Drawing up a monitoring plan for ETS aviation

In the monitoring plan (MP) an aircraft operator defines how it will determine its emissions. This monitoring plan must meet specific requirements. The MP comprises a completed Excel document and, where appropriate, supporting documents.

Requirements for monitoring plan

The European Commission has laid down harmonised regulations for the way in which aircraft operators must monitor and report their emissions. The requirements regarding the content of the monitoring plan can be found in the European Monitoring and Reporting Regulation (MRR) and the Dutch Emissions Trading Regulation. See Monitoring requirements for ETS aviation for more information and guidance documents.


When drawing up the monitoring plan, aircraft operators must use the Monitoringplan format drawn up by the European Commission (template No. 2)

Supporting documents

In principle, two supporting documents should accompany the completed MP in Excel format:

  • Evidence for meeting the uncertainty thresholds

Here, the aircraft operator demonstrates that the determination of the quantity of fuel is in compliance with the applicable uncertainty level.

  • Results of risk assessment

Here, the aircraft operator outlines the results of the risk assessment carried out on the data flow activities, and indicates what control measures have been taken for mitigating the risks identified. Data flow activities means all activities performed for the acquisition, processing and recording of data relating to CO2 emissions.

Aircraft operators with annual emissions of less than 25,000 tonnes of CO2 do not need to submit any supporting documents. These operators are classified as small emitters.

Procedures for management, data flow and control

Aircraft operators must define and implement written procedures for management, data flow and control activities. These must ensure that the final emissions report does not contain any misstatements and has been produced in accordance with the monitoring plan. The procedures supplement the monitoring plan and must be summarised in it; they do not need to be submitted to the NEa. This allows the aircraft operator to revise the procedures without having to obtain approval.