Monitoring, Reporting and Verification (MRV) obligations

Monitoring plan

Guiding Principles and Key Elements

Shipping companies must prepare a separate monitoring plan (MP) for each ship, outlining how emissions will be monitored. The MP must be verified by a third party and submitted to the administering authority via THETIS-MRV. Any subsequent changes must be verified and resubmitted immediately.

Main Elements of the Monitoring Plan:

• Basic Data: includes ship and company details, emission sources, procedures for monitoring fuel consumption, and emission factors for each fuel type
• Activity Data: covers the ship’s travelled distance, cargo carried, and time spent at sea
• Data Gaps: methods for handling any gaps in data
• Procedures and Responsibilities: systems and responsibilities for monitoring, data flow, risk analysis, and control activities

At least once a year, the shipping company must check whether the monitoring plan for each ship is still up-to-date. The monitoring plan shall be updated in the following situations:

• When the ship changes company
• When new greenhouse gas emissions occur due to new emission sources or new fuels
• When availability of data changes
• When data resulting from the monitoring method has been found to be incorrect
• When any part of the monitoring plan is identified as not conforming to the requirements

Guiding Principles for Monitoring Plans:

The guiding principles, outlined in Article 4 of the MRV Maritime Regulation, serve as best practices for shipping companies:

• Completeness: all fuel-consuming equipment and emission sources on board, including engines and auxiliary machinery, must be fully accounted for. Fuel consumption from all emission sources must be monitored and reported. This ensures a comprehensive approach, covering every source of emissions and type of fuel used on the ship
• Consistency and Comparability: emission data should remain consistent over time, and methodologies for monitoring must not be changed arbitrarily. All monitoring activities must follow the approved MP, which is assessed by an independent verifier. Maintaining consistency in data collection allows for reliable comparison across different reporting periods
• Transparency: data collection, calculation methods, and monitoring processes should be clearly documented, with all relevant information securely stored for verification purposes. Transparency ensures that data can be easily accessed by authorized parties, such as verifiers and the administering authority. This also helps shipping companies ensure smooth internal transitions and avoid errors that may lead to penalties or misreporting of EU allowances
• Accuracy: shipping companies must ensure that their data is accurate, exercising due diligence to avoid systematic or intentional errors. This principle requires companies to aim for the highest level of precision in their monitoring, reporting, and data management practices, reducing the risk of flawed emissions reports
• Integrity of Methodology and Emissions Report: the monitoring methodology must be robust, ensuring that verifiers can achieve "reasonable assurance" in their assessments. Data must be free from significant errors and avoid any bias, whether intentional or accidental. The resulting emissions report should reflect the ship’s emissions accurately and credibly

• Continuous Improvement: shipping companies are encouraged to regularly assess and improve their monitoring methodology. Feedback from verification reports or the administering authority should be used to update the MP as needed. Continuous improvement ensures the MP remains relevant, especially when new emission sources or fuels are introduced, or when better data handling practices become available

Shipping companies are encouraged to follow these principles to ensure compliance and maintain the integrity of their emissions reporting.

The NEa conducts a completeness test to determine if an MP (Monitoring Plan) is complete before initiating a full evaluation. Further details about the completeness test are available on this webpage. A preliminary review of MPs submitted to NEa has revealed that many of them have deficiencies in similar areas. This webpage provides a list of these common deficiencies found in MPs.

Emissions Report

From 2025, by 1st of April of each year, shipping companies must submit an emissions report for each ship under their responsibility. This is an emissions report for the entire reporting period of the previous year.

The emissions report shall be drafted using the format stated in Annex II of implementing regulation 2023/2449, verified and submitted via THETIS-MRV. 

There are two parts of the emissions report: the MRV part and the ETS part.

1. In the MRV part, shipping companies report all emissions of carbon dioxide, methane and nitrous oxide per ship. Also, the fuel consumption, distance travelled, time spent at sea and cargo or persons carried shall be reported
2. In the ETS part, various subtractions can be applied to the emissions for ships, voyages and fuels meeting the required criteria. The subtractions must be carried out in the order A through G. When the format of the emissions report is followed, these steps will automatically be taken

Emissions report
Part	Subtraction Type	Description
A	Total emissions monitored	The total CO2 emissions monitored under the EU MRV. From the 1st of January 2026 the total emissions for Part A will also include the CH4 and N20 emissions.
B	Zero rating of sustainable fuels	Shipping companies may claim a zero-emission factor for biofuels, provided that the required evidence is demonstrated. This approach reduces the reported total emissions and, consequently, lowers the surrender obligation under the EU ETS Directive. To qualify for the zero rating of biofuels, shipping companies must demonstrate that the biofuel complies with the monitoring and reporting procedures outlined in the MRV. For this, shipping companies should include biofuels in their monitoring plan and describe a procedure used to determine the CO2 emission factors of biofuels in accordance with Point 1.2 of Part C to Annex II to the MRV. The procedure should include the specific method by which compliance with the applicable sustainability and greenhouse gas savings criteria are demonstrated. This compliance is in principle evidenced through a Proof of Sustainability (PoS). The shipping company must be able to provide a PoS based on a voluntary scheme or national certification scheme, which is approved by the Commission under the sustainability framework of Directive 2018/2001 (the Renewable Energy Directive or RED). The PoS should apply to the specific fuel batch that has been purchased by the shipping company.
C	50% of emissions for Extra EU voyages	Only half of the emissions from voyages to and from third countries (extra EEA ports) are subject to the EU ETS surrender obligation. Several nearby “transshipment ports” will not be treated as extra EEA port. Find the list here
D	Zero rating for CO2 storage or use	For CO2 which has been demonstrably permanently stored in either a storage facility with a permit in accordance with Directive 2009/31/EC or bound in a product. Rules regarding the requirements for considering a greenhouse gas as having being permanently chemically bound are currently under development.
E	Until 2030: Derogations for EU Outermost regions and routes falling under Public Service Obligations (PSO’s) and small islands.	The European Union counts nine outermost regions  The Azores and Madeira (Portugal); the Canary Islands (Spain); Guadeloupe, French Guiana, Martinique, Mayotte, Réunion, and Saint Martin (France). List of recognised public service obligations and islands meeting small island criteria is published in Implementing decision (EU) 2023/2895.
F	Until 2030: 5% reduction for ships with an ice class	Until 2030 for ships with ice class IA or IA super, or an equivalent ice class established based on the HELCOM recommendation 25/7.
G	Apply the EU ETS phase in percentages	As per the EU ETS directive the surrender obligation is: 40% of 2024 emissions 70% of 2025 emissions 100% of emissions from 2026 onwards.

The emissions report shall be verified as satisfactory by a verifier and then submitted via Thetis-MRV to:

• The relevant administering authority
• The authorities of the ships flag state (if it is flying the flag of an EEA country)
• The European Commission.

Report at company level

From 2025, by 1^st of April each year, shipping companies must also submit an emissions report at company level, for ships falling within the scope of the ETS Directive. The emissions report at company level must be drafted using the format stated in Annex IV of implementing regulation 2023/2449.

The report must include:

• A list of all ships under the companies responsibility
• The sum of all ships total aggregated emissions of greenhouse gasses (expressed in tonnes of CO₂ equivalent), disaggregated by individual greenhouse gas (CO₂, N₂O and CH₄)

The emissions report at company level shall be verified as satisfactory by a verifier and then submitted via THETIS-MRV to:

• The relevant administering authority
• The authorities of the ships flag state (if it is flying the flag of an EEA country)
• The European Commission

Verification

Shipping companies need to have the monitoring plans and emissions reports verified by a verifier.

Monitoring plan

In order for verification of the monitoring plan to run smoothly, shipping companies must provide the verifier with information such as: the relevant monitoring plan (in accordance with the model in Annex I of implementing regulation 2023/2449), information about the ship’s installations, emission sources and flow meters, procedures for data flow and control activities, the risk analysis and changes in the monitoring or reporting system. The verifier 

may also request other relevant information from the shipping companies. You can find more details on the information to be provided in article 4 of Regulation (EU) 2023/2917.

Based on this information, the verifier shall carry out the verification. The verification can take place on location, digitally or without a site visit. Shipping companies are required to grant the verifier access to their locations, such as offices or ships. In case of any deviations, they will be informed by the verifier. They then correct the deviations and submit an improved monitoring plan to the verifier. The verifier shall send the shipping company the conclusions regarding the verification. The shipping company then submits the monitoring plan and these conclusions to the administering authority via THETIS MRV.

Emissions report

For the verification of the emissions reports and aggregated emissions report at company level, the shipping companies must provide the verifier with information such as: a list of voyages carried out by the ship in question, information on data gaps, a copy of the emissions report of the previous year and a copy of the monitoring plan applied with the conclusions of the verifier of the monitoring plan and evidence of the approval of the monitoring plan by the administering authority.

Shipping companies shall also provide the verifier with copies of the ships official logbook and of the oil record book, copies of bunkering documents, copies of relevant certificates concerning fuels and copies of documents containing information on the amount of cargo or passengers carried, time spent at sea and distance travelled. The verifier may ask the shipping companies to provide additional relevant information.