ETS2 Guidance

The ETS2 will be launched in 2025 and the scheme is being introduced in phases. Key milestones occur in 2025, 2026, 2027 and 2028.

Full implementation of the scheme is scheduled for 2027, marking the start of allowance auctions and surrendering obligations.

ETS2 differs from the initial ETS scheme because it is an upstream approach through regulating fuel suppliers rather than end users.

The following fuels are regulated under ETS2:

• (un)leaded petrol
• Gas Oil
• Kerosene
• LPG
• Natural Gas
• Heavy Fuel Oil
• Coal and Coke
• Any other product intended for use, offered for sale or used as motor fuel or heating fuel as specified in Article 2(3) of the Energy Taxation Directive (ETD). This includes any fuel additives used as motor fuel, certain bio-based fuels, and any other hydrocarbons for heating purposes, except for peat.

ETS2 focuses on regulating fuel suppliers rather than end users of the fuels regulated under the Directive. This includes:

• Fuel suppliers and distributors who supply fossil fuels regulated under the Directive to sectors covered by ETS2
• Fuel importers who import fuels into the regulated jurisdictions for consumption in sectors regulated by ETS2
• Potentially operators of small-scale combustion installations where they supply themselves with fuel

Every annual cycle of the ETS2 scheme will follow a timeline, where verified emissions reports are due by April 30^th and applicable, allowance surrender obligations are met by May 31^st. 

• 2025 – By 30^th April, REs must submit their first (unverified) emissions report to the Competent Authority. This also marks the beginning of the verified emissions monitoring period.
• 2026 – By 30^th April, the first verified emissions report is due.  Additionally, the Social Climate Fund will become operational.
• 2027 – Full compliance obligations under ETS2 commence.
• 2028 – The requirement to surrender allowances for verified emissions begins.