Policy Briefing — EU ETS maritime coverage reaches 100% of verified emissions in 2026 compliance year
From 1 January 2026, shipping companies must surrender EU ETS allowances covering 100% of verified emissions from voyages touching EU ports, ending the transitional discounts that applied in 2024–2025.
Executive briefing: Directive (EU) 2003/87/EC, as amended by Directive (EU) 2023/959, phases maritime transport into the EU Emissions Trading System (ETS). After surrendering 40% of verified 2024 emissions and 70% for 2025, shipping companies must cover 100% of voyages, intra-EU trips, and half of third-country legs performed from 1 January 2026 onward, increasing allowance demand and compliance risk.
Mandatory deliverables
- MRV alignment. Ensure EU Monitoring, Reporting and Verification (MRV) Regulation data reconciles with ETS declarations for each ship above 5,000 gross tonnage.
- Allowance strategy. Update procurement plans to cover 100% of verified emissions for the 2026 compliance cycle, with surrender due by 30 April 2027.
- Cost pass-through documentation. Maintain contractual evidence for surcharges applied to charterers, including emissions statements and agreed apportionment clauses.
Program actions
- Data quality. Validate MRV telemetry, fuel consumption logs, and port call records to avoid discrepancies that trigger penalties from administering authorities.
- Financial planning. Stress test allowance budgets against higher carbon prices and consider hedging instruments or pooling arrangements permitted under Article 28a.
- Counterparty engagement. Update charter-party templates with emission-sharing mechanisms, dispute resolution steps, and escalation channels for missing voyage data.
Enablement moves
- Integrate ETS compliance dashboards with sustainability reporting teams to align CSRD climate metrics and carbon pricing disclosures.
- Coordinate with fuel procurement teams to evaluate alternative fuels and energy efficiency investments that reduce allowance exposure.