Once the regulator has approved the Voluntary Monitoring Plan (VMP) for waste incineration and energy-from-waste (EfW) installations, operators must begin to prepare their annual emissions report. Operators are also requested to submit quarterly waste tonnage and emissions data to aid in policy development. In this update, we explain UK ETS reporting and what is required both quarterly and annually, how to manage the data, and how to prepare for future verification.
Annual Tasks and Deadlines
In terms of UK ETS Reporting, during the voluntary MRV-only period, EfW operators are expected to report their emissions in similar fashion to qualifying UK ETS participants.
- 1 January 2026 – begin monitoring emissions according to VMPUK ETS Reporting.
- July 2026 – appoint an accredited verifier (optional – operators may choose to self-declare).
- By 31 December 2026 – notify the regulator of any non-significant changes to the monitoring plan via METS.
- 31 December 2026 – complete emissions monitoring for 2026 calendar year.
- 31 March 2027 – submit annual emissions report alongside verification report or self-declaration for 2026 calendar year via METS.
This process will continue in the same pattern for 2027.
While verification is voluntary for the MRV-only period, going through the verification process without the pressure of compliance may be a useful exercise for many operators.
Quarterly UK ETS Reporting
During the voluntary MRV-only period, operators are requested to submit a Quarterly Emissions Report (QER) every three months. Each report should include:
- Total CO₂ emissions for the 3 month period
- Breakdown of fossil vs. biogenic emissions
- Activity data (e.g. waste throughput, fuel consumption)
- Monitoring methods and tier levels used
- Any missing data and how it was handled
At present it is not clear if the quarterly reports should be submitted to the regulator via METS.
Data Flow and Control Systems
Accurate reporting depends on robust data management. Your VMP should describe your data flow system, which includes:
- How data is collected, stored, and processed
- Who is responsible for each step
- What controls are in place to ensure accuracy
Operators will need to identify and assess risks, such as manual data entry errors or equipment failures, and implement control activities to mitigate them, for example:
- Automated data logging
- Regular calibration of instruments
- Cross-checks between departments
- Internal audits or peer reviews
Managing Missing or Incomplete Data
Sometimes data will be missing or unreliable. In these cases, operators must:
- Apply a conservative estimate based on historical data or literature
- Document the issue and your approach in the QER
- Flag it to your regulator for transparency
Your written procedures should include a clear approach for handling missing data.
Preparing for Verification
Although formal verification isn’t required during the MRV-only period, operators should still aim for audit-ready records. This means:
- Keeping detailed logs of sampling and analysis
- Maintaining version control on reports and procedures
- Ensuring traceability from raw data to final emissions figures
This will make future ETS compliance and third-party verification much smoother.
Our next update, the last in this series, will point operators to additional resources, regulator contacts, and discuss what to expect after the MRV-only period ends. Make sure to follow us on LinkedIn to get notified when the next blog in the EfW series is released.
Our team of Carbon Consultants are experts in emissions reporting. If you would like us to support you through the voluntary MRV-only period, please contact us here.
