Due to the amendment of the EU ETS Directive, maritime transport was added to the existing EU ETS. The maritime expansion initially covers all cargo and passenger ships of and above 5 000 gross tonnage (GT), that call at EEA (European Economic Area) ports, regardless of the flag under which they sail. From January 1, 2025, the Regulation (EU) 2015/757 of the European Parliament and of the council (MRV Maritime Regulation) applies to offshore ships with a gross tonnage of 5 000 or more and to general cargo ships with a gross tonnage of less than 5 000 but not less than 400. Offshore ships with a gross tonnage of 5 000 or more will be covered by the EU ETS from 2027 (Annex I of the EU ETS Directive). The EU ETS does not apply to, for example, warships, naval auxiliaries, fish-catching ships, etc.
The requirements applicable to shipping companies derive from both the MRV Maritime Regulation and the EU ETS Directive 2003/87/EC. Shipping companies were associated to a Member States by Commission Implementing Decision (EU) 2024/411 and the published attribution list is updated every two or four years. The aforementioned Implementing Decision was amended on 5 December 2025 by Commission Implementing Decision (EU) 2025/2452, which contains an updated list of shipping companies. A shipping company that is not on this list is attributed to the administering authority in accordance with the requirements of Article 3gf of the EU ETS Directive. The following greenhouse gases are covered by the EU ETS: carbon dioxide (CO2) and from 2026 methane (CH4) and nitrous oxide (N20). The trading system covers emissions from maritime transport as follows:
- 100% of emissions from ships calling at an EEA port for voyages within the EEA
- 50% of the emissions from voyages starting or ending outside of the EEA
- 100% of emissions produced when ships are within EEA ports
All ship's greenhouse gas emissions reporting takes place in THETIS-MRV platform. By April 1, 2024, shipping companies had to submit to the Environmental Board a monitoring plan assessed by a verifier for each of their ships that falls within the scope of the MRV Maritime Regulation and the EU ETS Directive. Environmental Board checked and approved those monitoring plans by June 6, 2025 at the latest. For ships falling within the scope of the aforementioned regulation for the first time after 1 January 2024, companies shall submit a monitoring plan in conformity with the requirements of this Regulation to the administering authority responsible without undue delay and no later than three months after each ship’s first call in a port under the jurisdiction of a Member State. In the latter case, the monitoring plan must be approved by the administering authority within four months of the ship's first visit to a port under the jurisdiction of the Member State.
Shipping companies belonging to the EU ETS must submit a verified emissions report to the administering authority every year and enter the emissions in the Union Registry.
According to the MRV Maritime Regulation, shipping companies are obliged to submit a verified emissions report by 31 March of each year for each ship on their fleet that was subject to the MRV Regulation during the reporting period. However, if a ship did not make any voyages covered by the MRV Regulation during the reporting period, it is recommended to submit a zero emissions report to prove this.
In addition, shipping companies covered by the EU ETS must submit a verified emissions report at company level (aggregated emissions data at company level) to the administering authority by the same deadline and enter the verified emissions in the Union Registry. If the company's activities were not covered by the ETS during the reporting period, it should submit a zero emissions report to prove this - otherwise the verified emissions cannot be reported as zero in the Union Registry.
In the event of a change of company (e.g. sale of a ship), the shipping company must submit a verified partial emissions report as soon as possible after the date of completion of the change and no later than three months thereafter, and this emissions report shall only cover the period during which the activity was carried out under its responsibility.
Shipping companies shall be liable to surrender allowances according to the following schedule:
40% of verified emissions reported for 2024;
70% of verified emissions reported for 2025;
100% of verified emissions reported for 2026 and each year thereafter.
Every year by September 30th at the latest, the shipping company must surrender the allowances in the Union Registry according to the emissions verified for the previous calendar year.
Union Registry
Shipping companies covered by the EU ETS must open a maritime operator holding account (MOHA) in the Union Registry. The registry has been established in accordance with the EU ETS Directive and Article 6 of the European Commission Decision 280/2004/EC. The registry is managed and operations are carried out in accordance with Regulation (EU) 2019/1122 of the European Commission.
If you have any questions, please contact Estonian Registry Administrator:
Mr. Mihkel Toom
Information session materials
Presentation from the information exchange meeting:
Contacts
Laura-Anett Kreevald
chief climate specialist
Mihkel Toom
senior climate specialist
Last updated: 19.06.2026
