Expert opinion: What the UK CAA’s new environmental information framework means for airlines
February 12, 2026
Patrick Bettle is a senior associate in Burges Salmon’s Dispute Resolution practice and a member of the firm’s top-tier transport team. His practice covers all aspects of the aviation industry and assists clients with commercial disputes at all stages of the lifecycle, as well as with wide-ranging regulatory advice.
He acts for airlines, aircraft lessors, OEMs, and maintenance and ancillary service providers in the UK, the EU and beyond. Patrick has a particular interest in decarbonisation and has assisted several leading airlines and suppliers with regulatory investigations into greenwashing concerns.
On 5 February 2026, the UK’s CAA published its new framework for the implementation of standardised consumer environmental information (CAP 3112).
The framework draws upon industry responses to the CAA’s previous call for evidence and consultation on the topic in 2023 and 2024, respectively. It aims to ensure that consumers are provided with clear and consistent emissions information at the point of searching for and booking their flights, and reflects the wider regulatory drive to provide UK consumers with clearer pre-purchase information.
Which airlines and booking platforms are covered by the CAA’s CAP 3112 environmental framework?
The framework has a broad scope. It applies to all flights sold or advertised in the UK that depart from or arrive at UK airports. It covers both airlines and booking platforms. This means that the framework will effectively apply to all airlines operating in the UK.
What must airlines and travel platforms do under the CAA’s flight emissions rules?
The framework updates the CAA’s Consumer Environmental Information Principles. It does not set out specific requirements as to precisely how data should be presented, but instead provides broad guidelines as to how emissions information should be reported.
In summary, such information should be:
- Accessible – Emissions information should be easy to locate without navigating multiple sub‑pages and should be accessible to users requiring adjustments (e.g., screen‑reader compatibility).
- Transparent – Consumers should be able to understand how emissions information has been calculated, including by being able to understand what methodologies have been used and how data has been gathered (this information can be provided in a linked webpage).
- Accountable and accurate – Publishers must take reasonable care to ensure the accuracy of the information provided.
- Specific – CO₂ or CO₂e estimates must be calculated using input data that most accurately represents a given route, aircraft, and capacity (including aircraft and engine type, flight distance, seat class, occupancy, passenger load and belly cargo) to provide consumers with a granular level of detail tailored to their choices.
- Timely – The CAA requires best endeavours to be used to keep the data as recent as possible and suggests that it should be updated at least annually.
- Consistent – Consumers should not see different environmental information applicable to the same flight on different platforms; this means that booking platforms should ensure that their data is consistent with the data published by the relevant airlines.
- Standardised – Information must meet minimum standards to ensure consistency across the industry.
- Comparable – Consumers should be able to compare information across different airlines and publishers, meaning that similar metrics should be used.
- Comprehensive – A new principle requiring publishers to use best endeavours to include information on the impact of an airline’s use of Sustainable Aviation Fuel (SAF) for a given flight or route.
- Subject to continuous improvement – The framework supports ongoing enhancements to both published information and industry sustainability performance.
Emissions data should be calculated using internationally recognised methodologies, such as DESNZ estimates for UK aviation emissions.
When does the CAA’s environmental information framework take effect?
The new framework does not come into effect immediately. The CAA expects airlines and other relevant organisations to work towards implementing the updated approach by 30 April 2027.
What happens if airlines fail to comply with the CAA’s emissions information framework?
Compliance with the framework is not currently mandatory, and the CAA will not take enforcement action against organisations that do not meet the expectations by the deadline. However, this position may well change following the CAA’s review of how airlines and booking platforms have implemented the framework, particularly if consumer-facing information does not comply with the stated principles.
Where organisations do not meet expectations, the CAA reserves the right to gather and publish the relevant data itself using its powers under section 85 of the Civil Aviation Act 2012.
As efforts continue towards the achievement of Jet Zero, environmental data is understandably an area of increasing importance for UK aviation. It is therefore no surprise that the CAA has been very active in this area in recent months.
