EU MRV & ETS Monitoring Plan Assessment

The EU MRV (Monitoring, Reporting, and Verification) and EU ETS (Emissions Trading System) are key frameworks governing shipping emissions. The central element is the Monitoring Plan, which defines how companies measure, record, and report fuel consumption and CO₂ emissions. Its assessment ensures compliance, accuracy, and transparency, confirming robust methodologies, clear responsibilities, and effective procedures, supporting regulatory alignment and the EU’s broader climate and decarbonization objectives for maritime transport.

Monitoring Plan (MP)

The EU MRV and EU ETS frameworks are now closely aligned, with emissions data collected under the EU MRV serving as the foundation for the EU ETS. While the EU ETS is not yet mandatory for ships below 5,000 GT, it is expected that general cargo and offshore vessels between 400 and 5,000 GT will be included from 2027.
An EU MRV and ETS monitoring plan details how a shipping company will monitor, report, and verify greenhouse gas (GHG) emissions from its ships, including CO₂, methane (CH₄), and nitrous oxide (N₂O). These plans are updated from the original EU MRV framework to incorporate the requirements, requiring companies to monitor and report emissions data through the THETIS-MRV Platform to an Administering Authority. The plan must be created, submitted by the responsible company, and verified by an accredited verifier before being approved by the Administering Authority, which is crucial for compliance with the EU’s efforts to reduce emissions in the maritime sector.

Find answers to the most commonly asked questions

Which ships need to monitor and report their verified annual data? Are some categories of ships exempt?

The EU Monitoring, Reporting and Verification (MRV) Maritime Regulation (Regulation (EU) 2015/757 or, hereinafter, the ‘MRV Maritime Regulation’) applies to ships of 5 000 gross tonnage (GT) and above in respect of the greenhouse gas emissions released during their voyages from or/and to ports in the European Economic Area (EEA) for transporting for commercial purposes cargo or passengers.
In addition, as of 1 January 2025, the MRV Maritime Regulation will also apply to offshore ships of and above 5 000 GT, as well as offshore ships and general cargo ships below 5 000 GT but not below 400 GT.
Ships are subject to the MRV Maritime Regulation regardless of their flag.
A limited number of categories of ships are excluded, notably:

warships
naval auxiliaries
fish-catching or fish-processing ships
ships not propelled by mechanical means
government ships used for non-commercial purposes.

Which offshore ships are subject to MRV obligations (since January 2025)?

Offshore ships of 400 gross tonnage and above are covered by the MRV Maritime Regulation since January 2025.
On 16 October 2024, the European Commission adopted amendments to Annex I of the MRV Maritime Regulation via a delegated act. This was to clarify that the Regulation should cover emissions from ships, other than icebreakers, designed or certified to perform service activities offshore or at offshore installations. The provided list of ships includes, among others, offshore support vessels, pipe layers, and drilling ships. The delegated act was published in the Official Journal on 27 December 2024.
Furthermore, the Commission has established a dedicated workstream within the existing European Sustainable Shipping Forum expert group, gathering Member States, various shipping organisations and civil society representatives. This workstream should facilitate exchanges of views and expertise on topics related to the inclusion of offshore ships within the MRV scope – especially in view of potential future adjustments to the Regulation.

Do emergency generator engines need to be included into the list of emission sources?

In general, emergency generator engines are not considered emission sources under the MRV. The regulation primarily applies to main engines, auxiliary engines, gas turbines, boilers, inert gas generators, and incinerators. However, if an emergency generator engine is used for operational purposes, it must be treated as an auxiliary engine. In such cases, the engine should be listed as an emission source in the Monitoring Plan (MP), with its fuel consumption monitored and corresponding emissions reported in the Emissions Report (ER).

What happens if my monitoring plan is not compliant?

Non-compliance with EU ETS regulations can result in penalties, including fines and potential exclusion from trading allowances. Therefore, having a verified and compliant monitoring plan is crucial.