Emissions Trading System for aircraft operators

Since 2020, flights within Switzerland and flights from Switzerland to the European Economic Area (EEA) and the United Kingdom (UK) have been subject to the Swiss Emissions Trading System (ETS). Aircraft operators must have enough emission allowances to cover their annual carbon emissions.

The Confederation sets the maximum number of emission allowances available in the ETS based on the volume of air traffic in 2018 (measured in tonne-kilometres). This cap was reduced by 2.2% each year from 2021 to 2023 and has been reduced by 4.3% annually since 2024 (linear reduction factor).

Up to 2025, a set number of emission allowances are allocated to aircraft operators free of charge, with the remaining amount being auctioned. The emission allowances are freely tradable and can be surrendered to the competent authority to cover the carbon emitted, or sold to other ETS participants.

Participation in the Swiss ETS

Aircraft operators that carry out domestic flights in Switzerland or flights from Switzerland to the EEA or the UK are obliged to participate in the ETS. Flights from the EEA to Switzerland are covered by the EU ETS, and flights from the UK to Switzerland are covered by the UK ETS. In line with arrangements in the EU, exemptions for special flights (e.g. military, rescue or research flights) and thresholds apply in the Swiss ETS. The thresholds are 10,000t of CO₂ per year and 243 flights in one of three consecutive four-month periods for commercial aircraft operators and 1,000t of CO₂ per year for non-commercial aircraft operators. If the aircraft operator is covered by the EU ETS, these thresholds do not apply.

Allocation of free allowances

For every aircraft operator, the FOEN calculates the annual number of emission allowances to be allocated free of charge based on that operator's transport volume in 2018, taking into account the linear reduction factor and the applicable benchmark.

If an aircraft operator does not carry out any ETS-relevant flights in a particular year and thus is not required to surrender any emission allowances, it must return the emission allowances that were allocated to it free of charge for the year in question. From 2026 all emission allowances will be auctioned i.e. no free allowances will be allocated.

Additional free allowances for flights to outermost regions

Since 2024, flights from Switzerland to the outermost regions of the EU, i.e. Guadeloupe, French Guiana, Martinique, Mayotte, Réunion, Saint-Martin, Madeira, the Azores and the Canary Islands have also been subject to the Swiss ETS. Aircraft operators were able to apply for free emission allowances for these flights for the years 2024 to 2026 in accordance with Article 46g of the CO₂ Ordinance.

Auctions

The FOEN regularly auctions off emission allowances via the Swiss Emissions Trading Registry (ETR). Those entitled to take part in these auctions include participants in the Swiss and EU ETSs and other companies from the EEA admitted to auctions in the EU. Anyone wishing to take part in a Swiss ETR auction must have an account with the Swiss ETR. Detailed information about the auctions can be found in the factsheet and the General Terms and Conditions for Auctions below:

Fact sheet: Auction of emission allowances (PDF, 1 MB, 15.01.2024)

General Terms and Conditions of the Auctions (PDF, 69 kB, 15.01.2024)

Dates, auction quantities, maximum and minimum bid quantities for the next auction and the results of previous auctions are published in the Emissions Trading Registry:

Swiss Emissions Trading Registry

Reporting and obligation to surrender emission allowances

By 31 March each year, aircraft operators must report on their carbon emissions for the previous year to the competent authority in the administering state (see ‘One-stop shop’ section below). They then have until 30 September to surrender sufficient emission allowances to cover these emissions. This is done in the emissions trading registry of the competent authority. Aircraft operators administered by Switzerland surrender their allowances/certificates in the Swiss ETR, while operators administered by a foreign authority do so in the Union Registry. From 2025 aircraft operators must also provide information on the climate impact of other emissions.

One-stop shop

Aircraft operators who have obligations under both the Swiss and EU ETSs are only administered by one state – the ‘one-stop shop’ principle. The competent authority in that state is responsible for all tasks related to the administration of the operator under both ETSs. This includes taking receipt of the annual emission reports and checking that the operator has met all its commitments and obligations.

Aircraft operators administered by Switzerland

The list of aircraft operators currently administered by Switzerland can be found here:

Aircraft Operators Attribution List (Commission Regulation (EU)) (PDF, 945 kB, 25.04.2024)

Swiss cap for aviation

The total number of emission allowances for aircraft is reduced each year by the linear reduction factor of 4.3% (2.2% up to 2023). The UK having left the EEA, flights to the UK were not subject to the Swiss ETS in 2021 and 2022. The aviation cap for these years was adjusted accordingly. As of 2024, the aviation cap also includes additional emission allowances for flights to the outermost regions of the EU.

Number of Swiss emission allowances in the ETS for aircraft operators

Table A: Total number of emission allowances for aircraft ('aviation cap') and the numbers available for allocation free of charge, for auctions and for the special reserve.
	Aviation cap (total number)	For allocation free of charge	For auctions	For the special reserve
2020	1 310 035	1 074 229	196 505	0
2021	1 072 636	879 562	160 895	32 179
2022	1 048 507	859 776	157 276	31 455
2023	1 223 572	1 003 329	183 536	36 707
2024	1 167 988	734 492	433 496	0