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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.

Monitoring PlanEuropean CommissionJuly 4, 2026

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Full summary and practical implications

The Non-CO₂ MRV framework requires aircraft operators to specify a geographical reporting scope within their approved Monitoring Plan.

Three reporting scope options are available: Reduced Scope, In-between Scope and Full Geographical Scope.

Under the EU ETS Reduced Scope, operators report flights departing from an aerodrome located within the European Economic Area (EEA), including its Outermost Regions (OMRs), and arriving at another aerodrome within the EEA, Switzerland or the United Kingdom.

Under the Swiss ETS Reduced Scope, operators report flights departing from Switzerland and arriving within Switzerland, the EEA or the United Kingdom.

The In-between Scope includes all flights covered under the Reduced Scope together with additional route pairs specified in the Implementing Regulation. For EU ETS operators, these are the route pairs where an EEA Member State is the "First State in the pair". For Swiss ETS operators, these are the route pairs where Switzerland is the "First State in the pair".

The In-between Scope does not allow operators to freely select any additional routes. Only the predefined route pairs identified in the regulation may be included.

Under the EU ETS Full Geographical Scope, operators report all flights arriving at or departing from an aerodrome located within the EEA, including its Outermost Regions, except flights departing from Switzerland or the United Kingdom.

Under the Swiss ETS Full Geographical Scope, operators report all flights arriving at or departing from Switzerland, except flights departing from the EEA or the United Kingdom.

Selecting the appropriate reporting scope influences flight coverage, monitoring procedures, data collection requirements and annual verification activities.

Operators should carefully assess their operational network and reporting objectives before selecting or amending the reporting scope within their Monitoring Plan.

Operator actions

What your team should do next

Review your approved Non-CO₂ Monitoring Plan to confirm the selected reporting scope.

Determine whether the Reduced, In-between or Full Geographical Scope best reflects your operational network.

Ensure internal systems correctly identify all reportable flights based on the selected scope.

Verify that the necessary trajectory, aircraft, engine and fuel data are available for all reportable flights.

If considering the In-between Scope, confirm that any additional routes are permitted under the Implementing Regulation.

Update monitoring procedures and supporting documentation whenever the reporting scope changes.

Discuss reporting scope expectations with your verifier before the reporting period begins.