EU MRV Regulation: Scope, Compliance Cycle, and Penalties

The EU MRV regulation requires any ship of 5,000 gross tonnage or above that calls at a port in an EU Member State to monitor its greenhouse gas emissions on a per-voyage basis, submit a verified annual emissions report through the THETIS-MRV platform, and carry a valid Document of Compliance on board. Since 2024 the reported figures also drive obligations under the EU Emissions Trading System, so the numbers you submit now translate directly into allowances you must buy and surrender. The framework is set out in Regulation (EU) 2015/757, as amended by Regulation (EU) 2023/957.¹

Which Ships and Voyages Are Covered

The regulation applies to any commercial cargo or passenger ship of 5,000 GT or above that calls at an EU port. Three voyage categories fall within scope: trips between two EU ports, voyages from a non-EU port into an EU port, and departures from an EU port to a non-EU destination.¹ Flag state doesn’t matter. A Liberian-flagged bulk carrier arriving in Rotterdam faces the same obligations as a Greek-flagged tanker docking in Piraeus.

Some vessels are excluded: warships, naval auxiliaries, fish catching or processing ships, wooden ships of primitive build, ships without mechanical propulsion, and government ships used for non-commercial purposes. Since January 2025, offshore support vessels of 400 GT and above have been brought into scope, lowering the entry threshold for that segment.

What You Must Monitor

For every voyage during the calendar year, companies record fuel consumption broken down by fuel type, distance traveled, time spent at sea, and cargo carried in metric tonnes or cubic metres. Every combustion source on board counts: main engines, auxiliary engines, boilers, and inert gas generators. Emissions are calculated using established emission factors for each fuel grade.¹

The gases in scope expanded on January 1, 2024. Alongside CO2, companies must now monitor methane (CH4) and nitrous oxide (N2O).² That matters especially for LNG-fueled vessels, where methane slip during combustion can be significant.

The regulation permits four methods for measuring fuel consumption:

Bunker Delivery Notes with periodic stocktakes, relying on fuel purchase records cross-checked against tank soundings.
Bunker fuel tank monitoring, using daily tank readings.
Flow meters installed on fuel supply lines to combustion equipment.
Direct emissions measurements of CO2 concentrations in exhaust gas streams, rarely used in practice.³

Most operators choose Bunker Delivery Notes because the data already exists for commercial purposes. Flow meters offer higher accuracy but require capital investment and ongoing calibration. Whichever method you pick must be documented in the vessel’s monitoring plan and applied consistently across the reporting period.

The Monitoring Plan

Every vessel in scope needs its own monitoring plan. It must cover the ship’s identification details and IMO number, a description of every CO2 emission source on board, the chosen fuel monitoring method, the emission factors applied to each fuel type, procedures for recording distance and cargo, and a method for filling data gaps.¹ The plan is submitted through THETIS-MRV using standardized electronic templates, and an independent verifier accredited by a national accreditation body must assess it before it takes effect.⁴ If the ship changes engines, switches fuels, or alters its operational profile, the plan needs updating and re-verification.

How Emissions Are Allocated by Route

Not every emission tonne counts equally. The framework distinguishes intra-EU voyages from extra-EU voyages, and the same split applies both to MRV reporting and to the EU ETS allowance obligations that flow from it:

Intra-EU voyages, such as Hamburg to Marseille: 100% of emissions count.
At berth in an EU port: 100% of emissions count.
EU to non-EU voyages, such as Rotterdam to Shanghai: 50% of emissions count.
Non-EU to EU voyages, such as Shanghai to Rotterdam: 50% of emissions count.⁵

Operators running mostly intra-EU services carry a proportionally larger compliance burden than those on intercontinental routes.

The Annual Compliance Cycle

Two dates anchor the year. After the monitoring year ends, the verified emissions report must be submitted through THETIS-MRV by March 31 of the following year. That deadline shifted from the original April 30 under the 2023 amendments.² For reporting year 2025, that means March 31, 2026.

The second date is June 30. By that day each year, ships must carry a valid Document of Compliance on board covering the previous reporting period. The document is issued by the verifier once it confirms the emissions report is satisfactory, and it remains valid for 18 months after the end of the reporting period it covers. Port state control inspectors check for it, and a missing or expired document triggers further scrutiny.

Verification is not a simple audit. The verifier evaluates whether the monitoring plan was actually followed, whether data gaps were handled properly, and whether the reported figures are plausible given the vessel’s operational profile. The verifier must be independent from the shipping company.

Who Regulates Your Company

Each shipping company falls under a single EU Member State, no matter how many EU ports it visits. The hierarchy is:

EU-registered companies are administered by the Member State where the company is registered.
Non-EU companies with EU voyage history fall under the Member State with the greatest estimated number of port calls over the previous four monitoring years.
Non-EU companies with no prior EU voyages are assigned to the Member State where the ship first arrives on a voyage in scope.⁵

The administering authority reviews your monitoring plans, receives your emissions reports, and holds the power to impose penalties. For non-EU companies, the assignment can shift if trading patterns change over time, and the European Commission publishes lists linking companies to their assigned authorities.

What the Reported Numbers Cost You

Since 2024, maritime transport is inside the EU Emissions Trading System, and the emissions data reported through MRV determines how many allowances the company must surrender. The obligation phases in:

2025 surrender for 2024 emissions: 40% of reported emissions.
2026 surrender for 2025 emissions: 70% of reported emissions.
2027 surrender and beyond, for 2026 emissions onward: 100% of reported emissions.⁵

From 2026, the EU ETS also covers CH4 and N2O for maritime transport, so those gases carry a direct cost and not just a reporting obligation.⁶ A company reporting 10,000 tonnes of CO2-equivalent for 2025 must surrender allowances covering 7,000 tonnes in 2026. With EU Allowance prices moving around EUR 65–75 per tonne, the exposure is real, and it reaches full weight from the 2027 surrender cycle.

To surrender allowances, companies need a Maritime Operator Holding Account in the Union Registry, opened through their assigned national administrator.⁷ Delaying the account request can leave you unable to surrender by the deadline, which becomes its own compliance problem.

Penalties for Non-Compliance

Each Member State sets its own penalty system, subject to the requirement that penalties be effective, proportionate, and dissuasive. There are no fixed EU-wide fine amounts; the exposure depends on which Member State administers your company. When a penalty is imposed, the issuing state must notify the European Commission, EMSA, other Member States, and the ship’s flag state.

The most severe consequence is an expulsion order. Under Article 20(3) of Regulation 2015/757, if a ship fails to comply with monitoring and reporting requirements for two or more consecutive reporting periods and other enforcement measures have failed, the Member State of the port of entry may issue an expulsion order. Once issued, every EU Member State must refuse entry to that vessel until the company fulfils its obligations and obtains a valid Document of Compliance.¹ The regulation preserves the right to admit ships in distress, and companies can challenge an expulsion order before a court or tribunal.

MRV Is Not FuelEU Maritime

A separate regulation, FuelEU Maritime (Regulation (EU) 2023/1805), applies to the same 5,000 GT ships but sets its own obligation: progressively reducing the greenhouse gas intensity of the energy used on board, starting at 2% below the 2020 baseline in 2025 and reaching 6% by 2030, 31% by 2040, and 80% by 2050.⁸ FuelEU uses its own monitoring plans and its own annual report, submitted through THETIS-MRV by January 31 each year. Meeting MRV obligations does not satisfy FuelEU, and vice versa.

1
EUR-Lex. Regulation (EU) 2015/757 of the European Parliament and of the Council
2
European Maritime Safety Agency. Reducing GHG Emissions – MRV Regulation
3
European Commission. Implementation of Shipping MRV Regulation – Working Paper on Monitoring Methods
4
European Maritime Safety Agency. THETIS-MRV Tutorials
5
European Commission. FAQ – Maritime Transport in EU Emissions Trading System (ETS)
6
European Commission. Reducing Emissions From the Shipping Sector
7
European Commission. Union Registry
8
European Commission. Decarbonising Maritime Transport – FuelEU Maritime