Operational Guide · Registers & Logbooks

# Review of the EU MRV Framework in Light of the EU ETS

The EU MRV Regulation existed years before the maritime EU ETS, but since 2023 has been rewritten piece by piece to become the data infrastructure the entire allowance-trading mechanism rests on: understanding its evolution separately from the ETS gives an incomplete picture.

EU MRV EU ETS emissions monitoring reporting

## Operational Explanation

The EU MRV Regulation (Monitoring, Reporting, Verification) predates the maritime EU ETS as a system for monitoring and reporting CO2 emissions from maritime transport, but since 2023 it has been the subject of successive amendments specifically to adapt it to the inclusion of the maritime sector in the EU ETS. From 1 January 2024 its scope was extended to methane (CH4) and nitrous oxide (N2O) in addition to CO2; from 1 January 2025 the scope of application was further extended to offshore ships above 400 GT and general cargo ships between 400 and 5,000 GT, categories previously excluded.

2026 will be a year of formal review: the European Commission will conduct an assessment of the scope of the maritime EU ETS, examining in particular a possible further extension to ships below 5,000 GT (but not below 400 GT) and relevant developments under way at the IMO, with direct implications also for the future scope of the MRV Regulation that forms its data foundation.

## Regulatory Reference

EU MRV Regulation (Regulation (EU) 2015/757 and subsequent amendments): extended to CH4/N2O from 1 January 2024 and to offshore ships >400 GT and general cargo 400-5,000 GT from 1 January 2025; the European Commission's review expected in 2026 will assess a further extension of the maritime EU ETS (and consequently its MRV scope) to ships below 5,000 GT but not below 400 GT.

## Scope of Application

Every ship falling within the scope of the EU MRV Regulation per the tonnage threshold currently in force, including the ship categories added from 1 January 2025 (offshore >400 GT, general cargo 400-5,000 GT).

## Procedure / How to Complete It

1. Verify whether your ship falls within the updated MRV scope, especially for the categories added from 1 January 2025 (offshore, general cargo below 5,000 GT).
2. Update emissions monitoring plans to include CH4 and N2O in addition to CO2, a requirement in force since 1 January 2024.
3. Monitor the outcomes of the European Commission's 2026 review of the maritime EU ETS scope, since a further extension of the minimum tonnage threshold would directly impact the MRV scope as well.
4. Coordinate MRV reporting with the parallel EU ETS and FuelEU Maritime obligations, since they largely share the same emissions monitoring data foundation.
5. Verify alignment between reported MRV data and that used to calculate EU ETS allowances due, to avoid discrepancies that could be challenged during verification.

## Practical Example

Example: a 4,500 GT general cargo ship, previously excluded from the MRV scope, verifies at the start of 2025 that it now falls under the monitoring and reporting obligation following the threshold extension, and updates its monitoring plan to also include CH4 and N2O alongside the CO2 already monitored.

## Real Cases

The extension of the MRV scope to offshore ships and general cargo below 5,000 GT from 2025, combined with the European Commission's 2026 review of a further possible extension of the EU ETS to even smaller ships, illustrates how the European regulatory framework on maritime emissions is continuously evolving: Companies operating ships near the relevant tonnage thresholds must actively monitor every change in scope, since a threshold change can suddenly bring a previously excluded ship within scope.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Scope of application of the MRV Regulation checked only once and never updated over time | A ship falling within a recently included category (e.g. general cargo 400-5,000 GT from 2025) without the Company noticing promptly | Periodically re-check the MRV scope of application, especially for ships near the relevant tonnage thresholds
Emissions monitoring plan not updated to include CH4 and N2O after the 2024 extension | Incomplete reporting relative to current MRV requirements | Always update the monitoring plan in line with the MRV Regulation's scope/substance extensions
MRV data and data used to calculate EU ETS allowances managed as separate, unaligned systems | Discrepancies that could be challenged between MRV reporting and the calculation of allowances due | Always coordinate MRV reporting with the parallel EU ETS obligations on the same data foundation

## PSC Observations

Compliance with the EU MRV Regulation is not typically subject to direct PSC verification, being an EU regulation managed through independent accredited verifiers, but non-compliance can result in administrative penalties and, in extreme cases, restrictions on access to EU ports.

## Operational Tips

- Periodically re-check whether your ship falls within the updated MRV scope, especially if it is near the relevant tonnage thresholds.
- Always update the emissions monitoring plan in line with the most recent substance/scope extensions of the MRV Regulation.
- Actively monitor the outcomes of the European Commission's 2026 review: a threshold change can have a direct impact on your fleet.

## Checklist

- MRV scope of application verified against the tonnage threshold currently in force
- Monitoring plan updated to include CH4 and N2O in addition to CO2
- Outcomes of the European Commission's 2026 review monitored for any impact on scope
- MRV reporting coordinated with the parallel EU ETS and FuelEU Maritime obligations
- Alignment between MRV data and EU ETS allowance calculation systematically verified

## FAQ

What is the difference between the EU MRV Regulation and the maritime EU ETS?
The MRV Regulation is the emissions monitoring and reporting system that provides the data foundation; the maritime EU ETS is the allowance trading mechanism that uses that data to calculate the allowances owed by Companies.
What changes entered into force in the MRV scope in 2024 and 2025?
From 1 January 2024, the extension to CH4 and N2O in addition to CO2; from 1 January 2025, the extension of scope to offshore ships above 400 GT and general cargo ships between 400 and 5,000 GT.
What will the European Commission's 2026 review of the maritime EU ETS assess?
A possible further extension of scope to ships below 5,000 GT (but not below 400 GT), in addition to relevant developments under way at the IMO.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

EU ETS and FuelEU Maritime CII (Carbon Intensity Indicator)

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