Having recently finished our second year supporting EU ETS2 reporting in Ireland, and working closely with Regulated Entities (REs) throughout the process, we wanted to provide an overview of how the year went, what we found during the reporting cycle, and what we are looking forward to as the system continues to develop.
This first verified EU ETS2 reporting cycle marked a significant step in the launch of the scheme. REs were required to ensure emissions data was not only compiled and traceable back through ETS1 customer inputs, but also formally verified before submission. While the core requirements were broadly understood, there are still areas where further clarification is expected from the EU Commission, particularly around interpretation and consistency of certain Annex Xa and ETS1-linked data points.
However, a key improvement this year was the integration of Annex Xa data directly into the ETS reporting tool. This helped streamline workflows, improve consistency, and reduce manual handling. For REs it also significantly eased the four-week pressure window previously associated with obtaining verified ETS1 customer data.
We also saw strong performance from the Irish EPA, with consistently good response times and efficient handling of queries, which helped keep the reporting cycle on track. In parallel, we worked successfully with a Greek verification body, whose adaptable approach and clear communication supported a smooth verification process.
That said, this was not without challenges. The Annex Xa functionality for ETS1 Operators was not fully stable throughout the cycle, which led to some inconsistencies and required manual workarounds. These teething issues underline that full ETS1–ETS2 alignment is still evolving and will likely require further technical and regulatory refinement.
Overall, the first year of verified ETS2 reporting in Ireland worked well. The process was more structured and less time-pressured than anticipated, largely due to improved data integration and stronger regulatory engagement. However, it is clear there are still open questions where further clarification from the EU Commission will be important, particularly where interpretations of Annex Xa data and ETS1 dependencies differ between systems or Member States.
Looking ahead, it will be interesting to see how the Commission address these early-stage issues. Improvement Reports will also provide REs with an opportunity to address findings raised by both verification bodies and regulators, helping to further strengthen the process in future cycles.
Click here to visit our website page to find out more about ETS2 and how the Swan Energy team can help, and if you have any questions regarding the ETS2 Reporting, please get in touch.
