Complying with the UK Emissions Trading Scheme (UK ETS) as an aircraft operator

This guidance will help you meet your obligations under the UK Emissions Trading Scheme (UK ETS) as an aircraft operator.

This guidance should be read in conjunction with the general UK ETS guidance.

Check whether you have obligations under the UK ETS

You have obligations under the UK ETS as soon as you become an aircraft operator. Failure to comply with obligations under the Order may result in significant civil penalties.

Definition of ‘aircraft operator’

An ‘aircraft operator’ is a person who performs an aviation activity above a threshold.

Aviation activity is a flight (other than an excluded flight) that departs from an aerodrome situated in the UK and arrives in an aerodrome situated in any of the following:

  • the UK
  • an EEA State (excluding outermost regions)
  • Gibraltar
  • an offshore structure in the UK structure of the continental shelf
  • an offshore structure in the continental shelf of an EEA state

An aviation activity also includes any flight arriving in an aerodrome situated in the United Kingdom from an aerodrome situated in Gibraltar.


To be an aircraft operator, you must also operate above the applicable threshold/s. The thresholds are different depending on whether you are a commercial or non-commercial air transport operator.

A commercial air transport operator is not an aircraft operator in relation to a scheme year where it operates either:

  • less than 243 full-scope flights per period for 3 consecutive 4-month periods
  • full-scope flights with total annual emissions of less than 10,000 tonnes of carbon dioxide

A non-commercial air transport operator is not an aircraft operator in relation to a scheme year where it operates full-scope flights with total annual emissions of less than 1,000 tonnes of carbon dioxide.

For a more detailed explanation of the thresholds, please refer to Article 7 and Article 8 of the Order.

Types of flight that are excluded

Several types of flights are excluded from meeting UK ETS obligations, including military, search and rescue, firefighting, and humanitarian flights. You have no UK ETS obligations in respect of excluded flights. The full list of excluded flights is in Schedule 1 of the Order.

Contact your regulator if you are in any doubt that you are under threshold or performing excluded flights.

Get a UK ETS Emissions Monitoring Plan (EMP)

Your regulator is responsible for issuing your EMP. Who your regulator will be depends on where you are registered or reside. The process for getting an EMP from your regulator will depend on whether you are currently regulated by the UK for the EU ETS.

If you are currently regulated by the UK for the EU ETS

Your regulator will remain the same and they will issue a UK ETS EMP in substantially the same terms as your EU ETS EMP on or after 1 January 2021. Your regulator should be in contact by the end of 2020 regarding your UK ETS EMP.

You will continue to have access to your account in your regulator’s online application and the Emissions Trading System Workflow Automation Program (ETSWAP).

If you are not currently regulated by the UK under the EU ETS

You must contact your regulator and apply for an EMP within 6 weeks of becoming an aircraft operator. If you have missed this deadline you must contact your regulator as soon as possible otherwise it may result in significant civil penalties.

Your regulator will depend on where you are registered or reside.

England or outside the UK: the Environment Agency (EA)

Scotland: the Scottish Environment Protection Agency (SEPA)

Wales: Natural Resources Wales (NRW)

Northern Ireland: the Northern Ireland Environment Agency (NIEA)

Opening an Aircraft Operator Holding Account in the UK ETS Registry

You must have an Aircraft Operator Holding Account (AOHA) in the UK ETS Registry to acquire and surrender allowances in line with your obligations.

Once your EMP has been issued, your regulator will instruct the Registry Administrator to open an AOHA for you. You will then be contacted by the Registry Administrator and asked to provide details of a primary contact (who is authorised to give instructions to the Registry Administrator on your behalf), and also to nominate authorised representatives to operate your AOHA for you.

Further information on on-boarding will be provided in early 2021.

The opening of a UK Registry account and validation of individuals must undergo the same scrutiny as when opening a bank account. This will include requesting any further information to satisfy the Registry Administrator that you are a fit and proper person to hold an account or act as an authorised representative in relation to an account. As such, this process can take up to 2 months (and longer in some cases).

Complying with your UK ETS obligations

To comply with your UK ETS obligations, you must:

  • comply with the conditions in your EMP
  • monitor your aviation emissions each year
  • in the following year, report your emissions and surrender a number of allowances equal to those emissions by the statutory deadlines

Failure to comply may result in significant penalties.

Compliance deadlines

Action Time
Monitor your aviation emissions in line with your EMP Between 1 January and 31 December in year n
Start preparing your annual emissions report (with time for verification, if required) Towards the end of year n
Submit your annual emissions report via ETSWAP By 31 March of year n+1
Surrender allowances equal to your reportable emissions By 30 April of year n+1

(‘n’ being a scheme year in which you are an aircraft operator)

Differences between the UK ETS and the EU ETS

The vast majority of processes in the UK ETS will be familiar to aircraft operators in the EU ETS.

The main differences are:

  • you must surrender UK Allowances for compliance in respect of emissions within the UK ETS
  • you must use a United Kingdom Accreditation Service (UKAS) accredited verifier accredited under ISO 14065 for the EU Emissions Trading Scheme. These accreditations will in due course be transitioned to the UK ETS. For further details, please see the UKAS website

You may choose from one of five fuel use monitoring methods (FUMM) approved for use in the CORSIA (currently only two out of five methods are approved for use by the EU ETS). One advantage is that this will enable those with both UK ETS and CORSIA obligations to use the same FUMM for both schemes.

You may use simplified reporting if you emit less than 3,000 tonnes of carbon dioxide per year from UK ETS aviation activities.

Verification and simplified reporting procedures

You can choose to use simplified reporting procedures if either of the following apply:

  • you emit less than 25,000 tonnes of carbon dioxide per year from full scope flights
  • you emits less than 3,000 tonnes of carbon dioxide per year from aviation activities

If you do not meet one of the criteria above, you must appoint an independent verifier to prepare your annual emissions report. The chosen verifier must be accredited for the regulated activity you are reporting.

It is your responsibility to provide your verifier with all the information that they need. A list of the minimum information that you need to provide is given in Article 10 of the Accreditation and Verification Regulation.

Changes in activity

You must let your regulator know about any changes in your operation that have taken place since your approved EMP was issued as this may mean you will need to vary your EMP. For example, any business reorganisation will necessitate a variation to your EMP and possibly to any free allocation entitlement.

Applying for free allocation

Free allocation of allowances to qualifying aircraft operators will continue, to reduce the risk of carbon leakage for businesses. Aircraft operators who wish to apply for free allocation must do so by 31 March 2021.

Read guidance on applying for free allocation.

If you are unhappy with a decision

If you are dissatisfied for any reason with a decision of your regulator, please discuss it with them first. In some cases, you may have a right of appeal, which your regulator will give you details about.

If you are dissatisfied for any reason with your verifier, please discuss it with them first. If you are still not satisfied, you should contact UKAS and inform your regulator.


CORSIA obligations

Only aeroplane operators registered or resident in the UK and its Crown Dependencies and Overseas Territories are attributed to the UK for regulation under CORSIA. All other aeroplane operators within scope of CORSIA will be regulated by the State in which they are registered or resident.

Aeroplane operators attributed to the UK for CORSIA purposes have already been monitoring and reporting their CORSIA emissions since 2019 and will need to continue to do so.

Proposals for legislating for CORSIA alongside the UK ETS will be consulted on in the coming months and the aim is for subsequent legislation to come into force by April 2022.

Remaining EU ETS obligations

Any EU ETS obligations for the scheme year 2020 still need to be met by aircraft operators currently regulated in the UK and this must be done via your existing regulator. This includes the requirement to submit a verified report by 31 March 2021 and surrender sufficient allowances to cover reportable emissions by 30 April 2021.

For EU ETS obligations arising in respect of scheme year 2021 and onward, the European Commission has advised that aircraft operators that are currently administered for EU ETS by the UK will be transferred to their new administering Member State indicated in the attribution list of aircraft operators published by the Commission.

Key definitions

Aircraft operator – an aircraft operator is a person who performs an aviation activity in a scheme year and is above the thresholds set out in Articles 7 and 8 of the Order.

Aviation activity – means a flight as defined in Schedule 1 of the Order other than one which is excluded under paragraph 2 of that Schedule.

Commercial air transport operator – means a person that, for remuneration, provides scheduled or non-scheduled air transport services to the public for the carriage of passengers, freight or mail and holds an air operator certificate (AOC) or equivalent document as required by Part I of Annex 6 to the Chicago Convention.

Non-commercial air transport operator – a person who operates flights and is not a commercial air transport operator.

CORSIA SARPs – CORSIA Standards and Recommended Practices, Annex 16, Volume IV.

Emissions Monitoring Plan (EMP) – A document setting out how the aircraft operator’s aviation emissions are to be monitored for the purposes of the Order.

Full-scope flight – means a flight departing from, or arriving in, an aerodrome situated in the United Kingdom, Gibraltar or an EEA state, other than an excluded flight.

The Order – Refers to The Greenhouse Gas Emissions Trading Scheme Order 2020.

Published 17 December 2020
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