Custom ETS2 monitoring of fuel deliveries
Under EU ETS-2, fuel suppliers are responsible for the CO2 emissions of the fuels they supply to the built environment, road transport and a number of other sectors. Since 2025, they have been monitoring those emissions under a monitoring plan approved by the NEa (the Dutch Emissions Authority), and every year a verified emissions report must be submitted to the NEa by 30 April at the latest. This requires it to be clear, for each delivery, which fuel it was and where it ended up. Appfront builds the software that classifies your deliveries, tracks the exceptions and compiles the emissions report.
What is software for ETS2 monitoring of your fuel deliveries?
Software for ETS2 monitoring records which fuels you supply, to whom and for what end use, and calculates the emissions you have to report. Directive (EU) 2023/959 added a separate chapter to the European Emissions Trading System for buildings, road transport and additional sectors. This covers the regulated entity: according to the NEa (the Dutch Emissions Authority), the supplier that is liable for excise duty on mineral oils or for coal tax or energy tax on natural gas. Since 1 January 2025 it has needed a permit, and the directive requires emissions to be monitored every year from 2025 and reported from 2026.
The difficult part is allocation. A diesel delivery to a haulage company falls under ETS-2, while a delivery to an installation that is already covered by EU ETS Stationary does not, but you still have to record it. Deliveries to aviation, shipping and fisheries are monitored without a surrender obligation. Biofuels that comply with the Renewable Energy Directive count with an emission factor of zero. Your ERP often holds only a customer and an item, and it is the account manager who knows which sector that belongs to. In the report, an accredited verifier has to be able to follow those choices.
We build custom software because every supplier has a different chain. An oil company supplies filling stations and wholesalers via excise warehouses, a trader supplies heating oil and diesel to consumers and businesses, an energy supplier delivers natural gas to buildings. What the software does depends on which fuel flows you have, how your monitoring plan determines the emissions, where the deliveries and excise data are held and how you record end use. The monitoring plan itself remains yours and the NEa's; the software carries it out.
Per delivery
Fuel and end use.
Exemptions
Stationary, aviation, shipping, fisheries.
Report
Ready for verification.
How we build software for ETS2 monitoring of your fuel deliveries
We start with your deliveries and your monitoring plan: which fuel flows you have, in which systems the deliveries and excise data are held, how you currently determine which sector a customer falls into and how the previous emissions report was put together. We then build a first version that classifies the deliveries by fuel flow and by sector, because the report is based on that. Your controller compares the result with the latest report. The biofuels, the deliveries to EU ETS Stationary, the file for the verifier and the alerts for changes to the monitoring plan follow once that works well. After that, we keep the software up to date as the rules change.
Fuel, customer, system.
The first version.
Supporting evidence retained.
Go-live, monitoring, and maintenance when things change.
What software for ETS2 monitoring of your fuel deliveries actually does
The components below feature in almost every ETS2 monitoring set-up. Which ones you need depends on your fuels, your customers and your systems.
Fuel flows
Per fuel and quantity.
End use
Sector per customer or delivery.
Exemptions
Stationary, aviation, shipping, fisheries.
Biofuels
With their emission factor.
Emissions report
In line with the monitoring plan.
Verification
Supporting evidence per choice.
Who we build software for ETS2 monitoring of your fuel deliveries for
The software is intended for fuel suppliers that fall under EU ETS-2 and whose emissions report is currently compiled from spreadsheets. The more fuels, customer types and exceptions you have, the more it delivers.
Oil companies
Excise warehouses.
Fuel traders
Diesel, heating oil, LPG.
Filling station chains
Road transport and end use.
Energy suppliers
Natural gas to buildings.
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This page covers monitoring and emissions reporting under EU ETS-2. For the delivery note itself, see our page on bunker note software for fuel delivery; for planning your tanker trucks, our tanker truck planning app page; for your own company's emissions, our page on CO2 accounting; and for the sector as a whole, our page on oil and gas software. You can read about our approach at building software.
Why Appfront for your ETS2 monitoring software for fuel deliveries?
A delivery to an installation under EU ETS Stationary that was counted anyway, a sector that gets filled in differently per customer, or a verifier who can't follow a choice: any of these costs a fuel supplier emission allowances and prompts questions from the NEa (the Dutch Emissions Authority). That is what we build around: every delivery with its fuel and end use, every exception visible, and a report that can be traced back to the individual delivery line.
Correct allocation
Sector per delivery.
Traceable
Down to the delivery line.
In time
Report prepared.
Security and privacy in ETS2 monitoring software for your fuel deliveries
The software processes delivery, customer and excise data, all of which is commercially sensitive. Access is set up per role: sales adds the end use per customer, the controller sees the emissions, and only the responsible person sees the report before it is submitted. Every change to an allocation is recorded with name, time and reason.
The software runs in a European data centre, with encrypted connections and storage and daily backups. Submission to the NEa takes place in Emissions Trading Portal 2 using eHerkenning; the software prepares the data and stores every submitted report together with its supporting evidence, so you can show what you reported and when.
Frequently asked questions about ETS2 monitoring software for your fuel deliveries
Questions that controllers, compliance staff and directors at fuel suppliers ask before they get started.
It records for each delivery which fuel you supplied, to whom and for what end use, classifies deliveries by sector, keeps exceptions separate and calculates emissions according to your monitoring plan. From that it produces the emissions report for the NEa, with the supporting evidence for the verifier.
According to the NEa, the fuel supplier that is a regulated entity and supplies fuels covered by ETS-2 to at least one sector that falls under it. A regulated entity is the supplier that is liable for excise duty on mineral oils, or that pays coal tax or energy tax on natural gas.
Every year by 30 April at the latest, covering the previous year, and verified by an accredited verifier. The first report covered 2025. According to the NEa's timeline, the first obligation to surrender emission allowances applies to 2028, with surrender on 31 May 2029.
Deliveries to installations under EU ETS Stationary fall outside ETS-2, but you still have to record them. Deliveries to aviation, shipping and fisheries are monitored without you surrendering emission allowances for them. The software keeps those flows separate.
Biofuels that meet the criteria of the Renewable Energy Directive can be reported with an emission factor of zero. The software keeps track of the share and the supporting evidence for each fuel flow, so the verifier can see what that factor rests on.
The NEa classes fuel suppliers with annual emissions of 100 tonnes of CO2 or less as mini-emitters. They may submit a simplified monitoring plan and do not need to have the report verified. The surrender obligation still applies.
For suppliers with multiple fuels, many customers in different sectors or deliveries to EU ETS Stationary. If you supply one fuel to a few regular customers, a well-built spreadsheet is often enough.
Your ETS2 report from your own deliveries?
Tell us which fuels you supply, to whom and how the emissions report is currently produced. We will show you how the software can handle it.