Approaching 31 March deadline for emission data reporting under EU MRV and EU ETS

The EU ETS began applying to certain vessels on voyages to/from and within the EU from 1 January 2024. According to a report published by the European Commission on 18 March 2025, over 5,000 shipping companies have registered in Thetis-MRV, the portal for uploading emission reports in the format as required by the EU MRV. The European Commission also reported that the administering authorities have received verified monitoring plans under the EU MRV for more than 15,000 ships. Some vessels will not (yet) fall under the EU ETS and will therefore only need to comply with the EU MRV reporting requirements at this time.

However, shipping companies falling within the scope of the EU ETS must also open a Maritime Operator Holding Account ("MOHA") and enter verified emission data from 2024 in the EU ETS Registry by 31 March 2025. This will be the first instance of shipping companies reporting under the EU ETS, and it remains to be seen what the rate of compliance will be. The shipping industry was implemented into the EU ETS relatively quickly, and some shipping companies are still familiarising themselves with the fairly complex new requirements and guidance being continuously published by the EU, leading to some administering authorities in some jurisdictions being overwhelmed with last-minute applications for accounts.

Responsible party

The default responsible party for compliance with both the EU MRV and the EU ETS is the registered owner, regardless of whether they are an EU or a non-EU company. However, the registered owner can delegate responsibility to the ISM Company, which could be the technical manager or a bareboat charterer, by completing a mandate letter and submitting it to the relevant administering authority.

Unless the registered owner has mandated the ISM Company, it is the registered owner that must submit the verified emission report for each of the ships under their responsibility, as well as an emission report at company level, in Thetis-MRV by 31 March.

Additionally, the responsible party must also open a MOHA and enter emission data in the EU ETS Registry, which must also be verified by 31 March. This means that the reports and emission data must have been verified by an accredited verifier before the deadline. Classification societies will typically act as the accredited verifier.

The Norwegian Environment Agency's role

The Norwegian Environment Agency (Nw: Miljødirektoratet) is an agency of the Ministry of Climate and Environment in Norway and serves as the administering authority in respect of a shipping company for EU ETS and EU MRV compliance in Norway. The Agency is responsible for ensuring that verified emissions reports and emission data have been submitted. The Agency will not verify or approve the emission reports or data but will supervise the submission status.

Additionally, the Agency acts as the national administrator in Norway. This entails that the Norwegian Environment Agency is responsible for administering the EU ETS accounts in Norway for the EU Union Registry, and it is therefore responsible for managing the applications to open a MOHA.

The Norwegian Environment Agency has published several guides on how to open accounts and submit emissions and surrender allowances on their website. Questions related to the user interface of the registry may be directed to the Norwegian Environment Agency.

Reporting requirements in the EU ETS registry

The first step for a responsible shipping company is to apply for a MOHA. This is done by contacting the Norwegian Environment Agency and complying with their step-by-step process for opening the account.

Once the MOHA has been opened, the shipping company needs to enter into a contract with an accredited verifier. Once this contract is completed, the shipping company can appoint the verifier in the EU ETS Registry. The verifier will then be able to see the data that the shipping company will enter in the EU ETS Registry.

The emission data may then be entered into the EU ETS Registry. The figures should match the figures that have been reported in Thetis-MRV. These figures may then be verified by the verifier in the EU ETS Registry. All these steps must be completed by 31 March.

If the emission data is not entered and verified by 31 March, the MOHA will be blocked. This entails that no allowances may be transferred out of the account. However, the account may still receive allowances, and the shipping company may still enter the emission data. Once the emission data have been entered and verified, the account will be unblocked. The blocking of the account is an automatic process in the registry and will happen immediately upon failure to comply, meaning that there is no grace period.

Shipping companies should be aware of the more severe consequences which apply in case of failure to comply with the requirement to surrender allowances by the deadline on 30 September. By 1 October, every MOHA will receive a compliance status of either A, B or C. If the account status is "A", this entails that sufficient allowances have been surrendered to cover the verified emissions and there are no consequences.

A status of "B" means that a shipping company has not surrendered sufficient allowances to cover the verified emissions by the deadline. For companies that are administered by the Norwegian Environment Agency, it will issue a penalty of at least EUR 100 for each allowance that has not been surrendered. The shipping company will still have to surrender the outstanding allowances in order to be in compliance with EU ETS.

If the account status is "C", this means that the account has neither surrendered the allowances nor entered verified emissions. This account will remain blocked, and the shipping company will also be subject to the penalty.

If shipping companies fail to comply for two or more reporting periods this may result in operational limitations, such as the shipping company's vessels being barred from or detained in EU ports.

It is only the MOHA that will receive a compliance status. If a shipping company has opened a trading account, this account will not be affected by any compliance status, as a trading account cannot be used for entering emission data or for surrendering allowances.