Deadlines for Non-CO₂ Reporting: What Airlines Must Do Now

The regulatory landscape for aviation emissions is evolving. Airlines are no longer required to monitor just CO₂ emissions—non-CO₂ climate effects such as contrails, NOx, and water vapour are now a formal part of emissions accountability.

A new MRV (Monitoring, Reporting, and Verification) system mandates that aircraft operators track and report these effects in a structured and verifiable way. To ensure compliance and avoid penalties, airlines must act proactively.

What Must Airlines Monitor?

Aircraft operators are now expected to calculate CO₂-equivalent (CO₂e) emissions that include:

  • Nitrogen Oxides (NOx)
  • Water Vapour
  • Contrails and Induced Cirrus
  • Non-Volatile Particulate Matter (nvPM)

These are translated into CO₂e using Global Warming Potential (GWP) values across multiple time horizons (e.g., GWP20, GWP100), adjusted for efficacy to better reflect true temperature impact.

Immediate Actions Airlines Should Take

To stay ahead of enforcement and verification requirements, operators must take these key steps:

1. Submit a Compliant Monitoring Plan

Every operator must submit or update their Monitoring Plan to include:

  • Methodology for non-CO₂ effects (Method C or D)
  • The IT tool being used (e.g., NEATS or an approved third-party platform)
  • Emission sources, routes, and fuel types

2. Choose the Right Monitoring Method

  • Method C (Weather-Based): For larger emitters, using actual weather, fuel, and trajectory data.
  • Method D (Climatological): For small emitters with lower emissions; uses averaged data and simpler assumptions.

3. Ensure IT Tool Compatibility

Operators must either:

  • Use the EU’s NEATS platform, or
  • Seek formal approval for third-party or internal MRV tools

Tool outputs must align with XML reporting formats and regulatory model outputs (e.g., CoCiP, aCCF, OpenAirClim).

4. Prepare for Verification

Engage a verifier accredited under the appropriate scope and assemble a comprehensive evidence pack including:

  • Flight data and engine identifiers
  • Fuel records and chemical properties
  • Tool specs and default values used
  • Documentation of GWP and efficacy application

Pitfalls to Avoid

  • Late or incomplete Monitoring Plan submission
  • Using tools that haven’t been approved
  • Relying solely on default values despite having primary data
  • Omitting efficacy in CO₂e conversions
  • Underestimating verification requirements

How Vurdhaan Helps Airlines Comply

Vurdhaan is a strategic partner to aircraft operators navigating non-CO₂ MRV obligations. We support you through every step of the compliance process with tailored, technically sound solutions.

Our services include:

  • Drafting and optimizing Monitoring Plans
  • Tool validation and NEATS integration
  • Route- and fleet-specific emissions modeling
  • Data infrastructure design and default value mitigation
  • Evidence pack compilation and pre-verification review

Whether you’re a major carrier or a small operator, Vurdhaan ensures your non-CO₂ reporting is credible, accurate, and regulator approved.

Need help meeting your non-CO₂ compliance deadlines? Contact Vurdhaan to avoid surprises and ensure your systems are audit ready.