Aircraft operators – EU ETS compliance

The EU Emissions Trading System (EU ETS) applies to carbon dioxide (CO2) emissions from regulated aircraft operators.

Aircraft operators should review the EPA Infographic on how they can comply with their obligations under the EU ETS.

More detail is given in the quick guide for aircraft operators available from the EU Commission and on the Commission pages on monitoring and reporting.  

Aircraft operators should note these key dates for their EU ETS compliance:

Key dates for Aviation EU ETS compliance
Date / Deadline What to do 
1 January of Year X

Calculate emissions from the previous calendar year (Year X-1) 

1. If you have not already done so, start compiling your Annual Emissions Report (AER) for emissions in Year X-1 (i.e. the previous calendar year). Assuming you were above the relevant threshold in year X-1.

2. Appoint or contact your chosen accredited verifier. Make sure they have capacity to verify your Annual Emissions Report so that you can submit this to the EPA by the reporting deadline of 31 March in Year X. 

Current reporting year: Year X  

1. Start monitoring your CO2 emissions and collecting data for the current reporting Year X.

This must be done in accordance with your approved Annual Emissions Monitoring Plan.

2. Log onto your Aircraft Operator Holding Account (AOHA) on the Union Registry and ensure that your Authorised Representatives remain up-to-date. 

Commence the update process if changes to these personnel are required. Contact the Union Registry Team at ETRAdmin@epa.ie for further instructions. 

Remember that the monitoring, reporting and verification (MRV) of greenhouse gas emissions must be robust, transparent, consistent and accurate for the EU ETS to operate effectively.

If you are a small emitter (see the definition in the quick guide for aircraft operators) you may use a  simplified approach to monitoring and reporting.
1 January – 31 December 

You must notify the EPA if you have changes to your approved Annual Emissions Monitoring Plan (e.g. changes to the fuels used, your fleet list or monitoring procedures).

Contact avets@epa.ie for details on how to do this.

No later than 31 March

1. Submit a Verified Annual Emissions Report for Year X-1 to the EPA by the reporting deadline of 31 March in Year X.

From 2022 this report will be submitted using the EU Commission online portal – EU ETS Reporting

2. Enter your Verified Emissions (VE) figure via your AOHA on the Union Registry. 

One of the Authorised Representatives on your AOHA enters this VE figure.

3. Ensure your Verifier approves your VE figure on the Union Registry.

No later than 30 April

Surrender allowances to account for your Verified Emissions via your AOHA on the Union Registry

As a rule, two Authorised Representative are required for surrender.

No later than 30 June  

Submit an Improvement Report by 30 June each year where the Verification Report contains outstanding non-conformities, misstatements or recommendations for improvement.

From 2022 this report will be submitted using the EU Commission online portal – EU ETS Reporting

No later than 31 December  

Ensure that any non-significant modifications to the approved Annual Emissions Monitoring Plan have been notified to the EPA.

No later than 31 December  

Complete monitoring your CO2 emissions and collecting data for the current reporting Year X.

This must be done in accordance with your approved Annual Emissions Monitoring Plan.