor calculated by ICAO, the NEa will calculate your yearly CO₂ offsetting requirements. By 30 November, the NEa will inform you on your offsetting requirements for the previous year. Offsetting is calculated according to Implementing regulation - EU - 2024/1879 - EN - EUR-Lex.

The NEa will calculate the total final CO₂ offsetting requirements for the 2024-2026 period and will inform you of the total final CO₂ offsetting requirements by November 2027 for the CORSIA period 2024-2026.