Aircraft operators – EU ETS compliance

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

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. 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. 2. Ensure that you can access your Aircraft Operator holding account in the Union Registry. Please use this link for further information.
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 (to include non-CO2 reporting from the 2025 reporting year onwards). This report must 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.
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. This report must be submitted using the EU Commission online portal – EU ETS Reporting.
No later than 30 September	Surrender allowances to account for your Verified Emissions via your AOHA on the Union Registry.
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.