Nope. You do have to calculate your emissions between city pairs - using the GC dist between the two plus 95 km (from memory) - not just say "we flew 12,000 km in the last year", etc. If you have an AOC, and you are under the threshold, it would appear that you are out of it - no rqmt to be a sched operator. We come under the UK umbrella, I should add.
It has to be said, though, that this year has been a very quiet one for us - it won't take much of an upturn for us to have to submit.
