Inclusion of Maritime Emissions

Implementation Timeline for Offshore Ships

Regulation (EU) 2023/957 was published in the Official Journal of the European Union (EU) on 16 May 2023 and entered into force on 5 June 2023. It amended Regulation (EU) 2015/757 on the monitoring, reporting and verification (MRV) of greenhouse gas emissions (GHG) from maritime transport. As of 1 January 2025, the amended Regulation 2015/757 also applies to offshore ships of 400 gross tonnage (gt) and above, covering GHG emissions released during their voyages from their last port of call to a port of call under the jurisdiction of a member State and from a port of call under the jurisdiction of a member State to their next port of call, as well as within ports of call under the jurisdiction of a member State.

Beginning on 1 January 2027, the EU ETS Directive will expand to cover offshore ships exceeding 5,000 gt, which will be required to surrender allowances at the company level by 30 September 2028. No later than 31 December 2026, the European Commission (EC) will present a report to the European Parliament and the Council, evaluating the feasibility, as well as the economic, environmental and social impacts, of including emissions from offshore ships, between 400 and 5,000 gt in the EU ETS Directive.

Applicable Offshore Ships

Directive (EU) 2023/959 amends Directive 2003/87/EC, which provides that, regarding offshore ships, a “port of call” includes the port where the boat stops to relieve the crew.  

Delegated Regulation (EU) 2024/3214 has amended Annex I to Regulation (EU) 2015/757 to clarify the term “offshore ships,” ensuring a uniform application concerning the determination of the GHG emissions covered by the Regulation beyond those already covered when related to a ships’ movements and activities serving the purpose of transporting cargo or passengers for commercial purposes. According to this amendment, GHG emissions from offshore ships shall cover GHG emissions released during voyages from the last port of call to a port of call under the jurisdiction of a member State and from a port of call under the jurisdiction of a member State to the next port of call, as well as within ports of call under the jurisdiction of a member State by the ships listed below, other than icebreakers, designed or certified to perform service activities offshore or at offshore installations:

This list is non-exhaustive. The ship’s statutory certifications or any other relevant documentation, including class notations, should be considered to determine whether the ship is designed or certified to perform service activities offshore or at offshore installations.

Ships Operated in Stationary Mode

Ships operated in stationary mode still fall within the scope of EU ETS but for stationary installations. As per the EC’s guidance document:

“Where liquefied natural gas (LNG) terminals or other offshore installations such as oil rigs are installed on a ship, the emissions from the ship’s engine would be covered by the EU ETS for maritime transport while it is mobile. However, if the ship’s engine is used during stationary mode (e.g., for the production of electricity or heating), its emissions are to be included in the GHG permit which it requires for being stationary.”

Therefore, operators of such ships should contact the jurisdiction's competent authority where the ship is operated in stationary mode to obtain a GHG emissions permit per Article 4 of the EU ETS Directive and submit a monitoring plan for approval accordingly. Note that such monitoring plans are not included in THETIS-MRV and that such ships will not be subject to other obligations set in the MRV Maritime Regulation, such as reporting emissions within the port of call, as long as they remain stationary. For more information, see the EC's website for guidance on stationary installations.

Stops at Offshore Facilities

Any offshore facility having an assigned United Nations Code for Trade and Transport Locations (UN/LOCODE) and any offshore facility located outside port areas but permanently connected to a port are considered ports within the MRV Maritime system.

• Offshore facilities having an assigned UN/LOCODE may include, but are not limited to, FPSO units, Floating storage and regasification units (FSRU), and single points of mooring (SPMs).
• The permanent connection of an offshore facility located outside port areas to a port can be established by different means if it serves the purpose of transferring cargo or passengers from the ship to the connected port (or conversely) in a permanent manner (e.g., including via, but not limited to, pipelines). Where such an offshore facility does not have any assigned UN/LOCODE, the shipping company should report the UN/LOCODE of the port to which the facility is connected.

Stops at offshore facilities that have an assigned UN/LOCODE and/or are permanently connected to a port will, therefore, determine a port of call within the MRV Maritime Regulation, provided that the loading/unloading of cargo or passengers or release of the crew take place there.

Actions for Compliance

1. From 1 January 2025, the shipping company must submit the monitoring plan of the offshore ship to its administering authority within three months after the ship’s first port of call in a port under the jurisdiction of a member State.
   1. The monitoring plan submitted to the administering authority must already have been assessed by an accredited verifier as conforming to the MRV Maritime Regulation.
   2. As offshore ships do not currently fall within the EU ETS scope, the administering authority is not required to approve them (only submit them).
2. From 1 January 2025, start monitoring carbon dioxide, methane and nitrous oxide emissions and activity data according to the verified EU MRV monitoring plan for the offshore ships with a port of call in a port under the jurisdiction of a member State.
3. By 31 March 2026 and each year, submit to the responsible administering authority to the ship’s flag State (for ships flying the flag of a member State) and to the EU Commission a verified emissions report for the entire reporting period of the previous year.
   1. As EU ETS does not cover offshore ships for the time being, they are not concerned by the obligation to submit aggregated emissions data at the company level (the so-called ‘CER')
4. By 30 June 2026 and each year, carry a valid Document of Compliance (DoC) on board.
5. By 31 March 2028 and each year, companies shall submit to the administering authority for offshore ships of 5,000 gt and above an aggregated report at the company level for the emissions of the previous calendar year.

References

The European Commission’s recent proposal COM(2026) 616 with its annexes sets out a comprehensive revision of the European Union Emissions Trading System (EU ETS), including important updates to the regulatory framework for maritime transport. These amendments are intended to align the sector with the EU’s climate ambitions, supporting its decarbonization while taking international developments into account.

Complementing these changes, the related proposal COM(2026) 620 introduces amendments to the EU MRV and FuelEU Maritime Regulations aimed at further streamlining the regulatory framework for shipping. In particular, the proposal seeks to align compliance cycles across the EU MRV, EU ETS and FuelEU Maritime regimes, minimize duplication and regulatory divergences, and strengthen the “monitoring-and-reporting-only-once” principle. Collectively, these measures are expected to reduce the associated administrative burden and costs for shipping companies.

EU MRV Regulation

1.    Extension of the Scope to Smaller Vessels

From 1 January 2029, the Commission proposes extending the EU MRV Regulation to additional vessel categories between 400 GT and 5,000 GT, including:

• Oil tankers
• Chemical tankers
• Gas carriers
• LNG carriers
• Ro-pax ships
• Passenger ships

General cargo ships and offshore vessels in this size range are already covered by the MRV Regulation since 2025.

2.    Ships Performing or Supporting Offshore Operations

The proposal replaces the current vessel-type approach with a broader activity-based framework covering vessels performing or supporting offshore operations in connection with an offshore worksite situated in the territorial sea, the EEZ, the continental shelf or the continental shelf sea of a Member State. Key changes include:

• New definitions of "offshore operations" and "offshore worksite"
• Removal of the existing list of offshore ship categories from Annex I
• Expansion of the definition of "port of call" to include offshore worksites

3.    Single Monitoring, Reporting and Verification Framework

The proposal seeks to establish a unified MRV framework that covers both GHG emissions and the energy used on board by ships supporting compliance under EU MRV, EU ETS and FuelEU Maritime. Shipping companies would submit a single monitoring plan and a single MRV report (including additional FuelEU-related parameters) for each ship under their responsibility.

To synchronize the compliance cycle, the proposal requires companies, by 28 February of the verification period, to submit the single MRV Report and the Compliance Balance Report (for FuelEU).

4.    Harmonization of Verification and Administration

Additional amendments include:

• Harmonization of verification procedures across MRV, EU ETS and FuelEU Maritime.
• Establishment of a single accreditation framework, whereby FuelEU verifiers must hold accreditation under the MRV Regulation.
• Clarification of the role and responsibilities of the administering authority through the introduction of a new Article 4a in the MRV Regulation and the establishment of an attribution mechanism for any shipping company falling within the scope of the MRV Regulation.
• Alignment of enforcement and compliance oversight provisions between MRV and FuelEU Maritime.
• Designation of the same administering authority for MRV, EU ETS and FuelEU Maritime obligations.

These changes are intended to support the principle of “monitoring and reporting only once” by creating a single monitoring, reporting, verification and administrative framework for MRV, EU ETS and FuelEU Maritime compliance.

EU ETS Directive

1.    Extension of the Scope to Smaller Vessels

Building upon the proposed MRV expansion, the Commission proposes extending the EU ETS from 1 January 2031 to certain vessel categories between 400 GT and 5,000 GT that become subject to the MRV requirements from 2029. 

Ro-pax and passenger ships below 5,000 GT are excluded at this stage and would be subject to a future assessment.

2.    Offshore Operations

Vessels performing or supporting offshore operations would become subject to the EU ETS from 2031, provided that they fall within the categories and activities covered by the amended MRV Regulation and ETS Directive.

3.    Avoidance of Double Payment

The Commission seeks to improve coherence between the EU ETS and any future IMO global GHG pricing mechanism. Accordingly, the proposal strengthens the maritime review clause by requiring a specific assessment of potential double payment and other interactions between the two systems. The proposal also contemplates the introduction of an IMO deduction mechanism, under which shipping companies could be permitted to surrender fewer EU ETS allowances to the extent that the same emissions are effectively subject to a carbon price under a future IMO measure.

4.    Sustainable Maritime Alternative Propulsion (SMAP) Mechanism

A newly established Sustainable Maritime Alternative Propulsion (SMAP) mechanism would reinvest ETS revenues to support the decarbonization of the maritime sector. For this purpose, up to 110 million allowances would be reserved from the first year following the entry into force of the revised Directive until 2040 to support the uptake of sustainable maritime fuels (SMF) and the deployment and operation of zero-emission propulsion technologies (ZEPT).

The reserved allowances would be used to cover all or part of the remaining price gap between SMF and fossil fuels, and to offset part of the additional costs associated with the deployment and operation of ZEPT. To qualify for support, SMF must be produced, and ZEPT must be manufactured, in:

• the EU;
• a third country with an emissions trading system linked to the EU ETS; or
• a third country supported by the EU under “ETS as a service”.

Shipping companies may apply annually for an allocation of allowances based on the quantity of SMF used or the emissions reductions achieved through ZEPT during the previous calendar year. The Directive proposes specific support rates, such as:

• 55% for advanced biofuels and biogas;
• 90% for renewable fuels of non-biological origin (RFNBOs);
• 80% for low-carbon hydrogen and low-carbon fuels; and
• 90% of the additional cost of zero-emission propulsion technologies.

These percentages can be increased in certain circumstances (e.g., island routes, EU-sourced feedstocks, or technology installed in EU shipyards).

5.     Extension of Existing Derogations

The proposal extends until 2035 existing derogations for:

• Ice-class ships
• Voyages involving outermost regions
• Voyages involving small islands without a fixed land connection
• Certain passenger transport services operated under public service obligations (PSOs) or public service contracts (PSCs)

The extension reflects the continuing challenges associated with the large-scale deployment of low- and zero-emission technologies and fuels on vessels providing essential connectivity services, as well as the specific technical constraints faced by ice-class ships.

6.    Containership-Specific Measures

The proposal introduces additional measures to reduce the risk of evasive port calls and the relocation of transshipment activities outside of the EU. To support this objective:

• The list of neighboring container transshipment ports would be reviewed annually rather than every two years.
• The existing criterion would be broadened to include non-EU ports located within 300 nm of an EU port where container transshipment exceeds 50% of its total container traffic (reduced from the current 65% threshold).
• A new criterion would include non-EU ports located within 150 nm of an EU port with specific terminal capacities (draught >11m, berth >250m, and suitable ship-to-shore cranes).

In addition, a temporary derogation until 31 December 2035 would allow shipping companies to surrender fewer allowances for incoming voyages (from a non-EU port to an EU port) exceeding 300 nm when performed by large containerships of 10,000 TEU and above.

7.    Emissions Reduction Trajectory

To align the system with the Union’s 2040 climate target of a 90% net reduction in emissions, the proposal adjusts the EU ETS reduction trajectory from 2031 onwards by adjusting the Linear Reduction Factor (LRF):

• 3.7% annually from 2031-2035
• 1.7% annually from 2036 onwards, reflecting the proposal's assumption that up to 260 million high-quality international credits may contribute to achieving the Union's 2040 climate target. If such credits are not available, the LRF would revert to 2.7% from 2036.

As a result, the emissions cap would decline at a slower pace after 2035 and allowances would continue to be issued into the 2040s.

In addition, the proposed extension of the EU ETS to certain smaller vessel categories between 400 GT and 5,000 GT from 1 January 2031 would be accompanied by a corresponding increase in the Union-wide emissions cap.

Next Steps

Both legislative proposals, COM(2026) 616 (EU ETS) and COM(2026) 620 (EU MRV/FuelEU Maritime), will proceed through the ordinary legislative procedure and require adoption by both the European Parliament and the Council before entering into force. The "One Europe, One Market" Roadmap identifies the first quarter of 2027 as a target for agreement on the EU ETS review. Given that COM(2026) 620 is designed to complement and align with the ETS review, the two proposals are expected to be negotiated in parallel. Both acts would enter into force 20 days after publication in the Official Journal.

For the EU ETS proposal, maritime-related implementation would be phased in. Key provisions such as the new Sustainable Maritime Alternative Propulsion (SMAP) mechanism, enhanced anti-evasion measures for container transshipment, and the extension of existing derogations for ice-class ships, outermost regions, small islands and certain public service passenger services are expected to apply from 1 January 2029. The further extension of ETS scope to offshore vessels and certain additional vessel categories between 400 GT and 5,000 GT, together with a corresponding increase in the maritime emissions cap, is expected to apply from 1 January 2031.

The European Commission has also launched a call for feedback on the proposed amendments to the EU ETS Directive and the MRV Regulation and the FuelEU Maritime Regulation, available here. The feedback deadline is 3 November 2026. All feedback received will be summarized by the European Commission and presented to the European Parliament and Council to support the legislative debate.