Non-CO₂ Aviation Effects
Track emerging non-CO₂ aviation climate impact topics and how operators should prepare for future developments.
Latest regulatory updates
What changed recently
Competent Authorities
Several Member States extend Non-CO₂ reporting deadlines following NEATS implementation challenges
The initial deadline for submitting annual Non-CO₂ Aviation Effects reports expired on 30 June 2026. However, implementation challenges within the Non-CO₂ Aviation Effects Tracking System (NEATS), including unexpected technical issues and scheduled maintenance activities, have resulted in several Competent Authorities extending the reporting deadline for affected aircraft operators.
European Commission
Understanding reporting scope options under Non-CO₂ MRV
Aircraft operators subject to the EU ETS and Swiss ETS Non-CO₂ MRV requirements must select a reporting scope within their Monitoring Plan. The regulation provides three reporting scope options—Reduced Scope, In-between Scope and Full Geographical Scope—each determining the flights that must be monitored and reported.
What operators should know
Practical guidance for compliance teams
What operators should know
What changed?
Several Competent Authorities have extended the initial 30 June 2026 Non-CO₂ reporting deadline following technical issues and maintenance affecting the NEATS platform. Operators should also ensure their selected reporting scope within the Monitoring Plan reflects their intended reporting obligations.
Why is it important?
The chosen reporting scope determines which flights must be monitored, while revised reporting deadlines provide additional time to address system-related challenges without compromising compliance.
Who is affected?
Aircraft operators subject to the EU ETS or Swiss ETS Non-CO₂ MRV requirements, particularly those preparing and submitting their first annual Non-CO₂ report.
When does it apply?
Immediately. Operators should confirm the applicable reporting deadline with their administering Competent Authority and continue preparing their Non-CO₂ reports using NEATS.
What action should operators take?
Review your approved Monitoring Plan, verify the selected reporting scope, monitor updates from your Competent Authority, and submit the report as soon as all required calculations and validations have been completed.
Risks of non-compliance
Assuming all Member States have adopted the same reporting deadline or selecting an incorrect reporting scope may lead to incomplete reporting, Monitoring Plan inconsistencies or delayed regulatory submissions.
Emissence insight
Emissence insight
Successful Non-CO₂ compliance depends on more than meeting reporting deadlines. Operators that establish robust monitoring processes, maintain accurate operational data and engage early with their Competent Authority are better positioned to manage implementation challenges and future regulatory developments.
Common mistakes operators make
- Confirm that your approved Monitoring Plan reflects the intended reporting scope before preparing the annual report.
- Validate flight, aircraft and operational data early to minimise delays during NEATS processing.
- Monitor communications from your Competent Authority and NEATS support team for updates on reporting deadlines and system enhancements.
Recommended actions
- Do not wait until the revised reporting deadline to complete Non-CO₂ calculations and report preparation.
- Maintain evidence of technical issues encountered during reporting and communicate them promptly with your Competent Authority where necessary.
- Carry out an internal readiness review before submission to ensure reporting scope, calculations and supporting data are complete and consistent.
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