Guidance: UK Emissions Trading Scheme for aviation: how to comply

Environment Agency

April 23
14:25 2024

About this guidance

You will need to comply with the UK ETS as soon as you become an aircraft operator.

This guidance will help aircraft operators understand and comply with their obligations under the UK ETS. These obligations are set out in full in The Greenhouse Gas Emissions Trading Scheme Order 2020 No.1265 (the order).

If you need to comply with the UK ETS, you must:

  • monitor your aviation emissions for each scheme year, which runs from 1 January to 31 December

  • report your aviation emissions by 31 March in the following year

Aviation emissions are emissions of carbon dioxide (CO2) arising from an aviation activity within the scope of the UK ETS.

You must also then surrender sufficient allowances to your aviation emissions by 30 April in the following year. This guidance explains how to carry out these steps.

If you do not comply with the UK ETS requirements you may have to pay significant civil penalties.

If you are not sure about your obligations, or any aspect of this guidance, please contact your regulator.

If you are (or expect to be) regulated by the UK under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), you should also refer to the guidance for the CORSIA.

Work out if the UK ETS applies to you

You will need to work out whether you are an aircraft operator under the UK ETS. You will be an aircraft operator if you are performing an aviation activity and have annual emissions from full scope flights above the threshold that applies to you.

There are different thresholds for commercial or non-commercial air transport operators.

Aviation activity

An aviation activity is a flight, other than an excluded flight, that departs from an aerodrome in the UK and arrives in an aerodrome in:

  • the UK (England, Northern Ireland, Scotland, and Wales)

  • an European Economic Area (EEA) state (excluding outermost regions)

  • Gibraltar

  • an offshore structure in the UK sector of the continental shelf

  • an offshore structure in the continental shelf of an EEA state

  • Switzerland

An aviation activity also includes any flight arriving at an aerodrome in the UK from an aerodrome in Gibraltar.

See The Greenhouse Gas Emissions Trading Scheme Order 2020 for full details about aviation activities and excluded flights.

Full scope flights

Full scope flights are those departing from or arriving in an aerodrome in the UK, Gibraltar, an EEA state, Switzerland, or outermost regions other than an excluded flight.

The EEA states are:

  • Austria

  • Belgium

  • Bulgaria

  • Croatia

  • Republic of Cyprus

  • Czech Republic

  • Denmark

  • Estonia

  • Finland (including land Islands)

  • France

  • Germany

  • Greece

  • Hungary

  • Ireland

  • Italy

  • Latvia

  • Lithuania

  • Luxembourg

  • Malta

  • Netherlands

  • Poland

  • Portugal

  • Romania

  • Slovakia

  • Slovenia

  • Spain (including Melilla and Ceuta)

  • Sweden

  • Norway (including Jan Mayen)

  • Iceland

  • Liechtenstein

The Basel-Mulhouse-Freiburg aerodrome (LFSB and LSZM) is in French territory.

The following are outermost regions:

  • the Canary Islands

  • French Guiana

  • Guadeloupe

  • Mayotte

  • Martinique

  • Runion

  • Saint-Martin

  • the Azores

  • Madeira

Threshold for commercial air transport operators

You are not an aircraft operator during a scheme year if you either:

  • operated fewer than 243 full scope flights in a 4-month period, for 3 consecutive 4-month periods

  • operated full scope flights with total annual emissions of less than 10,000 tonnes of CO2

Threshold for non-commercial air transport operators

You are not an aircraft operator if during a scheme year you operated full scope flights with total annual emissions of less than 1,000 tonnes of CO2.

Excluded flights

Flights by both fixed-wing and rotary-wing aircraft are excluded if the aircraft have a certified maximum take-off mass of less than 5,700 kilograms.

Several other types of flights are excluded from UK ETS, including military, search and rescue, firefighting and humanitarian flights.

The full list of excluded flights is set out in schedule 1 of the order.

Contact your regulator if you are unsure whether you are an aircraft operator.

If you think you may be an aircraft operator and have obligations under the UK ETS, you must first contact your regulator.

You must submit an emissions monitoring plan application within 42 days of the date you became an aircraft operator. If you miss this deadline you should contact your regulator as soon as possible.

UK ETS regulators

There are 4 regulators for aircraft operators regulated under the UK ETS. You are assigned a regulator based on the location of your registered office or place of residence. For:

If your registered office or place of residence is outside the UK, you may be transferred to another UK ETS regulator other than the Environment Agency. This will depend on the location of the departure aerodromes for the flights that generated most of your aviation emissions during the 2023 and 2024 scheme year. Any such transfer will happen at the start of the 2026 scheme year, following the end of the first allocation period on 31 December 2025.

When you contact your regulator, you will need to provide the:

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