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EU MRV & ETS Emissions Report Verification

EU MRV & ETS Emissions Report Verification  

The EU MRV & ETS Emissions Report is a mandatory annual submission covering fuel consumption, GHG emissions, and operational data for vessels trading in EU waters. Normec Verifavia ensures compliance with evolving maritime regulations through accurate data validation, accredited verification, and seamless submissions to THETIS-MRV. This reduces administrative burden, minimizes risks of non-compliance, and supports stakeholders to stay ahead of regulatory requirements.

EU MRV and ETS Compliance Framework 

All vessels exceeding 5,000 GT, regardless of their flag, port of registry, or home port, fall under the scope of the EU MRV and ETS framework. The only exceptions are warships, naval auxiliaries, fishing and processing vessels, wooden ships of primitive construction, ships not mechanically propelled, and government vessels used for non-commercial purposes.

The reporting obligations include fuel consumption, greenhouse gas emissions, distance travelled, time spent at sea, cargo details, transport work, and average energy efficiency. These requirements apply to all voyages arriving at, departing from, and operating between EU or EEA ports, as well as time spent at berth. 

Why choose Normec Verifavia?

  1. Effortless Compliance: Normec Verifavia’s experienced verifiers stay ahead of the Layered EU ETS regulations and updates, ensuring your monitoring plans and emission reports are fully compliant. This proactive approach helps minimize the risk of non-compliance penalties and reporting delays.
  2. Established verification programme: For the EU ETS/MRV, we have established a Verification Program (reference: EU ETS/MRV Verification Program v.1 – May 2026), which is shared with our clients prior to the engagement phase.
  3. Unbiased Expertise: Benefit from Normec Verifavia’s independent, impartial, and regulation-compliant verification services, delivering accurate assessments that ensure full alignment with EU ETS standards.
  4. Human Touch, Backed by Expertise:Our auditors work closely with your team, offering practical guidance and support to ensure compliance with evolving EU ETS regulations, while helping you meet critical reporting deadlines with confidence.
  5. Normec Verifavia: Your Cost-Effective One-Stop Solution for GHG Emissions Verification: Normec Verifavia delivers a one-stop GHG verification solution across EU ETS, IMO DCS, CII, and other schemes, simplifying compliance through accurate, transparent, and fully aligned verification by independent experts.

Annual Emissions Reporting 

From 2025, companies must submit verified annual emissions reports for each vessel under their responsibility no later than 31 March each year. The reports must cover the full reporting period of the previous calendar year and be independently verified by an accredited body such as Normec Verifavia before submission through THETIS-MRV. 

Partial Emissions Verification 

When a vessel changes ownership or management, the former operator is required to prepare a Partial Emissions Report. This verified report must cover the same parameters as the annual report for the period during which the ship was under its responsibility. The partial report must then be submitted to the new operator, the flag State, and the administering authority via THETIS-MRV. 

Company Level Emissions Report

In addition to ship-specific reports, companies must also prepare a Company Emissions Report, which consolidates data across the entire fleet. Normec Verifavia verifies the Company-level Emissions Report, after which the company submits the verified data to its Maritime Operator Holding Account (MOHA). Normec Verifavia then performs a final validation on the MOHA account to ensure the submitted figures align with the verified data and meet the specific requirements of the administering authority, confirming they are accurate and ready for allowance surrender. 

EU ETS Compliance Cycle 

The compliance cycle begins with the verification of ship-level MRV emissions reports. Verified data is aggregated into a Company Emissions Report, which must be submitted to the administering authority by 31 March. By 30 September, companies are required to surrender EU Allowances equivalent to their verified emissions. Non-compliance results in financial penalties of 100 euros per tonne of CO₂ and may ultimately lead to vessel bans from EU trade. 

Normec Verifavia provides independent verification to support transparent, accurate, and compliant reporting under the EU MRV and ETS framework. 

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Process
  1. Initiate Contact

    Reach out to our team to discuss your requirements and receive a tailored proposal aligned with your operations. 

  2. Gather Information

    Submit your Monitoring Plan, emissions reports, and all necessary supporting documentation for assessment.

  3. Verification & Analysis

    Our experts conduct a detailed evaluation of ship-level and company-level emissions reports, verifying compliance with EU MRV and EU ETS regulations. 

  4. Completion of Verification

    Following successful verification, a Verification Report and Document of Compliance (DoC) are issued via the THETIS platform. 

  5. MOHA

    Final Validation of GHG Figures on MOHA for Allowance Surrender. 

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FAQ

Find answers to the most commonly asked questions

Which data and information must be monitored?

Based on the monitoring plan assessed in accordance with Article 13, for each ship arriving in or departing from, and for each voyage to or from, a port under a Member State’s jurisdiction, companies shall monitor in accordance with Part A of Annex I and Part A of Annex II the following parameters:  

  1. port of departure and port of arrival including the date and hour of departure and arrival;
  2. amount and emission factor for each type of fuel consumed in total;
  3. GHG emitted;
  4. distance travelled;
  5. time spent at sea;
  6. cargo carried;
  7. transport work.

Companies may also monitor information relating to the ship’s ice class and to navigation through ice, where applicable. 

What are the critical deadlines for 2025 and beyond?

Essential deadlines include: 

  • March 31, 2025: Verified emissions reports and company-level data submission 
  • April 1, 2025: Union Registry emissions data entry 
  • September 30, 2025: EU ETS allowance surrender (40% of 2024 emissions) 
  • Ongoing: Monitoring per approved plans, with annual verification cycle 

What are the consequences of non-compliance?

Non-compliance results in financial penalties of €100 per tonne of CO₂ equivalent, potential vessel trading restrictions in EU waters, and mandatory corrective action requirements with accelerated compliance timelines. 

What types of derogations are applied under the EU ETS for maritime transport as per Implementing Regulation (EU) 2023/2297 and Decision (EU) 2023/2895?

The following derogations are applied under specific regulatory conditions:

  1. Ice-Class Dispensation
    Ships certified as Ice-Class IA, IA Super, or equivalent receive a 5% reduction in their annual EU ETS allowance surrender obligation.
    – Applies to vessels operating in icy waters with higher fuel demands. 
  2. Transshipment Port Exclusion
    Ports outside the EU, within 300 nautical miles, with >65% container transshipment traffic and no ETS-equivalent measures are excluded from the “port of call” definition.
    • Current ports listed:
    – East Port Said (Egypt)
    – Tangier Med (Morocco)
    • Next review: October–December 2025 
  3. Outermost Region (OMR) Exemption
    Voyages between an EU outermost region and a port in the same Member State are exempt from surrendering allowances, including emissions at berth.
    Examples of OMRs:
    – Canary Islands (Spain)
    – Azores & Madeira (Portugal)
    – Guadeloupe, Martinique, Réunion, Mayotte, French Guiana, Saint Martin (France) 
  4. Small Island Exemption
    Passenger and Ro-Pax ships under transnational public service contracts or obligations may be exempt until 31 Dec 2030 for voyages between:
    – Small islands (no road/rail link, <200,000 population)
    – Mainland ports
    • Member States may define eligible islands via local legislation.
    • List of eligible islands and ports to be published by the European Commission.