carbon marketcarbon priceEmissionseu carbonEU ETSEuropean Commissionshipping companiesverified emissions
3 min read

EU ETS & MRV in Shipping: Defining Responsibility Between Owners and Managers

Shipping companies need to establish clear lines of responsibility both for reporting emissions under the EU’s MRV (Monitoring, Reporting and Verification) regime and surrendering EU Allowances (EUAs), or carbon credits, to the authorities.       Currently, the technical manager is typically the designated Document of Compliance (DoC) holder who is responsible for MRV reporting of […]

OceanScore
OceanScore’s review of BIMCO’s FuelEU Maritime clause and its challenges.

Shipping companies need to establish clear lines of responsibility both for reporting emissions under the EU’s MRV (Monitoring, Reporting and Verification) regime and surrendering EU Allowances (EUAs), or carbon credits, to the authorities.  

 

 

Currently, the technical manager is typically the designated Document of Compliance (DoC) holder who is responsible for MRV reporting of fleet emissions data. However, the EU has now ruled that the registered shipowner is the default responsible legal entity for emissions monitoring and reporting, and surrendering of EUAs, effectively making the owner the DoC holder. 

 

 

The same company must be responsible both for emissions reporting and EU ETS compliance through surrender of EUAs. This responsibility can be delegated to the technical manager provided there is an agreement in place with the owner along these lines. Some practical aspects related to monitoring and reporting – such as developing a monitoring plan and emissions reports – can still be outsourced to the manager, while the owner retains legal responsibility as DoC holder. 

 

 

An updated monitoring plan must be submitted to the authorities by 1 April 2024. This has been expanded to cover additional obligations under the MRV and EU ETS, including elements such as emission factors for methane and nitrous oxide, as well as CO2, and procedures for data flow and risk assessments. 

 

 

Annual emissions reported under MRV will form the basis of a verified emissions report that will determine the volume of allowances to be purchased and surrendered to the authorities each year. 

 

 

We strongly advocate for a clear demarcation and straightforward structure where either the manager or the owner is responsible for both MRV emissions reporting and surrendering EUAs, as combined set-ups only add unnecessary complexity. 

 

 

A key consideration in this regard is who is best positioned with the resources and know-how: does the owner or manager have access to the relevant data, can implement corrections and discuss complex questions with the verifier? In most cases, this will favour the manager as the one taking on EU ETS responsibility.  

 

 

If the manager is entrusted with overseeing a vessel’s EU ETS processes, the structure of the Shipman management agreement should mirror that responsibility with simple rules for emissions reporting. Ideally, the Shipman should allow the manager to procure EUAs as needed without cumbersome approval procedures. We therefore advocate a simpler Shipman framework than that recommended by Bimco to avoid intricate processes for procurement of EUAs required from owners for off-hires and periods of unemployment.  

Related posts

The EU ETS poses a costs management challenge for shipping companies, according to OceanScore co-Managing Director Albrecht Grell.
emissions trading system euEU ETSeu ets managementfinancial blancingshipping companies
6 min read

Shipping companies must manage financial balancing act on EU ETS tightrope, says OceanScore

Shipping companies face rising costs and risks from the EU Emissions Trading System (EU ETS) in 2026, with higher carbon…

OceanScore
FuelEUpooling
4 min read

FuelEU Maritime Pooling: A Viable Strategy

FuelEU allows for pooling compliance deficits and surpluses as one way to secure compliance. OceanScore analyses continues to show that…

OceanScore
EU ETSFuelEUFuelEU pooling marketplace
4 min read

Navigating EU Maritime Regulations: A Different Challenge for Commercial Pools, Operators and Charterers

As global trade grows and decarbonization pressures increase, the shipping industry is facing heightened scrutiny over its environmental impact. At…

OceanScore
Shipping industry professionals discussing EUA procurement strategies and emissions cost management.
carbon dioxide equivalentEmissionsemissions trading system eueu emissionseu emissions trading systemEU ETSEUAsEuropean Union emissions tradingsecondary market
3 min read

EUA Trading Strategy for Shipping: How to Buy EU Allowances Efficiently

EUAs can be purchased at a fixed price at auctions arranged during the year by the European Energy Exchange. They…

OceanScore
eu emissions trading systemFuelEUfueleu maritime regulationfueleu plannermaritime regulation
6 min read

Running the numbers: OceanScore reveals ship segments set to feel €1.3bn sting of FuelEU penalties

OceanScore analyzes the financial impact of FuelEU Maritime regulations, forecasting penalties for various shipping sectors. The report highlights key areas…

OceanScore
4 min read

Maritime Compliance in 2026: What Commercial and Technical Teams Need to Prepare For

2026 will be a decisive year for maritime compliance. As FuelEU Maritime completes its first compliance cycle, EU ETS reaches…

OceanScore
compliance manager
3 min read

Forecasting for Maritime Compliance: A Closer Look Inside OceanScore’s Compliance Manager

A Forecasting Module That Earns Global Praise OceanScore’s Compliance Manager entails a forecasting module for maritime compliance that is receiving…

OceanScore
Shipping companies managing EU ETS carbon credit trading and compliance risks.
emissions trading system eueu allowance euaeu carbonEU ETSeu ets management
7 min read

Trading places: shipping must manage new financial risks with transition to EU ETS, says OceanScore

A collaboration agreement has been signed between a classification society ClassNK and a maritime data and technology firm OceanScore to…

OceanScore
Cargo ship navigating EU ETS compliance.
complex regulationseu allowance euaeu emissionsmonitoring planshipping companies
5 min read

OceanScore identifies EU ETS best practice to tackle ‘strategy gaps’ on compliance

Many shipping companies are still striving to define their strategy for EU ETS compliance some 80 days after implementation of…

OceanScore
DoC HolderEU ETSFuelEUfueleu maritime regulationimoMEPC83
3 min read

MEPC 83: The New Global Carbon Rules

MEPC83 approves complex global GHG reduction rules for shipping, introducing dual thresholds, remedial units, and a FuelEU-like system starting 2028.

OceanScore
Turn obligation into opportunity

Turn obligation into opportunity

Explore our maritime emissions compliance solutions designed to meet evolving regulations like EU ETS and FuelEU Maritime.

our clients and partners