A mandatory UK ETS Baselining data collection exercise will take place April – June 2025.
On the 11th November 2024, the UK ETS Regulators issued alerts drawing attention to the mandatory UK ETS baselining data collection exercise that will take place 1st April 2025 – 30 June 2025.
All installation operators will be required to submit historic installation data to their regulators, and, if appropriate, applications for the Hospital/Small Emitter Scheme (HSE) or Ultra Small Emitter (USE) schemes. Where an installation is seeking Free Allocation (FA) for 2027-2030 period (recently shifted from 2026-2030), a verified Baseline Data Report (BDR) and an approved Monitoring Methodology Plan (MMP) will be required to be submitted on or before 30 June 2025.
The recent move of the next allocation period from 2026 to 2027 does not affect the HSE/USE periods, therefore:
- Where an Operator wishes to retain or apply for USE status for 2026-2030, a verified Ultra Small Emitter Data Collection template is required to be submitted on or before 30 June 2025.
- Operators that wish to apply for the HSE Opt-Out scheme for 2026-2030 are required to submit installation data and evidence to demonstrate the installation meets the HSE qualification criteria but in most cases, will not need to undergo verification.
The Department for Energy Security & Net Zero (DESNZ) has stated that the updated FA rules will be published by the end of 2025, for implementation in reporting year 2027. As such, it has not yet been published how the BDRs submitted will translate into FA for a particular installation.
Therefore, it is theoretically possible, but in Swan Energy’s opinion unlikely, that particular HSE eligible installations may find it beneficial to apply for HSE status for the 2026 reporting period and then opt back in with FA for 2027 reporting year onwards. However, in order to have this option, a full verified BDR, as well as an approved MMP, will need to be submitted on or before 30th June 2025.
The Regulator’s Alert included a table outlining the requirements for each type of operator:
| Type of operator | Definition | What data is this operator required to submit? | What is the approach to verification? |
| 1. FA applicants
|
Operators applying for FA in the main UK ETS in the next allocation period (could be existing GHGEs, HSEs or USEs) |
|
Full verification* |
| 2. Non-FA, non-USE and non-HSE data submissions
|
All operators** who are not applying for FA for the second allocation period, nor HSE status or USE status for the 2026-2030 period.
Includes operators who meet the “electricity generator” classification and are therefore not FA-eligible unless they produce heat from high efficiency co-generation or district heating. |
|
No verification needed |
| 3. HSE applicants
|
Operators applying for HSE status for the 2026-2030 period. |
|
If applying under condition B or C, verification or self-declaration is required.
If applying under condition A, verification or self-declaration may be required. Please see Schedule 7 to the Order linked at the end of this communication. |
| 4. USE applicants
|
Operators applying for USE status for 2026-2030.
As explained above, we expect the template for existing USEs to be available slightly earlier than the other templates, to allow existing USEs to begin verifying their emissions in 2024. |
|
Verification or self-declaration.
Please note that if you are an existing USE reapplying for USE status, and you have not had your emissions data verified or self-declared before, you will need to get it verified before applying for USE status. |
| * If an operator does not complete these sections, its application for FA in the second allocation period will not be complete. If a monitoring methodology plan has not already been approved by the regulator, all operators applying for FA including USEs and HSEs must submit this alongside the BDR template.
Extract from Baseline data collection taking place during the period 1 April – 30 June 2025 for all UK ETS Installations, Hospital and Small Emitters and Ultra-Small Emitters, UK ETS Regulator Communications, November 2024 |
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Click here to get in touch with the Swan Energy team if you have any questions and to find out more about how we are able to support the UK ETS Baselining process.
