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 surrender emission allowances in the amount of their CO2 emissions.

Each year, the Confederation sets the maximum amount of emission allowances available in the ETS (‘cap’) based on air traffic transport performance 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).

By 2025, a certain amount of emission allowances will be 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 CO₂ emissions caused, 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. 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 10,000 t of CO2 per year and 243 flights in one of three consecutive four-month periods for commercial aircraft operators and 1,000 t of CO2 per year for non-commercial aircraft operators. If the aircraft operator is covered by the EU ETS, these thresholds do not apply.

Free-of-charge allocation

For every aircraft operator, the FOEN calculates the annual quantity of emission allowances to be allocated free of charge based on that operator's transport performance 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.

Additional free allocation for flights to outermost regions

As of 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, are no longer exempt from the Swiss ETS. Aircraft operators were able to apply for free emission allowances for these flights in accordance with Article 46g of the CO₂ Ordinance.

Auctions

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

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

Fact sheet: Auction of emission allowances (PDF, 1 MB, 15.01.2024)valid from 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 CO₂ emissions for the previous year to the competent authority in the administering state (see ‘One-stop shop’). They then have until 30 September to surrender sufficient emission allowances to cover these CO₂ 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 EHR, while operators administered by a foreign authority do so in the Union Registry.

One-stop shop

In line with the 'one-stop shop' philosophy, aircraft operators who have obligations under both the Swiss and EU ETSs are only administered by one state. 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, reviewing whether the operator has met all its commitments and enforcing the operator’s 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 quantity of emission allowances for aircraft is reduced each year by the linear reduction factor of 4.3% (2.2% until 2023). Due to the UK’s departure from 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.

Quantity of Swiss emission allowances in the ETS for aircraft operators

Table A: Total quantity of emission allowances for aircraft ('aviation cap') as well as the quantities available for allocation free of charge, for auctions and for the special reserve.

	Aviation cap (total quantity)	for allocation free of charge (partial quantity)	for auctions (partial quantity)	for the special reserve (partial quantity)
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

Table B: CO2 emissions, aircraft operators subject to the ETS, actual emission allowances allocated free of charge in the Swiss ETS (as of: 31.10.2024).