Installations
Schedule 2 activities, including combustion where total rated thermal input exceeds 20 MW; they hold a permit.
SI 2020/1265 Sch 2UK ETS · Requirements
UK ETS reporting requirements in the UK: monitor, report, verify, surrender
The UK ETS reporting requirements are an annual cycle: an installation, aircraft operator or maritime operator monitors its emissions over the calendar year, has them verified, reports them to its regulator by 31 March and surrenders allowances by 30 April.
They are set by the Greenhouse Gas Emissions Trading Scheme Order 2020, which was extended to shipping on 1 July 2026.
Before the detail
UK ETS reporting requirements, in brief
The UK Emissions Trading Scheme is a cap-and-trade scheme that started on 1 January 2021, and its reporting requirements are monitoring, reporting and verification, known as MRV, followed by surrender.
The scheme is run by the UK ETS Authority, a partnership of the UK Government, the Scottish Government, the Welsh Government and the Northern Ireland Department of Agriculture, Environment and Rural Affairs.
It is enforced by five regulators, and the duties fall on operators, never on a group as a whole.
It is not an annual report disclosure: the place for those is the UK sustainability reporting requirements hub.
How the scheme works as a market, from the cap to the auction reserve price, is on our UK ETS guide; this page sets out what each participant must do.
In one table
The UK ETS reporting requirements, one line each
Each requirement, who owes it, its deadline and the source.
The scheme year is the calendar year.
| Requirement | Who | When | Source |
|---|---|---|---|
| Hold a greenhouse gas emissions permit, or an HSE permit | Installations | Apply at least 2 months before operating | Order art 26; installations guidance |
| Hold an approved emissions monitoring plan | Aircraft and maritime operators | Maritime: apply within 42 days of first activity | Order arts 28–32; Sch 2A |
| Monitor emissions to the approved plan and the MRR | All operators | 1 January to 31 December | Installations guidance |
| Appoint a UKAS-accredited verifier | All operators | Regulators advise by July | Installations guidance |
| Submit a verified annual emissions report | All operators, HSEs included | By 31 March | Participating in the UK ETS |
| Submit a verified activity level report | Installations with free allocation | By 31 March | Participating in the UK ETS |
| Surrender allowances equal to reportable emissions | Installations and aircraft operators | By 30 April | Order arts 27, 34; art 52 |
| Surrender for 2026 and 2027 together | Maritime operators | By 30 April 2028 | Participating in the UK ETS |
| Submit improvement reports | Installations, where required | By 30 June | Installations guidance; MRR art 69 |
| Notify non-significant monitoring plan changes | Installations | By 31 December | Installations guidance |
| Monitor and notify if over 2,499 tCO₂e | Ultra-small emitters | Ongoing | Order Sch 8 |
| Keep records of relevant data | All operators | At least 10 years | Installations guidance |
Who is in scope
Three kinds of participant, one cycle
The DESNZ guidance says the scheme applies to energy-intensive industries, power generation, aviation and maritime activity, listed in Schedules 1, 2 and 2A to the Order.
For installations the commonest test is combustion of fuels on a site where combustion units with a total rated thermal input exceeding 20 MW are operated.
Installations whose main purpose is incinerating hazardous or municipal waste are outside that entry.
Aviation covers UK domestic flights, flights between the UK and Gibraltar, and flights departing the UK to the European Economic Area and to Switzerland, flown by any operator whatever its nationality.
Maritime covers ships of 5,000 gross tonnage and above, regardless of flag, for voyages beginning and ending in UK ports and for emissions at berth and within ports.
The two transport sectors are explained in depth on the UK ETS aviation and maritime page.
A regulated activity under the Order
Aircraft operators
UK domestic flights, UK–Gibraltar, and departures to the EEA and Switzerland; they hold a monitoring plan.
DESNZMaritime operators
Ships of 5,000 GT and above on domestic voyages and in UK ports, from 1 July 2026.
SI 2026/392Installations
Permit, monitoring plan and the annual cycle
An operator must hold a greenhouse gas emissions permit, or a hospital or small emitter permit, before carrying out a regulated activity, and the installations guidance says to apply at least two months before starting.
The permit includes an approved monitoring plan and conditions to monitor, report verified emissions, surrender allowances and notify changes.
Monitoring follows the Monitoring and Reporting Regulation, with simplifications for installations emitting less than 25,000 tonnes of CO₂ equivalent a year.
The verified annual emissions report for the previous scheme year is due by 31 March, and an installation with free allocation also submits a verified activity level report by the same date.
A change of more than 15% in activity against historic levels triggers a recalculation of free allocation.
Improvement reports are due by 30 June: every four years for category A installations, every two years for category B and every year for category C, and after verifier non-conformities or recommendations.
A significant change to the monitoring plan needs a permit variation at least 14 days in advance, and non-significant changes are notified by 31 December.
Records of all relevant data are kept for at least 10 years, and regulators audit annual reports periodically.
The separate air-quality permitting regime for the same sites is covered on the environmental permitting and air emissions page.
- 1
Monitor from 1 January
Follow the approved monitoring plan and the Monitoring and Reporting Regulation for the whole calendar year.
- 2
Verify by 31 March
A UKAS-accredited verifier checks the annual emissions report and any activity level report.
- 3
Report by 31 March
Submit the verified report to the regulator through METS; it is not submitted until that step is done.
- 4
Surrender by 30 April
Surrender allowances in the UK ETS Registry equal to the reportable emissions.
- 5
Improve by 30 June
Submit improvement reports where the tiers or the verifier’s findings require them.
Assurance
Verification: accredited, independent, on site
Every UK ETS emissions report is verified, which makes the UK ETS one of the few UK regimes where independent verification is a legal requirement.
The verifier must be accredited by the United Kingdom Accreditation Service to ISO 14065 and the Verification Regulation, with a scope covering the regulated activity reported, the installations guidance says.
UKAS supervises verifiers and keeps the list, and a verifier need not have a UK office, according to DESNZ.
A site visit is needed if there has not been one in the two preceding reporting years, or four for remote locations such as offshore, and whenever the verifier or a significant part of the monitoring plan changes.
The opinion is “verified”, “verified with comments” or “not verified”, and only the first two make the report satisfactory.
Without a satisfactory report by 31 March, the regulator determines the emissions itself, may recover its costs and may impose a civil penalty.
The standards and accreditation behind this are explained on the GHG verification standards and UKAS accreditation pages.
Aviation and maritime
Aviation and maritime as they stand on 11 October 2026
An aircraft operator holds an emissions monitoring plan, reports verified emissions by 31 March and surrenders by 30 April, unless exempted under articles 7 or 8 of the Order for that year.
Free allocation for aircraft operators has been phased out from 2026, so every allowance surrendered now has to be bought.
International flights outside these routes fall under CORSIA, a separate regime under the Air Navigation (CORSIA) Order 2021 with its own verified emissions reports.
The maritime extension, made by SI 2026/392, has applied since 1 July 2026, with offshore vessels added from 1 January 2027.
A maritime operator applies for a monitoring plan within 42 days of its first maritime activity and reports verified emissions of three gases by 31 March after each scheme year.
Its first surrender, by 30 April 2028, covers the 2026 and 2027 scheme years together, from 1 July 2026 to 31 December 2027.
Government and military ships, fish-catching and fish-processing ships, and ferries serving Scottish islands and remote peninsulas are exempt.
| Requirement | Aircraft operators | Maritime operators |
|---|---|---|
| Plan | Emissions monitoring plan | Monitoring plan, applied for within 42 days of first activity |
| Gases | Carbon dioxide | Carbon dioxide, methane, nitrous oxide |
| Verified report | By 31 March | By 31 March after each scheme year |
| Surrender | By 30 April | By 30 April 2028 for 2026–27, then annually |
| Free allocation | Phased out from 2026 | None |
| Regulator | By registered address; EA if outside the UK | By registered address; EA if outside the UK |
Opt-outs
Hospitals, small emitters and ultra-small emitters
Small installations can opt out of surrender, but not out of reporting.
A hospital or small emitter must still report its annual emissions, and is subject to an emissions target instead of a surrender obligation.
For 2026–2030 the Order’s Schedule 7 sets a maximum of 24,999 tonnes of CO₂ equivalent, biomass excluded, and for combustion a rated thermal input below 35 MW.
If an HSE’s emissions exceed its target, article 54 imposes a penalty equal to the excess multiplied by the carbon price.
An ultra-small emitter, with no more than 2,499 tonnes under Schedule 8, needs no permit but must monitor its emissions and tell its regulator if it goes over.
Both statuses are granted by list or application, not automatically, and the window for 2026–2030 has closed.
| Status | Emissions ceiling | Permit | Report | Surrender |
|---|---|---|---|---|
| Standard installation | None | GHG emissions permit | Verified, by 31 March | Yes, by 30 April |
| Hospital or small emitter | 24,999 tCO₂e; combustion below 35 MW | HSE permit | Annual | No: emissions target instead |
| Ultra-small emitter | 2,499 tCO₂e | None | Monitor; notify if exceeded | No |
Who enforces
The UK ETS regulators
| Regulator | Installations | Aircraft and maritime operators |
|---|---|---|
| Environment Agency | England | Registered in England, or outside the UK |
| Scottish Environment Protection Agency | Scotland | Registered in Scotland |
| Natural Resources Wales | Wales | Registered in Wales |
| Northern Ireland Environment Agency | Northern Ireland | Registered in Northern Ireland |
| OPRED (for DESNZ) | Offshore installations | — |
The Order extends to the whole of the UK, but Northern Ireland electricity generators remain in the EU ETS under the Windsor Framework.
How each UK regime divides by nation is set out on the UK regimes by jurisdiction page.
Enforcement
Penalties for missing a UK ETS requirement
| Failure | Civil penalty | Order |
|---|---|---|
| Operating an installation without a permit | Costs avoided plus estimated emissions × the carbon price, which the regulator may increase | art 50 |
| Breaching a permit condition, such as reporting late | £20,000, plus £500 a day up to a maximum of £45,000 | art 51 |
| Not surrendering enough allowances by 30 April | £100 × the inflation factor for each allowance not surrendered; name published | arts 49, 52 |
| HSE exceeding its emissions target | Excess emissions × the carbon price | art 54 |
| Aircraft operator not reporting | £20,000, plus £500 a day up to a maximum of £45,000 | art 64 |
| Maritime operator: no plan, no monitoring or no report | £20,000, plus £500 a day up to a maximum of £45,000 | arts 64B–64E |
| False or misleading information | Civil penalty | art 67 |
The installations guidance says the surrender penalty applies even if the operator surrenders in full after 30 April.
A deficit notice can still require the missing allowances, and the obligation follows a permit if it is transferred.
Regulators must publish the name of every person given the excess emissions penalty, under article 49.
What is changing
The UK ETS Authority’s expansion decisions
Each item below is labelled by status, because the Authority’s policy overview mixes decisions, consultations and delays.
Decided and in force: maritime from 1 July 2026, offshore vessels from 1 January 2027, and a £28 auction reserve price from 8 April 2026, index-linked from 1 January 2027 by SI 2026/214.
Decided: the scheme continues into a Phase II from 2031 to 2040, with banking of allowances between phases.
Decided and legislated: free allocation for CBAM sectors phases out from 2027, at a factor of 0.975 for 2027 falling to 0.775 for 2030 under SI 2026/278, following the free allocation review.
Delayed: waste incineration will not join in 2028, the Authority said on 26 August 2026, and the MRV-only period from 1 January 2026 is voluntary.
Planned: greenhouse gas removals, with legislation aimed for by the end of 2028 and the system expected to operate by the end of 2029, subject to further consultation.
Consulted on, no decision: international maritime voyages (closed 20 January 2026), sustainable aviation fuel (closed 15 June 2026) and free allocation rules for hydrogen production (closed 2 October 2026).
Not yet agreed in law: linking with the EU ETS, which the UK and EU committed to work towards in the May 2025 Common Understanding.
Other UK regimes
How UK ETS reporting sits beside SECR, ESOS and CBAM
A UK ETS installation’s verified emissions are also part of its owner’s Scope 1 figure under SECR, and the SECR rules are on the SECR reporting requirements page.
SECR and the other GHG reporting requirements are disclosures with no legal verification requirement; the UK ETS report is a verified regulatory return.
ESOS is a separate energy audit duty and can apply to the same group, as the ESOS reporting requirements page explains.
Climate Change Agreements are a voluntary tax-discount scheme, not an MRV regime, and are covered on the Climate Change Agreements page.
UK CBAM, from 1 January 2027, prices the same five industrial sectors’ imports, and its own duties are on the CBAM reporting requirements page.
Things the UK ETS does not require
No annual report disclosure: the verified report goes to the regulator, not to shareholders.
No surrender for hospitals and small emitters, but annual reporting all the same.
No UK ETS duty on waste incineration in 2028, despite the earlier plan.
No international maritime coverage yet: only domestic voyages and in-port emissions.
Check yourself
Six statements about UK ETS requirements
Each answer names the provision or guidance it turns on.
The scheme’s cap, price and market are on the UK Emissions Trading Scheme page.
Where UK ETS data meets wider carbon disclosure, see the carbon reporting requirements page.
True or false?
Surrendering allowances in May avoids the excess emissions penalty.
A hospital or small emitter still reports its emissions every year.
Any accredited verifier anywhere may verify a UK ETS report.
Maritime operators surrender for 2026 and 2027 together in 2028.
Waste incineration joins the UK ETS on 1 January 2028.
The combustion test covers sites with total rated thermal input of exactly 20 MW.
0 of 6 answered.
Nothing you choose is stored or sent.
Frequently asked
UK ETS reporting requirements, answered
What are the UK ETS reporting requirements?
A covered operator holds a permit (installations) or an emissions monitoring plan (aircraft and maritime operators), monitors its emissions across the calendar scheme year, submits a verified annual emissions report to its regulator by 31 March, and surrenders allowances equal to its reportable emissions by 30 April.
Installations with free allocation also submit a verified activity level report by 31 March.
The law is the Greenhouse Gas Emissions Trading Scheme Order 2020.
Who is covered by the UK ETS?
Operators of installations carrying out an activity in Schedule 2 to the Order, including combustion where total rated thermal input exceeds 20 MW; aircraft operators flying covered routes; and, since 1 July 2026, maritime operators of ships of 5,000 gross tonnage and above on domestic voyages and in UK ports.
The DESNZ guidance says the scheme covers heavy industry, power, aviation and domestic maritime, approximately 25% of UK territorial emissions.
When is the UK ETS emissions report due?
By 31 March each year, covering the previous calendar scheme year, for installations, aircraft operators and maritime operators.
The report must be verified as satisfactory by a UKAS-accredited verifier and submitted through the Manage your UK ETS reporting service (METS).
When must UK ETS allowances be surrendered?
By 30 April each year, equal to the reportable emissions of the previous scheme year.
Maritime operators are the exception for the first cycle: they surrender for 1 July 2026 to 31 December 2027 together by 30 April 2028, then annually from the 2028 scheme year.
What is the penalty for not surrendering UK ETS allowances?
The excess emissions penalty under article 52 of the Order: £100 multiplied by an inflation factor for each allowance not surrendered.
GOV.UK says it applies even if the allowances are surrendered in full after 30 April, and the regulator must publish the name of every operator penalised.
A deficit notice can still require the missing allowances.
Who verifies UK ETS reports?
An independent verifier accredited by UKAS to ISO 14065 and the Verification Regulation, with a scope covering the activity reported.
The verifier’s opinion must be verified or verified with comments for the report to count as satisfactory; otherwise the regulator determines the emissions and may recover its costs.
Who regulates the UK ETS?
The Environment Agency for England (and for aircraft and maritime operators registered in England or outside the UK), SEPA for Scotland, Natural Resources Wales, the Northern Ireland Environment Agency, and OPRED for offshore installations.
The UK ETS Authority — the UK Government, Scottish Government, Welsh Government and DAERA — sets policy.
What is a hospital or small emitter in the UK ETS?
An installation with HSE status, for which the 2026–2030 conditions include reportable emissions of no more than 24,999 tCO₂e and, for combustion, rated thermal input below 35 MW.
An HSE still holds a permit, monitors and reports annually, but meets an emissions target instead of surrendering allowances.
HSE status is by application or list, not automatic.
What is an ultra-small emitter?
An installation with USE status and reportable emissions of no more than 2,499 tCO₂e.
It does not hold a permit but must still monitor its emissions and notify its regulator if it goes over the threshold.
The application window for 2026–2030 status has closed.
Does the UK ETS cover shipping?
Yes, since 1 July 2026, for ships of 5,000 gross tonnage and above regardless of flag, covering carbon dioxide, methane and nitrous oxide from domestic voyages and in-port activity.
Offshore vessels are added from 1 January 2027.
International voyages were consulted on in November 2025 and are not yet in scope.
What do maritime operators have to do?
Apply for an emissions monitoring plan within 42 days of their first maritime activity, monitor emissions, submit a verified annual emissions report by 31 March after each scheme year, and surrender allowances, first by 30 April 2028 for the 2026 and 2027 scheme years together.
Does the UK ETS cover waste incineration?
Not yet.
In August 2026 the UK ETS Authority confirmed that expansion to waste incineration will not take place in 2028 as originally intended, with a new timeline to follow.
A monitoring, reporting and verification-only period began on 1 January 2026, and participation in it is voluntary.
How long must UK ETS records be kept?
The installations guidance says operators must keep records of all relevant data and information for at least 10 years, in practice 10 years from the date the report was submitted, including the data used to prepare it.
Is the UK ETS linked to the EU ETS?
Not as at 11 October 2026.
The UK and EU agreed in May 2025 to work towards linking, and press reports in October 2026 said a deal had been reached, but no agreement had been published or brought into law.
Northern Ireland electricity generators remain in the EU ETS under the Windsor Framework.
Is UK ETS reporting the same as SECR?
No. SECR is a disclosure in a company’s annual report with no verification requirement; the UK ETS is a permit-based compliance scheme with verified reports to a regulator and allowances to surrender.
A company can be in both, and its UK ETS installations’ emissions also form part of its SECR Scope 1 figure.
Do aircraft operators still get free UK ETS allowances?
No. DESNZ says free allocation for aircraft operators has been phased out from 2026.
Installations in sectors at risk of carbon leakage continue to receive free allocation, issued on or before 28 February each year.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 19 sources fromlegislation.gov.ukDepartment for Energy Security and Net ZeroUK ETS regulatorsUK ETS AuthorityGOV.UK (Cabinet Office)
- legislation.gov.ukThe Greenhouse Gas Emissions Trading Scheme Order 2020 (SI 2020/1265)
The UK ETS itself: permits, monitoring plans, surrender, the regulators and every civil penalty.
- legislation.gov.ukSI 2020/1265, article 52 — failure to surrender allowances
The excess emissions penalty: £100 multiplied by the inflation factor per allowance.
- legislation.gov.ukSI 2020/1265, article 51 — failure to comply with permit conditions
£20,000 plus £500 a day up to a maximum of £45,000.
- legislation.gov.ukSI 2020/1265, article 50 — operating without a permit
Costs avoided plus emissions multiplied by the carbon price.
- legislation.gov.ukSI 2020/1265, article 64 — aviation: failure to report
The penalty for a missing verified aviation report.
- legislation.gov.ukSI 2020/1265, article 49 — publication of names
Regulators must publish the name of every person given an excess emissions penalty.
- legislation.gov.ukSI 2020/1265, article 54 — hospitals and small emitters exceeding target
The penalty where an HSE’s emissions exceed its target.
- legislation.gov.ukSI 2020/1265, Schedule 7 — hospitals and small emitters
The 24,999 tCO₂e maximum and the 35 MW condition for 2026–2030.
- legislation.gov.ukSI 2020/1265, Schedule 8 — ultra-small emitters
The 2,499 tCO₂e maximum.
- legislation.gov.ukSI 2026/392 — Extension to Maritime Activities Order 2026
Maritime in the UK ETS from 1 July 2026, three gases, new civil penalties.
- Department for Energy Security and Net ZeroParticipating in the UK ETS
Updated 1 July 2026: obligations by participant type, regulators, HSEs, USEs, verifiers, free allocation.
- UK ETS regulatorsUK Emissions Trading Scheme for installations: how to comply
Updated 9 February 2026: the annual cycle, verification, improvement reports and records.
- UK ETS AuthorityUK Emissions Trading Scheme (UK ETS): a policy overview
Updated 7 September 2026: coverage, Phase II, maritime, waste, greenhouse gas removals, consultations.
- UK ETS AuthorityUK ETS scope expansion: waste
26 August 2026: waste incineration will not join in 2028; the MRV-only period is voluntary.
- UK ETS AuthorityUK ETS free allocation review
November 2025 response: 2027–2030 allocation and the CBAM-sector phase-out.
- legislation.gov.ukSI 2026/214 — UK ETS Auctioning (Amendment) Regulations 2026
The £28 auction reserve price from 8 April 2026, index-linked from 1 January 2027.
- legislation.gov.ukSI 2026/278 — UK ETS free allocation amendments
The UK CBAM reduction factors, 0.975 for 2027 falling to 0.775 for 2030.
- legislation.gov.ukAir Navigation (CORSIA) Order 2021 (SI 2021/534)
The separate monitoring and reporting regime for international flights.
- GOV.UK (Cabinet Office)UK–EU Summit: Common Understanding (19 May 2025)
The commitment to work towards linking the UK and EU emissions trading systems.
Continue reading