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2025 EU MRV, EU ETS & FuelEU Maritime Verification Season: Lessons from the Verifier's Perspective
The 2025 compliance season was another milestone for us at Normec Verifavia. As the maritime industry continued adapting to the evolving EU MRV, EU ETS and FuelEU Maritime frameworks, we worked closely with operators to ensure accurate, compliant and timely verification of their emissions and compliance reports.
During the 2025 reporting season, we successfully completed:
Completing more than 2,800 verification engagements across EU MRV, EU ETS and FuelEU Maritime provided us with a unique perspective on the industry’s first full compliance season. Beyond completing a large volume of verifications, the season provided valuable insights into the practical challenges faced by operators and highlighted areas where regulatory awareness can be further strengthened ahead of the next reporting cycle.
During the early implementation of FuelEU Maritime, one recurring challenge was several operators using biofuels were unaware of the requirement to provide valid Proof of Sustainability (PoS) documentation. This resulted in delays to the verification process.
Our Resolution: Using our Emissions Dashboard, supported by BDN-based reporting and API-integrated data, we identified missing sustainability documentation during verification. We subsequently guided operators on the applicable ISCC requirements, helping facilitate timely verification while improving awareness for future compliance cycles.
Ro-Pax vessels presented some of the most demanding reporting scenarios, driven by Dual-Fuel operations, Bio-LNG usage, OPS and the sheer volume of annual voyages. Under FuelEU Maritime, mandatory reporting of all voyages and port calls further increased the reporting complexity & the operators IT systems often provided only limited voyage-level data.
Our Resolution: We worked closely with operators to streamline the reporting process, by guiding them on preparation and validation of multiple sequential XML submissions. This ensures that the full annual dataset was accurately incorporated. For Dual-Fuel and Bio-LNG scenarios, we provided additional guidance on the reporting of fuel consumption and OPS-related data, helping operators align their submissions with the applicable EU ETS and FuelEU requirements
We observed that many operators were unfamiliar with the different derogations and exemptions available under EU ETS and FuelEU Maritime, particularly where their applicability differs between the two regulations. This often led to incorrect or missed declarations in THETIS, impacting emissions calculations and compliance results.
Our Resolution: With our continuous verification process through our Emissions Dashboard, we assessed the eligibility of applicable derogations and identified instances where they had been incorrectly applied or overlooked. We proactively guided operators on the correct regulatory interpretation and application in THETIS, while raising awareness for accurate reporting in the future.
Fuel classification was another area with inconsistencies. Operators often classified fuels primarily based on sulphur content, whereas EU ETS and FuelEU Maritime calculations require fuel segregation based on viscosity in accordance with the applicable ISO fuel standards. Incorrect classification could directly affect emissions calculations and compliance outcomes.
Our Resolution: Leveraging our API-enabled data validation with BDN-based reporting, we efficiently identified fuel segregation discrepancies during verification. We reviewed the reported categorisations, directed corrections where necessary & guided operators towards the correct classification methodology.
During the reporting season, updates to the THETIS platform affected the calculation of GHG intensity and FuelEU compliance balances for Ice Class IA and IA Super vessels. Additional changes to decimal rounding methodologies also created reconciliation differences between operator submissions and verified values.
Our Resolution: To remain aligned with the latest THETIS and EMSA updates, we promptly incorporated the revised calculation methodologies into our internal verification tools and digital verification platform. We subsequently recalculated and revalidated the affected reports, ensuring that the verified results remained fully consistent with the latest calculation methodology.
The expansion of EU MRV to include vessels between 400 GT and 5000 GT introduced new compliance challenges. Operators were unaware that these vessels had entered the scope of the regulation. For offshore vessels, additional uncertainty arose around the regulatory definition of a port of call and the identification of reportable voyages.
Our Resolution: We assessed vessel applicability on a case-by-case basis, verified voyage eligibility in accordance with the regulation, and provided practical guidance on scope, voyage determination, and the interpretation of port-of-call requirements for offshore operations, enabling operators to report with greater confidence and accuracy.
One of the biggest learning points for many operators came from their unfamiliarity with the FuelEU Maritime flexibility mechanisms. They were unaware on how these could be strategically applied to optimize compliance.
Our Resolution: Throughout the verification process, we guided operators on the regulatory implications and suitability of the available flexibility mechanisms for their vessels. Leveraging our familiarity with numerous pooling platforms, we helped operators better understand surplus, deficit, banking and pooling options reducing their overall compliance costs.
Reflecting on the 2025 verification season, one of our strongest observations is that successful compliance depends not only on accurate emissions data but also on a thorough understanding of the regulations governing that data.
Many of the issues encountered this year stemmed from evolving legislation, newly introduced reporting requirements, THETIS, IT SYSTEMS and limited familiarity with the practical application of the regulations. As these frameworks continue to mature, we expect many of these challenges to reduce as industry knowledge improves.
From our experience, operators can significantly improve the efficiency of future verification cycles by:
For us at Normec Verifavia, verification goes beyond regulatory compliance. It is about partnering with operators to navigate an evolving regulatory landscape with confidence. As the Maritime regulatory landscape continues to evolve with the introduction of CO₂-equivalent emissions, we see every verification season as an opportunity to help the maritime industry move towards smarter and more efficient environmental compliance.
