The EU Emissions Trading System (EU ETS) is the world's first major carbon market and remains the cornerstone of the EU's policy to combat climate change. This checklist outlines the annual compliance cycle for operators of stationary installations and aircraft operators covered by the system.
Phase 1: Permitting and Monitoring Plan
- Obtain a GHG Emissions Permit: Ensure your installation has a valid greenhouse gas emissions permit from the national competent authority before commencing operations.
- Develop a Monitoring Plan: Create a detailed monitoring plan in accordance with the Monitoring and Reporting Regulation (MRR). This plan must be approved by the competent authority.
- Implement the Monitoring Plan: Continuously monitor emissions throughout the calendar year strictly following the approved plan. Any significant changes to the plan must be approved.
Phase 2: Reporting and Verification (Q1)
The first quarter of the year is critical for reporting the previous year's emissions.
- Draft the Annual Emissions Report (AER): Compile the monitored data into the AER format required by your national authority.
- Engage an Accredited Verifier: Contract an independent verifier accredited under the Accreditation and Verification Regulation (AVR).
- Undergo Verification: The verifier will assess the AER against the monitoring plan and the MRR. Address any misstatements or non-conformities identified.
- Submit the Verified AER: Submit the verified Annual Emissions Report to the competent authority by 31 March.
Phase 3: Surrendering Allowances (Q2)
- Open a Registry Account: Ensure you have an active operator holding account in the Union Registry.
- Calculate Allowance Requirement: Confirm the exact number of allowances needed based on the verified emissions report (1 allowance = 1 tonne of CO2 equivalent).
- Acquire Allowances: Obtain the necessary allowances through free allocation (if eligible), auctions, or the secondary market.
- Surrender Allowances: Surrender the required number of allowances in the Union Registry by 30 September (Note: The deadline was changed from 30 April to 30 September starting in 2024).
Phase 4: Continuous Improvement
- Submit Improvement Reports: If the verifier identified areas for improvement, or if you are not meeting the highest tier requirements, submit an improvement report to the competent authority.
- Monitor Regulatory Changes: Stay updated on changes to the EU ETS, such as the inclusion of maritime transport or the phase-out of free allocations.