The maritime sector in the EU ETS

The maritime transport sector will be included in the EU Emissions Trading System (EU ETS) from 1 January 2024.

Ships that will be covered by the EU ETS

The maritime expansion initially (from 1 January 2024) covers CO2 emissions from 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.

Offshore ships of or above 5000 GT will be included from 1 January 2027.

The extension of the ETS to maritime transport includes:

  • 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.

Each shipping company already submitting reports to Thetis MRV will be assigned to an administering authority in an EU MS by the European Commission in a list to be published by 1 February 2024

Monitoring, Reporting and Verification (MRV)

Shipping companies will need to submit a monitoring plan for each of their ships falling within the scope of the MRV Maritime Regulation and the ETS Directive to their administering authority by 1 April 2024. By that date, the monitoring plan must have already been assessed as being in conformity with the MRV Maritime Regulation by an independent accredited verifier.

The monitoring plans, in accordance with the revised MRV Regulation, will now be mandatorily submitted through THETIS-MRV. This can be done either by filling in the online form (which will be deployed as of 5 January 2024) or by uploading files in accordance with the new template and IT format (please see the links for the "xml interface" in the FAQ of THETIS-MRV).

For a ship that falls within the scope of the MRV Maritime Regulation and ETS Directive for the first time after 1 January 2024, the shipping company must submit the monitoring plan to the administering authority within three months after the ship’s first port of call in a port under the jurisdiction of a Member State. The monitoring plan that is submitted to the administering authority must have already been assessed as being in conformity with the MRV Maritime Regulation by an independent accredited verifier.

Accounts in the EU ETS registry (Union Registry)

The Environmental Protection Agency (EPA) will contact the shipping companies who must register in the Irish domain of the Union Registry based on the list that the EU Commission will publish by 1 February 2024. The shipping companies included in the EU ETS, which are registered in one of the EU Member States, must open a compliance account in the country they are registered in.

Shipping companies that are registered in countries outside the EU but sail to EU Member States are also covered by the EU ETS and will be assigned to an EU Member State where they must open their compliance account.

The EU Commission determines, according to adopted guidelines, where the shipping companies need to open a compliance account.

Shipping companies that are covered by the EU ETS must open a compliance account on the Union Registry - known as a Maritime Operator Holding Account (MOHA) - see the revised EU regulation on the rules governing the Union Registry for more details.

Any entity (including an entity covered by the EU ETS and entities which are not) may apply to open a Trading Account in the Union Registry. These accounts cannot be used for compliance obligations under the EU ETS. The documentation requirements and fee for the opening of a trading account are more onerous than for a compliance account.

Both compliance accounts and trading accounts require at least two authorised (account) representatives at account opening, who can act on behalf of the account holder (the shipping company - i.e. the entity with responsibility for compliance) in the EU ETS.

Surrendering allowances (starting in 2025).

The companies that are covered by the EU ETS must surrender a number of eligible allowances each year, which corresponds to the total (verified) amount of greenhouse gases that the company has emitted the previous calendar year. One allowance corresponds to the emission of one tonne of CO2 emitted.

Shipping companies must surrender their first ETS allowances by 30 September 2025 for verified emissions arising in 2024 as reported by 31 March 2025.

The share of emissions that must be covered by allowances surrendered on the Union Registry gradually increases as follows:

2025: 40% of emissions reported for 2024 must be covered 

2026: 70% of emissions reported for 2025 must be covered

2027 and beyond: 100% of reported emissions for the previous calendar year must be covered.

The authorised (account) representatives associated with the MOHA must surrender the allowances by 30 September each year at the latest.

The maritime sector will not be allocated free allowances.

Trading of allowances

Anyone who has an account in the Union Registry can trade allowances regardless of the account type and there is no ceiling on the amount that can be traded (subject to certain single transaction thresholds). Allowances in the EU ETS are financial instruments, and the price varies depending on  market behaviour.

Allowances can be bought on certain auction platforms and trading markets. Allowances can also be traded between companies or individuals who have accounts in the EU ETS, regardless of which country the accounts are registered in, and whether they are trading or compliance accounts.

Account holders must enter into their own agreements concerning price, allowance volume, transaction date, etc., with the party with whom they wish to trade. Financial transactions relating to the purchase and sale of emission allowances take place outside the EU ETS registry and do not have to be notified to the EPA. It is only the transfers of the allowances that are performed in the Union Registry and no service fee is charged for performing such transactions.

Further Questions

Any further queries in relation to EU ETS (Maritime) within Ireland should be addressed to

For further information, please see resources on the website of the European Commission including an FAQ and Timing/Scope Infographic:

FAQ - Maritime transport in EU Emissions Trading System (ETS) (