@Sepp
The same (EU-based AOC operator, below minimas but expanding ...) applies for us. According to the information we've received from Unité ETS at Paris, for the time being "no furhter actions are required. If you don't fall anymore under the "de minimi" threshold, then Eurocontrol will know it and add you into an updated list of aircraft operators". This all sound very confusing if not chaotic to me ... and I refuse to believe that expanding small operators are well advised to do nothing, therefore we have decided to do a statistical analysis of fuel used from 1.1.2010 on our side (although Paris' response to it was "you can do it in order to be sure of your situation but it is not required"). Other than that we just wait and see ...
What are you doing? Do you have other statements?
Regards, A70