EU Emissions Trading System (EU ETS)

EU Emissions Trading System (EU ETS)

What is EU Emissions Trading System (EU ETS)?

The European Union Emissions Trading System (EU ETS) is the cornerstone of EU climate policy and the world’s largest carbon market. It operates on a cap and trade principle: a maximum cap is set on total GHG emissions from covered installations, and companies must monitor, report, and surrender allowances corresponding to their verified emissions.
ETS compliance is mandatory for a wide range of industries, including:

  • Power & heat generation
  • Manufacturing of cement, steel, glass, chemicals, paper
  • Aviation operators
  • Large industrial combustion units

The system incentivizes decarbonization while ensuring robust, transparent emissions reporting across the European market.

Scope and applicability

SCS provides support for EU ETS compliance obligations for operators required to submit verified emissions information to a national Competent Authority. Service availability depends on the applicable scheme, location, and accreditation scope.  SCS Europe is in process of achieving accreditation for the activity group 4 (production of (non) ferrous metals) and activity group 8 chemicals.

Why Choose SCS?

SCS Global Services has provided third-party Greenhouse Gas verification for over 15 years in various industry sectors, including: Food and Agriculture, Apparel, Manufacturing, Technology, Airlines, Retail, Building Materials, Municipalities, Utilities and many more. Since 2026, SCS Global Services Europe has added a new program to our portfolio: the EU Emissions Trading System (ETS).

SCS verifiers employ the most current accounting principles and GHG calculation methodologies for the activity groups 4 and 8. We ensure thar your emissions data is accurate, compliant and ready for submission to the competent authorities of your country.

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  • Main Obligations for ETS Installation Operators
  • The ETS Verification Process
  • SCS ETS Services
  • FAQs

Operators participating in the EU ETS must fulfil several core obligations each year:

  1. Monitor Greenhouse Gas Emissions

    Installations must follow an approved Monitoring Plan describing measurement methodologies, data sources, calculation factors, and QA/QC procedures.

  2. Prepare and Submit an Annual Emission Report

    Each installation submits a verified Annual Emissions Report (AER) to its national Competent Authority.
    This report must:

    • Cover all relevant direct emissions
    • Follow the approved methodology
    • Ensure completeness, accuracy, and transparency
    • Include activity data, emission factors, and calculation details
  3. Have the Report Independently Verified

    Before submission, the AER must be verified by an accredited, independent third party verifier.

  4. Surrender Emission Allowances

    By the annual deadline, operators must surrender EU Allowances (EUAs), equal to their verified emissions. EUAs can be bought and sold on the market, and the variable market price of EUAs reflects the cost of reducing emissions.

Step by Step Overview of the Verification Cycle

SCS verification activities are conducted in line with EU ETS monitoring, reporting and verification requirements (MRV), using a risk-based approach to assess data, controls, and materiality. 

  1. Strategic Analysis

    The verifier performs a high level assessment of your installation, processes, monitoring methodology, and inherent risks.

  2. Risk Assessment

    A detailed risk analysis is conducted to identify:

    • Significant emission sources
    • Data gaps
    • Calculation risks
    • Control system weaknesses
  3. Verification Planning

    Based on identified risks, the verifier develops a tailored verification plan covering:

    • Site visits
    • Data checks
    • Transaction sampling
    • Methodology reviews
  4. Process Analysis & Data Verification

    The verifier reviews:

    • Activity data (fuel, materials, outputs)
    • Emission factors
    • Calibration records
    • Internal controls & QA/QC
    • Completeness and consistency of datasets
  5. Site Visit (where required)

    On site assessment to validate:

    • Measurement systems
    • Operational boundaries
    • Metering and sampling procedures
    • Data capture processes
  6. Issue Resolution

    The verifier communicates non conformities and improvement needs, allowing the operator to correct or clarify issues prior to finalization.

  7. Verification Report Opinion

    Once all issues are addressed:

    • A formal Verification Report is issued
    • A Verified Emission Figure is provided

The operator can then safely submit the AER to the authorities.

Supporting Installations from Preparation to Annual Verification

  1. SCS provides a full suite of services to ensure operators meet their ETS obligations efficiently and confidently.
    ETS Preparation Session

    We offer preparation sessions to explain:

    • ETS fundamentals
    • Monitoring & reporting rules
    • Calculation methodologies
    • Data validation and internal controls
    • Common verification findings and how to avoid them
      Preparation sessions can be delivered onsite or online, oriented towards operators, compliance teams, or sustainability managers.
  2. Pre-Verification check

    Before the formal verification begins, SCS can perform a pre verification check, including:

    • An online self-assessment
    • Review of the Monitoring Plan
    • Evaluation of data availability & completeness
    • Testing sample calculations
    • Identifying early issues to avoid non conformities
    • Providing recommendations to improve accuracy and reliability
      Pre-verification helps ensure a smooth, low risk  formal verification later in the year.
  • What is the EU Emissions Trading System (EU ETS)?

    The EU Emissions Trading System (ETS) is the European Union’s primary instrument for reducing greenhouse gas emissions. It operates under a “cap‑and‑trade” framework, where a maximum limit is placed on total emissions from covered activities, and operators must hold and surrender emission allowances equal to their verified emissions each year.

  • Who is required to comply with the EU ETS?

    EU ETS applies to operators of covered installations in energy‑intensive sectors (such as producers of oil, steel, cement, iron and aluminum, glass, and pulp and paper, among others) as well as certain aviation activities. Covered installations must monitor emissions, submit an Annual Emissions Report (AER), have it independently verified, and surrender sufficient allowances by regulatory deadlines.

  • Why is monitoring, reporting, and verification (MRV) so important under EU ETS?

    Robust MRV ensures that emissions data is accurate, transparent, and comparable across the system. Independent verification is a mandatory requirement and plays a critical role in maintaining the integrity and effectiveness of the EU ETS, while enabling operators to demonstrate compliance with regulatory obligations.

  • What role does SCS Europe play in EU ETS compliance?

    SCS Global Services Europe B.V. provides independent assurance services across GHG emissions programs. It is expanding its capabilities to deliver accredited verification and independent pre-verification assessments aligned with EU ETS requirements and broader EU regulatory frameworks. These services are non-advisory and do not include system design, data development, or implementation support.

  • What is the status of SCS Europe’s EU ETS verifier accreditation?

    SCS Europe submitted its accreditation application to become an EU ETS verifier in early 2026 for:

    • Activity Group 4 – Production of (non)‑ferrous metals
    • Activity Group 8 – Chemical industry activities

    This initiative reflects SCS’ long-term commitment to serving regulated operators with reliable, independent, and technically rigorous verification services.

  • Can SCS Europe support operators before accreditation is granted?

    Yes. SCS Europe offers EU ETS readiness and pre-verification services that provide independent assessment of an operator’s systems and data in advance of formal verification. SCS Europe brings experience across EU regulatory programs, including ETS, CBAM, EUDR, and RED III, allowing for a consistent approach to GHG-related assurance from pre-verification through final verification.

  • What is the EU ETS Readiness Tool?

    The EU ETS Readiness Tool is a free, online self-assessment developed by SCS Europe. It allows operators to evaluate their readiness for EU ETS verification by identifying potential gaps or areas of misalignment in monitoring, reporting, and control processes.

  • What is pre-verification and what does it help identify?

    Pre-verification is a voluntary, non-accredited service conducted with the same technical rigor as formal verification, without issuing a verification opinion. It provides a detailed review of an operator’s emissions monitoring and reporting systems and identifies potential material misstatements, weaknesses in monitoring plans or data flows, and risks related to compliance with the EU ETS Monitoring and Reporting Regulation (MRR).

    Early identification of these issues provides greater visibility into verification readiness and potential compliance risks.

  • What is included in an EU ETS informational session?

    As part of pre-verification engagements, SCS Europe offers informational sessions for installation operators and responsible staff. Sessions provide an overview of:

    • EU ETS principles and requirements
    • Legal obligations and timelines
    • Monitoring, reporting, and verification processes
    • Common findings observed during ETS verifications

    The goal is to ensure teams are informed on requirements, timelines, and verification expectations.

  • How are EU ETS services priced?

    Pricing for EU ETS services is determined on a case-by-case basis, depending on factors such as the activity group, size and complexity of the installation, data quality, and the scope of services required (e.g., readiness assessment or pre-verification). This approach ensures services are appropriately scoped and aligned with regulatory requirements.

  • How should operators get started?

    Operators can begin by using the free EU ETS Readiness Tool to assess their current state of readiness. For those seeking further evaluation, SCS Europe offers independent pre-verification services that provide detailed insight into verification readiness.

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Tarik Bellahcene (Belgium)

Business Development Director