Classification society DNV recently shared a summary of key deadlines and activities in 2025 related to key regulations for greenhouse gas (GHG) emissions.

The following is an excerpt from the news update:

Decarbonization is a top priority for ship owners. While the EU MRV and IMO DCS have become routine, new regulations such as the EU ETS and FuelEU Maritime present uncharted territory for many. Below is a summary of the key regulations and required actions for 2025:

EU MRV

To comply with EU MRV requirements, ship managers must ensure accurate emissions data and promptly submit their reports for verification by an accredited verifier. Once verified, managers are required to submit the reports to the THETIS-MRV system.

Deadlines in 2025:

• Submission (to verifier, DNV): 21 February (in which case DNV guarantees verification before the deadline)
• Verification: 31 March

EU ETS Company Emissions Report

The EU Emissions Trading System (EU ETS) Company Emissions Report is a crucial part of the compliance process for companies regulated under the EU ETS. This data is based on EU MRV emissions data for 2024. Some key points:

To create the EU ETS Company Emissions Report, all vessel emissions reports need to be verified and submitted to THETIS (this must be done prior to the submission of the EU ETS Company Emissions Report). Companies are also required to submit a report of their company emissions for the previous calendar year.

Companies are also required to surrender their EU ETS Allowances equivalent to their verified emissions.

The verification process shall ensure the accuracy and reliability of the reported data. Accredited verifiers, such as DNV, will check the emissions reports to confirm their correctness.

Deadlines in 2025:

• Submission of the verified Company Emissions Report: 31 March 2025. This deadline is for both ship and company emissions. Early submission is recommended.
• Surrender of the due EU ETS Allowances (from the Maritime Operator Holding Account (MOHA) holder in the EU ETS Union Registry): 30 September 2025.

Important note: DNV will provide EU ETS Company Emissions Report verification, and we will shortly follow up with more information in the My Services portal on Veracity on how to order the verification and how to upload the documents to THETIS-MRV.

FuelEU Maritime

Vessels trading in the EU/EEA* already have an approved FuelEU Maritime Monitoring Plan on board (deadline: 1 January 2025). There are no further deadlines for 2025, but DNV strongly encourages every affected company to take immediate action:

• Establish a strategy to minimize the cost of compliance.
• Review and update the commercial contracts between the technical manager/ISM company and ship owner – trusted data are crucial to manage financials and commercial management.
• Ensure the implementation of clear terms in commercial charter contracts that define the specific roles and responsibilities of all parties in compliance with the FuelEU Maritime regulations.
• For vessel pooling, it is important to note that if the legal declaration of pooling is made the year following the reporting period, most commercial decisions will need to be finalized during the 2025 charter negotiations.

Deadline in 2025:

• Continuous reporting and data verification for the EU MRV throughout 2025

*Note: The EEA EFTA countries Iceland, Norway and Lichtenstein are not yet part of the FuelEU Maritime due to delays in the process; implementation is expected shortly.

Partial FuelEU Emissions Report

The partial FuelEU Emissions Report is required when there is a change of company managing a ship (see Appendix in the pdf for more information). It should be noted that both the EU MRV and IMO DCS have specific requirements regarding changes of company. These requirements are detailed in the FAQ sections of the references listed below. DNV will offer partial FuelEU Emissions Reports from the end of Q1 2025 (THETIS functionalities are still under development).

IMO DCS Fuel Oil Consumption Report (FOCR)

The aggregated DCS data form the basis for the Carbon Intensity Indicator (CII) rating and the SEEMP Part III. Data quality and an efficient, digital system are key.

Deadline in 2025:

• Verified FOCR reporting: 31 May 2025

Note: DNV’s full summary of key deadlines and activities in 2025 related to key regulations can be found here. 

Photo credit: william william on Unsplash
Published: 12 February, 2025