UK aviation regulator outlines environmental disclosure framework for airlines

The Civil Aviation Authority (CAA) has published a new framework setting out guidance and principles on the provision of standardised consumer environmental information in the aviation sector. The framework applies to airlines and other organisations selling or advertising applicable flights – those departing from or arriving at UK airports. It also extends to package holidays that include such flights.

Airlines and other affected organisations are expected to publish information on the estimated environmental impact of individual flight choices, drawing on the CAA's updated Consumer Environmental Information Principles and accompanying methodologies.

The framework organises these requirements around principles covering accessibility, transparency, accuracy, specificity, timeliness, consistency, standardisation, comparability, comprehensiveness and continuous improvement. Each principle is supplemented by further guidance to aid compliance.

Accessible

Environmental information should be easily accessible to all consumers wherever applicable flights are advertised or sold in the UK. It should be easy to find within the flight search and booking process before purchase and, wherever possible, should meet the web content accessibility guidelines.

Transparent

Publishers of environmental data should publish, or link to, the methodology with which it is calculated.

Accountable and accurate

Publishers are accountable for the accuracy of the calculations and for using the most accurate, up-to-date and credible sources of input data.

Specific

Environmental information should be calculated using data as specific as possible to the passenger's choice of flight; for example, aircraft type, route, seat choice, average load factor and cargo weight proportion. Where specific input data is unavailable, the most credible alternative data should be used.

Timely

Environmental information should be updated at least annually to reflect operational changes.

Consistent

The same environmental information should be available wherever flights are advertised or sold, with consistency across all channels. Where third parties publish environmental information related to a flight, airlines should seek to ensure it is, at a minimum, aligned with their own.

Standardised

Publishers should meet minimum standards for measuring and reporting environmental data to ensure consistency and comparability across different airlines and flight options.

Comparable

Environmental information should be shown using standard metrics – kg CO₂ or kg CO₂e per passenger journey.

Comprehensive

Publishers should, wherever possible, incorporate data on the use of sustainable aviation fuel.

Continuous improvement

Publishers should consider how environmental information could drive improvements in aviation sustainability and build in mechanisms to measure consumer impact and incorporate those findings into business improvement decisions. Information should also reflect the full climate impact of aviation and new technologies as data becomes available.

Next steps

The CAA expects airlines and other relevant organisations to take adequate steps towards implementing the framework by 30 April 2027 and intends to review airline websites and booking platforms during 2027 to monitor uptake.

If organisations do not take credible steps to display environmental information using the methodologies outlined in the framework or provide reasons for adopting a credible alternative, the CAA intends to consider additional actions, including adopting a mandatory approach to the presentation of such environmental information. This could involve the authority exercising its information-gathering powers to collect the relevant data, carry out the calculations and publish the information itself, with the costs of doing so likely to be recovered from industry.

Osborne Clarke comment

Airlines and other organisations selling or advertising flights departing from or arriving at UK airports will want to be looking to begin assessing their current environmental information disclosures against the framework's principles and methodologies.

The CAA has signalled that it intends to move to a mandatory approach if adequate steps towards implementation are not taken. Organisations should therefore treat the framework as a practical benchmark of best practice for compliance readiness, and consider what operational and technical changes may be required to publish standardised emissions data at the point of booking before 30 April 2027.