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EU ETS

Law firm WFW shares EU ETS and FuelEU compliance and exemptions checklists

Watson Farley & Williams’ Nick Walker and Valentina Keys present a guide for shipping companies to navigate through complexities of EU ETS and FuelEU Maritime regulation.

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Watson Farley & Williams LLP London Partner Nick Walker and Counsel Valentina Keys on Monday (2 September) published an article to guide shipping companies on the European Emissions Trading Scheme and FuelEU Maritime regulation: 

Since 1 January 2024, shipping companies have been subject to the expanded European Emissions Trading Scheme (“EU ETS”), have had to monitor their emissions, open trading accounts (see below) and been tasked with formulating more efficient fuel and route compliance strategies in preparation for the submission of their first reports in March 2025. This briefing and the bespoke compliance and exemptions checklists we have prepared will help guide you through the complexities of the EU ETS and FuelEU Maritime Regulation (“FEMREG”).

EU ETS and MOHAs

Shipping companies will be required to surrender their EU ETS allowances for the first time on 30 September 2025. For an analysis of the commercial and legal implications of EU ETS for shipowners, managers, charterers and other maritime participants see here and here. Against this backdrop, little progress has been made with the opening of Maritime Operator Holding Accounts (“MOHAs”) with only 940 or so MOHAs having been opened by shipping companies thus far¹. 

We understand that registries in various member states are struggling to manage the large volumes of applications that have been made. The fact that the EU ETS has only been partially implemented in member states (only a handful have so far implemented the EU ETS Directive 2023/959) does not help and the lack of understanding amongst registry staff of the complexities of the maritime industry stands as perhaps the biggest hindrance to the timely and effective opening of MOHAs. 

With this in mind, WFW has both prepared bespoke clauses to be inserted into charterparties, ship management agreements and MOAs and launched its own EU ETS/FEMREG risk management agreement in order to fill in the gaps that the regulations simply do not address (e.g., the EU ETS costs clause and dispute resolution mechanisms).

First Fuel EU deadline

In the meantime, importantly, the first of many compliance deadlines has just passed pursuant to FEMREG. FEMREG poses an even greater challenge due to its technically complex and pernickety nature with shipping companies required to submit their Fuel EU Monitoring Plans by 31st August 2024 (see our insight here). The European Commission has now released the long awaited FuelEU Monitoring Plan Template to assist with the submission (see here).

FAQs

Whilst the European Commission (“EC”) has now published FAQS for both EU ETS and FEMREG, it is important to remember that these are guidelines only and not legally binding. Nor do they delve into the level of detail that many in the industry are seeking. With a view to shedding more light on the missing detail and particularly on the scope and mechanics of both EU ETS and FEMREG,  WFW has prepared a compliance toolkit consisting of a compliance deadlines checklist; and a table of exemptions that apply under both EU ETS and FEMREG (which you can download here), as well as bespoke EU ETS and FEMREG clauses and agreements. It is important for shipping companies and their investors to be alive to these deadlines as well as to the exemptions when assessing applicability and preparing their compliance strategies.

Exemptions

The list of potentially available exemptions is far from straightforward. Whilst some apply under both EU ETS and FEMREG, others may only be available under one or the other. WFW’s checklist table covers all the available exemptions and divides them into three categories: (1) vessel size and class; (2) voyage types; and (3) maritime activity and ports of call. It can be particularly daunting to work out what constitutes a “small island” exemption, or that of an “Outermost Region”.  Six exemptions are available under (1); ten exemptions are available under (2) and (3). You can view the table of exemptions by downloading our Compliance Toolkit here.

Key Compliance Deadlines

We have also prepared an EU ETS and FEMREG Compliance Deadlines Checklist to assist the industry with their internal planning and budgeting strategies. To access our EU ETS and FEMREG Compliance Deadlines Checklist, download our Compliance Toolkit here.

[1] Full list of MOHAs available here

 

Photo credit: CHUTTERSNAP from Unsplash
Published: 4 September, 2024

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Emissions reporting

StormGeo and OceanScore link emissions data, compliance workflows

Cooperation combines StormGeo’s expertise in operational vessel and emissions data with OceanScore’s expertise in emissions compliance workflows across EU ETS, FuelEU Maritime and UK ETS requirements.

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StormGeo and OceanScore link emissions data, compliance workflows

Weather intelligence and decision support solutions provider StormGeo and Hamburg-based technology platform OceanScore on Wednesday (3 June) said they have deepened their ongoing cooperation through the signing of a collaboration agreement during Posidonia 2026 in Athens on 2 June.

The cooperation combines StormGeo’s expertise in operational vessel and emissions data with OceanScore’s expertise in emissions compliance workflows across EU ETS, FuelEU Maritime and upcoming UK ETS requirements.

Together, the companies aim to help shipping companies seamlessly navigate increasing regulatory complexity more efficiently — from emissions reporting and data validation to compliance exposure management, pooling and financial settlement.

As emissions regulation becomes an increasingly important part of commercial shipping operations, the need for reliable operational data and streamlined compliance processes continues to grow. The cooperation between StormGeo and OceanScore is designed to support shipping companies with more connected, transparent and actionable processes across operational and commercial teams.

“From the outside, companies like StormGeo and OceanScore may sometimes be perceived as competitors because both operate around emissions and compliance workflows,” said Albrecht Grell, Managing Director at OceanScore. 

“But in reality, the industry increasingly needs both perspectives working together: trusted operational emissions data on one side and commercial compliance execution on the other. Our cooperation reflects that shipping companies are no longer looking for isolated solutions — they need connected processes, automated across different systems and reliable decision-making throughout the full compliance chain.”

By connecting validated operational emissions data with commercial compliance management, the cooperation supports workflows across:

  • emissions reporting and validation 
  • compliance management across EU ETS, FuelEU Maritime and upcoming UK ETS requirements
  • exposure visibility and cost transparency
  • pooling, settlement and financial processes 

The cooperation also aims to improve commercial transparency and coordination across operational and commercial stakeholders.

“StormGeo plays a central role in helping shipping companies turn operational vessel and emissions data into trusted, decision-ready insights,” said Espen Martinsen, Chief Commercial Officer at StormGeo. 

“As emissions regulations become more complex, this data is essential for transparent and efficient compliance management. By working with OceanScore, we can help customers connect StormGeo’s validated operational data with commercial compliance processes, creating a more integrated and practical approach to emissions management.”

The signing ceremony took place at the StormGeo booth during Posidonia 2026 in Athens and was attended by representatives from both companies.

Both companies expect the cooperation to continue evolving alongside upcoming regulatory developments, including FuelEU Maritime, EU ETS, the upcoming UK ETS and future emissions-related frameworks affecting global shipping.

 

Photo credit: StormGeo
Published: 4 June, 2026

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EU ETS

DNV: Making emissions data verification manageable at scale

DNV’s article features its customers sharing how a proactive, digital approach to emissions data verification is helping them manage reporting more efficiently and at scale to ensure compliance under FuelEU Maritime.

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Classification society DNV recently published a Maritime Impact article featuring its customers sharing how a proactive, digital approach to emissions data verification is helping them manage reporting more efficiently and at scale to ensure compliance under FuelEU Maritime: 

The FuelEU Maritime regulation has been in force since 1 January 2025, and the due date for verification of the first year’s emissions data at the end of April is imminent.

FuelEU Maritime adds reporting complexity

FuelEU Maritime (FEUM) has brought the number of emissions reporting obligations for ships operating in European waters to four, along with IMO DCS as well as EU MRV and ETS. The UK’s own MRV and ETS reports and any pooling arrangements under FEUM add further complexity. “Customers are finding it challenging to meet the verification due date,” says Conrad Golebski, Global Sales Manager, MRV, DCS, and FuelEU Maritime at DNV. “But non-compliance results in costs, which can be quite high for vessels that do not meet the emission targets.”

Data quality issues are widely underestimated

Preparing the document of compliance for the regulatory authorities has been an annual exercise – and a very stressful one, emphasizes Golebski. The annual verification process is often challenging, as the extent of data quality issues tends to be underestimated and only becomes apparent after year-end submissions, leading to a growing number of correction requests during verification for shipowners.

“Rectifying these issues can be a complex and time‑consuming process, involving an intense communication exchange before verification can proceed.”

There are two types of error that compromise data quality, says Golebski. “Human data entry errors must be corrected one by one. Systematic errors will affect the data of the entire fleet, and detecting and correcting them as early as possible will make a big difference towards minimizing the rectification effort.”

Continuous emissions data submission enables early, high quality verification

 “Clients who choose to upload their ships’ emissions data to the OVD Admin continuously throughout the year instead of waiting until January can benefit from our quality checking algorithms and make the necessary corrections as they go,” Golebski points out. “This will make the actual verification step the following spring much more comfortable and avoid missing the submission deadline.”

From DNV’s data warehouse, the data can be distributed to the client-requested services, such as Fleet Status, Emissions Insight, the DCS-, MRV-, and FEUM-specific applications, or Emissions Connect. 

“It is this centralized digital concept that makes our system so convenient,” says Golebski. 

“We maintain and update our infrastructure constantly to account for client needs and improve user-friendliness.

Note: The full DNV article can be found here

 

Photo credit: DNV
Published: 25 May, 2026

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Emissions reporting

Veson taps Veracity by DNV for verified emissions reporting

Product integration connects Veson’s IMOS with the Veracity platform, enabling emissions figures confirmed by DNV to flow directly into IMOS.

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Veson taps Veracity by DNV for verified emissions reporting

Maritime data and freight management solutions provider Veson Nautical (Veson), on Monday (27 April) has announced a strategic partnership with independent industry cloud platform, Veracity by DNV, to bring verified emissions data into the heart of operational and commercial shipping workflows. 

The product integration connects Veson’s IMOS with the Veracity platform, enabling emissions figures confirmed by DNV to flow directly into IMOS. Within IMOS, these figures are clearly tagged as verified and integrated directly into voyage financials and P&L — reducing reliance on disconnected systems and manual re-entry.   

The integration addresses the growing need for maritime operators to incorporate compliance and automated data quality checks into daily voyage decisions, P&L tracking, and regulatory reporting. By embedding these inputs directly into live P&L calculations, shipping companies can improve the accuracy of voyage results, reach settlement faster, and reduce audit risk. 

“This collaboration between Veson and Veracity by DNV is an exciting development for us at Hafnia,” said Michael Rasmussen, General Manager, Pool Management at Hafnia. 

“We have historically spent significant time toggling between systems to reconcile emissions data. Having verified, accurate data in one place has the potential to streamline that workflow and make it easier for our teams to work with trusted figures in their day-to-day operations.”  

Looking ahead, the partnership will further expand into an end-to-end emissions reporting and verification workflow. Operational vessel data can be automatically transferred from IMOS to DNV’s Veracity platform, where it can be quality-assured in line with the Operational Vessel Data (OVD) standard and passed to DNV’s verification services in Emissions Connect. 

This will provide joint customers with a continuous data flow from data collection to verified emissions data, which can be used to meet evolving frameworks such as EU ETS, FuelEUMaritime, and additional commercial use cases.

“The industry is moving toward a model where verified data is central to both compliance and commercial performance,” said Sean Riley, President and Chief Operating Officer at Veson Nautical. “With DNV we are connecting those two worlds, bringing trusted emissions data directly into the workflows that drive day-to-day decisions and voyage P&L outcomes.” 

“Together with Veson, we are demonstrating how verified data can unlock new value in commercial operations,” said Mikkel Skou, Executive Director, Veracity by DNV. 

“This partnership is a strong example of our envisioned maritime data ecosystem in action; a collaboration that enables our common customers to use their data as a trusted foundation for better decisions, stronger collaboration, and more efficient operations.”  

The partnership builds on Veracity by DNV’s extensive data network, which has connectivity to more than 65,000 vessels worldwide through automated access to verified data. As part of Veson’s expanding Platform Partner Network, DNV extends that reach into the core system where maritime commerce is managed — giving shipping companies access to trusted data within a more connected ecosystem.

 

Photo credit: Veson Nautical
Published: 28 April, 2026

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