EU ETS: monitoring and reporting
How to submit your verified emissions report when an improvement report is needed, and how to enter your emission in the EU Registry.
Aircraft operators: extension to 2013 compliance cycle
Aircraft operators must report 2013 aviation emissions (based on the reduced scope of the EU ETS) by 31 March 2015 and surrender a corresponding amount of allowances by 30 April 2015. The reporting and surrendering deadlines for aviation emissions for 2013 and 2014 will therefore be the same dates in 2015. However, two separate annual reports must be submitted.
This is a result of the European Commission’s regulation to temporarily amend the EU Emissions Trading Directive for aviation.
Timetable for monitoring and reporting
Start monitoring your emissions for the current reporting year in accordance with your approved monitoring plan or emissions plan.
By 28 February
Your regulator allocates free allowances to the EU Registry accounts of eligible operators.
By 31 March
Submit your verified annual emissions report for the previous reporting year. For example, emissions for 1 January to 31 December 2014 should be reported and verified by 31 March 2015. Excluded installation operators have the option to self-verify their emissions or to use an accredited (or certified) verifier.
Enter your reportable emissions from the previous year into the EU Registry. If you are an excluded operator, you don’t need to do this. But you do need to notify your regulator if your annual reportable emissions exceed the maximum amount in any year.
Your verifier approves your emissions in the EU Registry. Excluded operators don’t need to do this.
By 30 April
Surrender allowances equal to the value of your annual emissions in the EU Registry.
By 30 June
Submit your improvement report (if required). Excluded operators don’t need to do this.
By 31 December
Notify your regulator of any changes to your monitoring plan, capacity, activity level or operations. Some changes need to be notified sooner, or prior to making the change.
More information about types of changes you need to tell your regulator about and the time frames for doing this:
- Notifying changes
- EU ETS Phase III: guidance for installations
- EU ETS Phase III: guidance for aircraft operators
Enforcement and penalties for non-compliance
You must comply with EU ETS Regulations and your permit or emissions plan. The Environment Agency may impose civil penalties if you:
- carry out a regulated activity without a permit
- monitor your emissions incorrectly
- fail to submit a verified annual emissions report by the deadline
- under-report your emissions
- surrender insufficient allowances to cover your emissions
You must submit your verified annual emissions report on time or your regulator may determine your reportable emissions for you. They may charge you for their time.
See a list of civil penalties imposed by the Environment Agency.
More information about the Environment Agency’s approach to EU ETS enforcement and penalties is in Annex 4 of the Enforcement and sanctions guidance.
Verified emissions reports
Before you submit your emissions report to your regulator, you must first submit it to an accredited (or certified) verifier for verification in ETSWAP. Excluded installations can choose to self-verify or use an accredited (or certified) verifier.
Aircraft operators who emit less than 25,000 tonnes of CO2 per year (based on the full scope of the EU ETS) can choose to determine their emissions using Eurocontrol’s small emitters tool and data from its ETS Support Facility, or use an accredited (or certified) verifier.
Your verifier cannot complete your report: their role is to provide an independent check of your report.
Your verifier will assess the monitoring methods, information, data and calculations you have used. They are checking:
- omissions, misrepresentations or errors in your report
- that you have monitored and reported according to your approved monitoring or emissions plan and the Monitoring and Reporting Regulation
- whether the procedures you use to support your monitoring are effective
- whether you can improve your monitoring
After verifying your report, your verifier needs to send you a verification opinion statement (VOS) using ETSWAP. You then submit your report, with the VOS, to your regulator.
You must appoint a verifier that is accredited (or certified) for the regulated activity you are reporting.
You can appoint a UK based verifier that is accredited by the United Kingdom Accreditation Service (UKAS). Their website provides information about verification in the UK.
Or you can appoint a verifier accredited by a national accreditation body in another EU country. You will find details of other national accreditation bodies on the European Cooperation for Accreditation website.
It is good practice to appoint a verifier at least 9 months before you need to submit your report.
Verifier site visits to installations
Your verifier needs to be able to gather information and evidence. You need to provide them with access to your site so they can assess the operation of measuring devices and monitoring systems, and conduct interviews.
The site visit is also an opportunity for the verifier to assess whether you have correctly identified the boundaries of the site and whether there are any additional sources that should be included.
A site visit must be carried out by your verifier:
- at least once every 3 years or
- if you have changed verification companies or
- if there have been major changes to your monitoring plan since 1 January 2013
In exceptional cases, your verifier may decide that a site visited isn’t needed.
If, on the basis of a risk assessment, your verifier thinks that a site visit isn’t needed to your installation, your regulator needs to approve a site visit waiver. You must submit your request for a site visit waiver to your regulator via email and include your verifier’s risk assessment.
You need to submit your request by 30 September of the reporting year. This will allow enough time for your verifier to carry out a visit if your regulator refuses your request.
Installations that emit less than 25,000 tonnes of CO2 and excluded installations don’t need approval from the regulator for a site visit waiver. Your verifier must, however, still need to be able to justify their reasons for not visiting an installation.
All installations, including those emitting less than 25,000 tonnes of CO2 and excluded installations using an accredited (or certified) verifier must have had a site visit before 31 March 2014.
Verifier site visits to aviation operators
Your verifier needs to be able to gather information and evidence. If their risk analysis identifies that a visit to an aircraft or aerodrome is required, you must provide them with access, for example, to conduct interviews.
Access to a computer based, centralised database is also considered a site visit for aviation operators. In this instance, you may only need to provide your verifier with access to where you hold and store your monitoring data and relevant information.
If you are a small emitter and you have used the approved small emitter tool, your verifier may decide that a site visit isn’t necessary. The decision must be based on your verifier’s risk analysis.
Site visit waivers for aviation operators don’t require approval from your regulator.
Excluded installations: self-verified reports
Excluded installations can choose to either:
- appoint an accredited (certified) verifier to verify their annual emissions report or
- self-verify their emissions report and have it audited by their regulator
If you chose the second option, you need to submit your self-verified emission report via ETSWAP by 31 March. As part of self verification, you need to submit a notice to confirm that:
- you have complied with the Monitoring and Reporting Regulation and with your monitoring plan
- your report doesn’t contain any major errors or ‘material misstatements’
You need to make sure you have internal assurance systems in place to check your report is accurate. You must also keep records of all relevant data and information to support your reporting.
Your regulator will do a risk assessment of your report. If needed, they will ask you to provide more information for the audit.
Regulator audits are risk based and they will aim to audit each excluded installation at least twice during EU ETS phase III.
Regulators will audit higher risk excluded installations more frequently and they will audit those that emit more than 20,000 tonnes of CO2 annually.
Aircraft operators: who emit less than 25,000 tonnes of CO2 per year
Aircraft operators within this category can choose to either:
- appoint an accredited (certified) verifier to verify their annual emissions report, or
- report their emissions using Eurocontrol’s small emitters tool and data from its ETS Support Facility without the need for verification
In both cases you need to submit your emissions report via ETSWAP by 31 March .
Your regulator will audit your report and if needed will ask you to provide more information.
The 25,000 tonnes of CO2 per year threshold is based on the full scope of the EU ETS and includes all Annex I flights including extra-European and positioning flights.
Submit your emissions report
On 1 January each year you will receive an email telling you that a ‘Complete your emissions report’ task has been placed in your ETSWAP account work queue.
ETSWAP will send out email reminders to those operators that have not yet submitted their verified emissions report.
Help pages within ETSWAP provide guidance on how to submit your emissions report to your regulator after it has been verified.
Log in to the ETSWAP system.
Further guidance on reporting your emissions:
- EU ETS Phase III: guidance for installations
- EU ETS Phase III: guidance for aircraft operators
- EU Commission website: Monitoring, reporting and verification of EU ETS emissions
Aviation operators: no activity to report
If you haven’t carried out an aviation activity or a reportable flight during the reporting year, you don’t need to monitor your emissions or submit a verified report. However you do need to notify the regulator of this.
You notify the regulator by completing just the section of the report form in ETSWAP that states you have not performed an Annex 1 activity during the reporting year. You then submit the report form.
Reporting the use of bioliquids and biofuels
The Monitoring and Reporting Regulation states that if you are reporting an emission factor of zero in respect of the use of bioliquids or biofuels, you must satisfy your regulator that the sustainability criteria set out in Article 17 (2) to (5) of the Renewable Energy Directive (2009/28/EC) have been fulfilled.
This requirement also applies to excluded installations.
Appendix 3 of the document EU ETS Phase III: guidance for installations has more information on how to report the use of bioliquids.
The EC guidance document 3: biomass issues in the EU ETS has more information on the use of solid biomass.
You must keep records of all relevant data and information to support your emissions reporting for at least 10 years. Regulators will carry out periodic reviews of operators and will ask to see your supporting data as part of the audit. Verifiers will be checking this requirement is met as part of their verification.
Installations: improvement reports
To comply with the Monitoring and Reporting Regulation, you need to regularly check whether you can improve the way you monitor your emissions.
In some instances you need to tell your regulator how you are going to make improvements to your monitoring. You need to submit an improvement report using ETSWAP if you are an installation operator:
Not using the highest required tier for your monitoring
You need to submit an improvement report to your regulator explaining why. You also need to state how you will make improvements that will enable you to move towards using the highest tier in future.
Using a fallback approach for a major or minor source stream
You need to submit an improvement report to your regulator justifying why you cannot apply at least tier 1. You also need to explain how you will make improvements in future that will enable you to use tier 1.
In both of the examples, if you are not proposing any improvements, you need to explain why this is either not technically feasible, or would lead to unreasonably high costs.
The deadlines for submitting these improvement reports are:
- Category A installations – by 30 June every 4 years
- Category B installations – by 30 June every 2 years
- Category C installations – by 30 June every year
Verifier recommended improvement reports
Verifier recommended improvement reports apply to both installation and aviation operators.
You need to submit this type of improvement report if your verifier has identified non conformities in your emissions report, or is recommending improvements. Non conformities usually mean that you have not complied with your monitoring plan and/or reporting requirements.
A task called ‘Submit an improvement report’ will automatically be placed in your ETSWAP work queue if the emissions report you submitted contains a non-conformity or improvement identified by your verifier.
You need to submit a verifier recommended improvement report by 30 June. In the report, you need to describe how and when you will address the issues identified by your verifier.
If you believe that the improvements recommended would not improve your monitoring methodology, or would be unreasonably expensive, you must provide the reasons why and evidence to support this.
If you are an excluded installation with an accredited (or certified) verifier, or your annual emissions are less than 25,000 tonnes of CO2, you do not need to submit verifier improvement reports. But you should still consider the improvements your verifier recommends.
Enter your emissions into the EU Registry
You must enter your emission figure for the previous monitoring year into the EU Registry by 31 March.
Your verifier also needs to log into their Verifier account in the Union Registry and confirm your emissions are correct and match the figure submitted through ETSWAP. This also has to be done by 31 March, so you should enter your figure into the registry several days before the deadline to allow your verifier time to confirm your emissions.
If you have not carried out any regulated activities in a year, and have no emission to report, you must still enter an amount of zero into the EU Registry. If you don’t do this, your account will be blocked.
Once your emissions figure has been verified you are ready to surrender allowances to cover your emissions. You must do this by 30 April. See EU ETS: allowances for more information.
Excluded operators do not need to enter their emissions into the EU Registry or surrender allowances to cover their emissions. Instead, they need to meet emissions targets.
Log into EU Registry.
Excluded installations: annual emissions targets
If you are an excluded installation you have to meet an annual emissions target.
If your emissions are higher than your target, you will receive a civil penalty. You will have to pay a cost per tonne of CO2 you have emitted over your target. The cost will be set in line with the market price of carbon.
If your annual emissions are lower than your target, you will bank the over achievement for the next compliance year.
Your regulator will amend and re-issue your excluded installation permit to reflect the over achievement.
These guidance documents have more information on requirements for EU ETS:
The Commission has also produced guidance for operators:
- The Monitoring and Reporting Regulation – general guidance for installations
- The Monitoring and Reporting Regulation - general guidance for aircraft operators
- The Accreditation and Verification Regulation – general guidance on verification
For help with Union Registry queries:
Telephone: 01925 542 594 between 9am and 5pm
For other EU ETS queries contact your regulator
Installations, email: email@example.com
Aviation operators, email: firstname.lastname@example.org
Scottish Environment Protection Agency
National Resources Wales
Northern Ireland Environment Agency
Published: 23 April 2014
Updated: 8 June 2015
- The Environment Agency has explained that their approach to penalties is in line with their published Enforcement and sanctions guidance.
- New sections: 'Aircraft operators: extension to 2013 compliance cycle' 'Commercial and non-commercial aircraft operators who emit less than 25,000tCO2 per year'. Updates to section: 'Verified emissions reports'.
- First published.