Since January 1st, 2025, aircraft operators under the purview of the EU ETS have the added obligation of monitoring and reporting their non-CO2 effects, including soot particles, water vapour, nitrous oxides (NOx) and oxidised sulphur species. The monitoring and reporting requirements of non-CO2 aviation effects are included in the Monitoring and Reporting Regulation (MRR) 2018/2066.
It is important to note that, until at least 2028, there is no requirement to surrender EU ETS allowances for the reported non-CO2 effects. A thorough review will be conducted by the European Commission at that juncture to reassess the situation.
Aircraft operators are required to report the non-CO2 effects of their flights for the first time by March 31, 2026.
Scope
Only aircraft equipped with jet engines are subject to the monitoring, reporting, and verification (MRV) requirements for non-CO2 effects. Other types of aircraft are excluded from the non-CO2 MRV, even if they fall under the EU ETS for CO2 emissions. If an aircraft operator does not operate flights with a jet-engine aircraft, the non-CO₂ MRV obligation is not applicable to them.
As established in the ETS Directive, the monitoring and reporting of non-CO2 effects is mandatory for intra- and extra-European Economic Area (EEA) flights. However, to help facilitate the start of the monitoring and reporting on non-CO2 aviation effects, the European Commission has decided to implement a temporary derogation in the scope. For the initial two years (2025 and 2026) of the monitoring and reporting obligation, a reduced scope will apply. The scope is limited to include intra-EEA flights and flights from the EEA to Switzerland (CH) and the United Kingdom (UK). Voluntary reporting of flights outside the reduced scope is possible.
Monitoring methods and monitoring plan
The European Commission has developed two monitoring methods for the monitoring of non-CO2 aviation effects, Method C and Method D.
Method C is the standard method consisting of a weather-based approach, using primarily enhanced weather data, as well as flight information, trajectory data, aircraft properties and fuel properties.
Method D is a simplified monitoring method and consists of a location-simplified approach that may be used by small emitters (as defined in Article 55(1) of the MRR, i.e. < 243 flights per period for three consecutive four-month periods and < 25.000 tCO2 in the Full Scope). Method D uses primarily aircraft in-flight location-related data such as flight information, trajectory data, but also basic weather data and aircraft properties.
Under both Method C and D, aircraft operators may choose to use either primary or secondary data.
Primary data refers to information directly measured, monitored, or recorded by the operator (e.g., actual flight trajectory, engine identifiers, aircraft mass during flight, fuel flow, or fuel properties). This data is generally more accurate.
Secondary data refers to information supplied by the IT tool NEATS (Non-CO2 Aviation Effects Tracking System) without input from the operator. Using secondary data, the IT tool automatically calculates the climate impact of your flights’ non-CO2 effects. In this case, operators only need to verify the flight information in NEATS, while all other parameters are filled in with secondary data from external sources or default values.
For non-CO2 MRV, the MRR requires using an IT tool provided or approved by the European Commission (EC). The EC is launching a new IT tool called NEATS to automatise the monitoring and reporting process and the tool will be implemented, hosted and operated by EUROCONTROL.
However, NEATS was not available from January 1, 2025. According to Article 56b(6) MRR, in this situation aircraft operators must record flight information and aircraft properties per flight (defined in the MRR as the aircraft type, the engine(s) identifier(s) and the aircraft mass along the flight trajectory), and then enter the data into NEATS once the tool becomes operational.
How will NEATS work?
NEATS aims to simplify the process for aircraft operators, requiring them only to upload basic aircraft properties (such as type, engine identifier, and mass) and fuel properties. In case where no data is provided, default values will be used, offering the possibility of a fully automatic monitoring, reporting and verification process.
The collected data is then utilized in an emission module to initially compute emissions per flight. Subsequently, using open-source models, NEATS calculates the CO2 equivalent of these emissions for multiple time horizons (20, 50, and 100 years) based on the Global Warming Potential (GWP) metric. At the end of the reporting year NEATS will generate a report, which needs to be submitted to the competent authority.
NEATS provides the following key features:
Uploading of flight data by aircraft operator
Computation of non-CO2 aviation effects values
Generation of non-CO2 aviation effects annual report
Access for the accredited verifier specified by the aircraft operator and the relevant competent authority
Compliance with MRR reporting requirements and regulatory framework
As of 1 January 2025, all aircraft operators subject to the EU ETS must include monitoring methods with regard to the monitoring, reporting and verification of non-CO2 aviation effects in their monitoring plan.
EUROCONTROL has set up a NEATS User Group Sharepoint site – a central hub for updates and resources related to NEATS. Please register at the following link to access the Sharepoint.
Good to know: to access NEATS, you need to have an account in EUROCONTROL’s Azur B2C. After registration you are asked to set up a Two-Factor Authentication. More information on accessing NEATS can be found on Sharepoint (the link only works after registering to the NEATS User Group Sharepoint site).
Please note that your EUROCONTROL Azur B2C account (for the purpose of accessing NEATS) is not the same account as your EUROCONTROL Microsoft guest account (for the purpose of accessing Sharepoint/Teams/etc.).
Please designate a focal point in your company (or an authorized representative, if applicable) as soon as possible for the central administration of all your planned NEATS users and to create a NEATS user account for this person. After registration and logging in, you can select the name of the aircraft operator you are working for. The first user automatically becomes the focal point of the respective aircraft operator. The list of focal point(s) can be modified later.
More information on this process is available here (the link only works after registering to the NEATS User Group Sharepoint site).
You can upload the following data in NEATS:
flight information
flight trajectory
aircraft properties
flight fuel properties
Data needs to be uploaded in files using the JSON format.
Please note, data needs to be uploaded in files using the JSON format. All data you provide in this version of NEATS, will be used in later versions of NEATS and thus also for reporting purposes. If you upload and use test data in NEATS, you should delete the test data manually in NEATS before reporting.
More information on how to upload data in NEATS can be found here (the link only works after registering to the NEATS User Group Sharepoint site).
All relevant guidance on the use of NEATS can be found on the NEATS User Group Sharepoint site (the link only works after registering to the NEATS User Group Sharepoint site).
If you have any other questions, comments or if you encounter bugs or other issues using NEATS, please contact EUROCONTROL: neats@eurocontrol.int
For more general information on the inclusion of non-CO₂ aviation effects in the MRV framework, please refer to the FAQ section on the European Commission’s website, where you can find documentation on this topic.
