Our third in a series of updates about ETS2 looks the planned ETS2 Roll Out. It examines the key compliance dates that Regulated Entities (REs) under the ETS2 scheme must adhere to. Understanding these timelines is essential for ensuring compliance and avoiding potential enforcement action.
As mentioned in our previous update Who will ETS2 Impact? What Stakeholders Need to Know, in 2024 and early 2025 the following should have already been completed by REs of the scheme:
1 – A monitoring plan (MP) should have been submitted to the Competent Authority.
2 – An ETS2 permit should have been applied for with the Competent Authority.
3 – An unverified emissions report should have been prepared for the 2024 reporting period and submitted to the Competent Authority via the ETS Reporting Tool by 30 April 2025.
The infographic below summarises the key compliance dates for the ETS2 Roll Out that REs should be aware of from 2025 – 2028, following completion of the actions outlined above:
These milestones are explained in more detail below. We look at the key dates from the 2025 – 2030 period for the ETS2 Roll Out.
2025 – Reporting Begins
This is the first monitoring period where all REs should already hold a MP and ETS2 permit. The period ends on 31 December 2025.
2026 – Verified Reporting Begins
By 30 April 2026, the first verified emissions report for the 2025 reporting period should have been submitted. During 2026, the Social Climate Fund (SCF) will also be launched, and REs should open Union Registry accounts which will be necessary to purchase and hold allowances within the future. Additionally, the Commission is expected to announce on 15 July 2026 whether the scheme will be fully implemented.
2027 – Full Launch and Allowance Auctions
By 1 January 2027, unless the Commission postpones this, ETS2 will become fully operational and allowance auctioning will commence. The Commission should also publish the ‘cap’ allocated to the 2028 period.
2028 – Surrendering of Allowances Begins
The surrendering of allowances shall begin in relation to the verified 2028 emissions report. The deadline for this will be 31 May 2028. The start of the Market Stability Reserve (MSR) shall also commence, which will adjust the supply of allowances where necessary to maintain market stability. Alongside the Commission publishing their first progress report based on the rollout of the scheme.
2029 and 2030 – Continued Monitoring Reporting and Verification (MRV) & Allowance Surrendering
If you require any further information about the ETS2 Roll Out and the milestones detailed within this article, or help ensuring you’re compliant with the scheme, please contact info@swanenergy.co.uk or call us on 01484 843 867.
For the final instalment in this ETS2 series, look out for our upcoming article titled ‘Ireland Seeks Exemption from ETS2 Surrender Obligations for Fuels under the Carbon Tax Regime’.
