Compliance Briefing — September 24, 2025

Executive briefing: The EU Emissions Trading System (EU ETS) now covers maritime transport, requiring shipping companies to monitor 2024 voyages and surrender allowances by 30 September 2025 for 40% of verified emissions. Regulation (EU) 2023/957 amends Directive 2003/87/EC to phase in coverage to 70% in 2025 emissions (delivered 2026) and 100% in 2026. Companies must use the THETIS-MRV platform to submit monitoring, reporting, and verification (MRV) data, reconcile it against Registry holdings, and document any use of the Maritime Transport Compliance Entity (MTCE) representative model.

Key compliance checkpoints

Allowance reconciliation. Confirm verified emissions reports align with allowances surrendered in Union Registry accounts, accounting for 40% liability for 2024 activity.
Data validation. Ensure accredited verifiers have signed off MRV reports and that THETIS-MRV submissions match aggregated voyage data, including port calls in the European Economic Area.
Contingency planning. Establish backup signatories and technical contacts to avoid delays when uploading surrender orders ahead of the 30 September deadline.

Operational priorities

Cash-flow coverage. Forecast allowance purchasing needs for the 70% compliance year (2025 emissions) and hedge EUA exposure accordingly.
MTCE governance. Where parent companies act as Maritime Transport Compliance Entities, verify board approvals and documented delegation agreements with each shipping company.
Audit evidence. Retain verifier statements, surrender transaction records, and calculation workpapers for competent authority inspections.

Enablement moves

Run drills that simulate registry downtime and demonstrate manual surrender contingencies.
Brief treasury and sustainability teams on forecast EUA requirements through the 2026 full coverage phase-in.

Sources

Zeph Tech supports maritime ETS compliance with allowance forecasting models, MRV data validation, and regulator-ready evidence packs.