The precise requirements for monitoring in aviation are described in the Regulation, which has been in force since 01/01/2013 (last amended on 01/01/2025).
Since 01/01/2019, aircraft operators from all ICAO member states have also been obliged to monitor their carbon dioxide emissions as part of .
In the European Union, the requirements of CORSIA were implemented by means of a delegated regulation of the EU Commission on the Emissions Trading Directive, which declares the amended Monitoring Regulation applicable to routes covered by CORSIA. This means that the EU ETS 1 MRV also applies to all CORSIA routes for aircraft operators based in the EEA.
Monitoring Plan
In a given trading period, all aircraft operators participating in emissions trading must immediately create a plan for monitoring and determining their emissions of carbon dioxide (), either at the beginning of each period, or upon initially engaging in aviation activities which are subject to emissions trading. This monitoring plan is the basis for annual reporting both in terms of content and technically. It specifies the requirements of the Regulation for each aircraft operator.
At the same time, a monitoring plan created with the Form Management System (FMS) is a technical prerequisite, as an emissions report (EmB) can only be created and produced on the basis of a monitoring plan created in the FMS.
Use of sustainable aviation fuels
If an aircraft operator intends to report sustainable aviation fuels in the EU ETS 1, the monitoring plan must first be adapted accordingly and submitted to DEHSt for approval. The sustainability of biomass components must be verified with the corresponding proofs of sustainability in the Sustainable Biomass System (Nabisy) of the Federal Office for Agriculture and Food.
Detailed information on the content and technical requirements for the monitoring and reporting of biofuels with regard to accounting in the EU ETS 1 for aviation is explained in Chapter 6 of the DEHSt Guidelines for Aircraft Operators. In principle, the same regulations also apply to aircraft operators based in the EEA on all routes.
Procedure for the creation of monitoring plans
Our FMS is available for the creation of monitoring plans. Electronic communication between aircraft operators or their authorised representatives, verifiers and the German Emissions Trading Authority (DEHSt) takes place via the Virtual Post Office (VPS).
To import large amounts of data into the FMS, we provide an XML interface. Small emitters can also make use of the simplified procedure for determining fuel consumption and estimate their fuel consumption and associated CO2 emissions using a tool (see answers LV 010 and LV 033).
FAQs
All aircraft operators (commercial and non-commercial) that are subject to the emissions trading and are allowed to use a simplified procedure (see answer LV 033) may make use of an appropriate estimation tool in the emissions reporting and estimate their fuel consumption and CO2 emissions.The tools shall be used only if they are approved by the European Commission. The approved tools must be used in their respectively valid version.
The tools must be able to process all the relevant Eurocontrol data and to prevent an underestimation of emissions. The tools shall be used only if they are approved by the European Commission. The approved tools must be used in their respectively valid version.
The European Commission has approved the so-called Small Emitters Tool (SET) for use in the European Union emission trading system (EU ETS 1) (see Commission Regulation (EU) Number 606/2010 of 09/07/2010).
The tool was developed by Eurocontrol, the European Organisation for the Safety of Air Navigation. The tool and a description is available free of charge on the Eurocontrol website. There is also the possibility for an instant delivery registration if you wish to receive each release of the tool by e-mail. When reporting emissions, care must be taken to always use the current version for the corresponding reporting year.
Another option for using the simplified procedure is the Eurocontrol Support Facility. For this purpose, aircraft operators must set up an access and the emissions report must be prepared entirely with data from the Eurocontrol Support Facility. When using this procedure, the verification of the emission report can be waived (see answer LV 038). Using the Small Emitters Tool is not sufficient for a waiver of the verification; in this case the emission report still has to be verified by independent third parties.
For the reporting years from 2013 on, those aircraft operators who operate fewer than 243 flights per period in three consecutive four-month periods within one year and those aircraft operators who operate flights with total annual emissions less than 25,000 tonnes of per year can use a simplified procedure (see Article 55 Regulation).
For the purpose of verifying whether an aircraft operator is above or below one of these two relevant thresholds, the fundamental geographical scope of the Emissions Trading Directive ("full scope") is relevant and not the reduced geographical scope.
In addition, for the reporting years starting in 2017, aircraft operators operating flights with total annual emissions of less than 3,000 tonnes of CO2 per year relative to the reduced geographical scope can now also use a simplified procedure (Article 28a, paragraph 4 Emissions Trading Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 and amending Council Directive 96/61/EC (as of 5 June 2023).
Furthermore, to determine the number of flights performed and the amount of annual emissions, all flights that do not fall under an exemption pursuant to Annex 1 Part 2 Number 33 (including those free of charge) but have been conducted by an aircraft operator must be taken into account.
From 01/01/2025, aircraft operators are also obliged to determine the non--effects they cause for each flight and report them to the responsible competent authority as part of emissions reporting. The necessary monitoring and reporting rules are currently being developed by the European Commission and are due to be published on 31/08/2024. The non--effects mainly include contrails and atmospheric changes caused by nitrogen oxide emissions. Detailed information on non- effects and their significance can be found in the UBA brochure „Climate Impact of Aviation“.
