Consumer Environmental Information (CAP3112)

Airlines and other organisations selling or advertising applicable flights in the UK are expected to take adequate steps towards implementing the Consumer Environmental Information framework by 30 April 2027 and to make environmental information available during the online search and booking process by that date.

At minimum, adequate steps means providing consumers with information on the environmental impacts of at least a proportion of flights. Where there are significant barriers to implementation, such as technical or website changes, organisations should communicate this to consumers and provide information on when environmental information will become available. The framework has been designed to align, where possible, with emerging international approaches. As a result, work undertaken to implement EU or Swiss requirements should be readily adaptable to the UK context. The intention is to provide flexibility and avoid duplication, allowing organisations to leverage existing investments in methodologies, data systems and implementation activity

The framework is currently being implemented through CAA expectations and monitoring rather than an immediate mandatory reporting regime. During 2027, the CAA will review industry uptake and determine whether additional measures, including a more mandatory approach, are required. The CAA's preference is not to introduce a mandatory requirement if effective implementation can be achieved through the current framework.

The framework applies to flights that depart from or arrive at UK airports when those flights are sold or advertised in the UK. The CAA defines these as "applicable flights", meaning the framework covers both outbound and inbound services connected to the UK, rather than only flights departing from the UK.

This definition aligns with the CAA's existing approach to ATOL protection.

The framework applies where applicable flights are sold or advertised in the UK but does not prescribe a single mechanism for determining whether a consumer is located in the UK.

The CAA recognises that international booking platforms may rely on a range of indicators, including IP address data, point-of-sale information and other signals that indicate a website is targeting or serving UK consumers.

The CAA would generally expect organisations to take reasonable steps to identify when applicable flights are being offered to UK consumers and to implement the Consumer Environmental Information Principles accordingly.

Consistent with the CAA's approach to ATOL protection, a UK consumer may include an individual whose principal place of residence is in the UK.

The CAA acknowledges that airlines already provide emissions information through schemes such as CORSIA and emissions trading schemes and has sought to minimise additional burden by encouraging the use of existing internationally recognised methodologies rather than creating a new calculation standard.

The framework also aligns with stakeholder recommendations that annual updates should generally follow existing reporting cycles, including ETS and CORSIA where possible.

Leveraging existing reporting systems should help reduce implementation complexity and costs.

There are currently no financial penalties or formal sanctions associated with implementation by April 2027.

However, the CAA will monitor industry adoption during 2027 and, where organisations do not take credible steps towards implementation or fail to use recognised methodologies, it may consider further action.

This could include using its information-gathering powers under the Civil Aviation Act 2012 and considering whether a more mandatory framework is required.

The framework states that environmental information should be available during the online search and booking process for applicable flights by April 2027, and that organisations should take adequate steps toward implementation by 30 April 2027.

The framework does not establish a formal phased transition period. Instead, implementation will be followed by a monitoring and review phase during 2027, allowing the CAA to assess uptake, identify implementation challenges and determine whether further action is required.

At minimum, adequate steps means providing consumers with information on the environmental impacts of at least a proportion of flights. Where there are significant barriers to implementation, such as technical or website changes, organisations should communicate this to consumers and provide information on when environmental information will become available. The framework has been designed to align, where possible, with emerging international approaches. As a result, work undertaken to implement EU or Swiss requirements should be readily adaptable to the UK context. The intention is to provide flexibility and avoid duplication, allowing organisations to leverage existing investments in methodologies, data systems and implementation activity

CAP3112 provides the CAA's implementation framework, Consumer Environmental Information Principles, supporting guidance and preferred approach to methodologies.

The CAA has committed to continued stakeholder engagement and monitoring throughout implementation. We recognise that stakeholders have requested further clarification on topics such as methodologies, minimum data standards and implementation challenges.

At present, the CAA's approach is not to prescribe granular requirements, allowing flexibility in how organisations choose to present environmental information provided that it aligns with the principles set out in CAP3112.

Further stakeholder engagement on implementation is expected during December 2026.

The CAA will undertake a structured review to explore the following questions;

1. Can UK consumers readily access environmental information when searching for and booking flights?
2. Are airlines and intermediaries taking credible steps towards broad implementation of CAP3112?
3. Is voluntary uptake sufficiently widespread that a mandatory regime is unnecessary?

The CAA will look at a representative sample of relevant airlines, travel agents, comparison sites and holiday providers to assess;

• Whether environmental information is displayed during the search and booking process.
• At what stage the information appears (search results, flight selection, checkout, etc.).
• Whether the information is sufficiently prominent and understandable to consumers.
• Whether the information covers all flights offered or only a subset.
• Whether methodologies, assumptions and data sources are explained or linked.
• Whether information is provided consistently across channels.
• For providers not displaying environmental information, whether a clear explanation of barriers and implementation timelines is provided.

The CAA may also reach out to certain providers after it has completed an initial review to seek further information or clarification.

Responsibility for accuracy rests with the publishers of environmental information. Organisations are expected to use the most accurate, up-to-date and credible data available and to publish or link to the methodologies, data sources and any verification processes used.

The CAA will monitor implementation across airline and booking websites during 2027 and review the approaches being adopted across the sector.

We also intend to highlight examples of good practice where appropriate.

Following its review of implementation during 2027, the CAA will assess whether the framework is delivering transparent and accurate environmental information for consumers.

Where uptake is insufficient or organisations are not taking credible steps towards implementation, the CAA may consider additional interventions, including further guidance, additional requirements and potentially moving towards a more mandatory approach.

The CAA could also use its statutory powers to gather relevant information directly and, if necessary, consider alternative approaches to the provision of environmental information in the future.

The CAA's review during 2027 will examine the extent to which airlines, travel agents and booking platforms have implemented the framework in practice. At a minimum, organisations should be providing environmental information to consumers for at least some applicable flights and be able to demonstrate credible progress towards broader implementation. Where significant barriers remain, such as complex technical or website changes, organisations should clearly explain these constraints and set out when consumers can expect environmental information to become available.

This is an area that the CAA is continuing to explore through ongoing bilateral engagement with airlines, travel agents, online travel agents, comparison platforms and other affected stakeholders. The CAA recognises that by not mandating a specific approach to emissions calculations, some providers such as online travel agents and providers of complex itineraries may face particular challenges in implementing some elements of the framework, including ensuring consistent environmental information is presented across multiple airlines, booking channels and journey types. The April 2027 review will take these challenges into account and the CAA would not necessarily expect full implementation in all cases. However, organisations should be able to demonstrate credible progress, communicate clearly with consumers where information is not yet available, and set out how they could address outstanding issues and align with UK requirements and emerging international approaches.

A key challenge identified internationally is ensuring that consumers receive comparable information regardless of where they search for or purchase flights. Both the EU and Swiss approaches provide useful examples of how this can be addressed.

The EU Flight Emissions Label seeks to ensure consistency through the use of a harmonised methodology across participating airlines and booking channels, enabling more meaningful comparisons between flights and reducing the risk of differing emissions figures being displayed for the same itinerary.

The Swiss framework goes further in relation to connecting itineraries and package holidays, requiring emissions information to reflect the full passenger journey through to the final destination and to apply across travel agents, online booking platforms, and package holiday providers.

While the UK framework has not yet adopted a specific approach in this area, one potential model under consideration for the future is that where a flight product, itinerary or package holiday is offered for sale, the provider would display a single consumer-facing emissions estimate calculated using a recognised methodology. The estimate would cover the entire passenger journey, including all flight sectors, code-share segments, connecting flights and return flights were sold as part of the same transaction. We welcome further stakeholder engagement on these issues as implementation develops.