TECHNICAL AND REGULATORY NEWS No.

28/2023 – STATUTORY

PREPARING FOR THE EU ETS –

NEXT STEPS
Relevant for ship owners and managers of cargo and passenger ships above 5,000 GT sailing in the EU. November 2023

As of 1 January 2024, the EU ETS will include ships above 5000 GT transporting cargo and
passengers for commercial purposes. The EC has just adopted an implementing regulation
detailing which company is responsible for reporting and surrendering emission allowances.
This statutory news outlines the next steps to prepare for the EU ETS, and updates to the
EU MRV Monitoring Plan.
Options for managing the responsibility and practical
aspects related to the EU MRV and EU ETS
There are basically three options for managing the responsibil-
ity and practical aspects related to the EU MRV and EU ETS:

1. The registered owner takes on the responsibility for

compliance with the MRV and ETS and establishes its own
monitoring system
The owner company should provide its Administering
Authority (AA – see below) with a list of ships for which it
assumes responsibility with the MRV and ETS obligations. The
Background
registered owner must establish its own monitoring system,
The EU amended the Emission Trading System (EU ETS) Direc-
develop a Monitoring Plan, have it assessed by a verifier, and
tive to include shipping from 1 January 2024. The monitoring,
submit it to the AA by 1 April 2024.
reporting and verification requirements detailed in the EU MRV
regulation have also been revised to support the EU ETS.
2. The registered owner takes on the responsibility for
compliance with the MRV and ETS but delegates the
The European Commission (EC) is now in the process of devel-
practical monitoring to the ISM company
oping implementation and delegation regulations providing
The owner company provides its AA with a list of ships for which
more details, and DNV will communicate these in due course.
it assumes responsibility with the MRV and ETS obligations.

This news provides an update on the options for the respon-

The ISM company can continue with the monitoring and
sible shipping company, as well as other relevant technical,
reporting as today, but the Monitoring Plan must be updated
operational and commercial matters when preparing for ETS.
referring to the owner as the responsible entity. The ISM
Please make sure to visit our revamped EU ETS topic page
company will implement the Monitoring Plan and provide
with a comprehensive FAQ section providing you with even
the emissions reports for the registered owner. It is still not
more clarity and guidance on these critical topics.
decided if it will be possible for the ISM company to submit
the plans and reports in Thetis MRV on the owner’s behalf.
Shipping company responsible for the EU ETS
and EU MRV
3. The registered owner delegates the responsibility for
The EC has adopted an implementing regulation detailing
compliance with the MRV and ETS to the ISM manager
which company is responsible for monitoring and reporting
The registered owner company and ISM company must sign
greenhouse gas (GHG) emissions and surrendering emission
a document clearly indicating that the ISM company has been
allowances. The default responsible entity is the registered
mandated by the shipowner to comply with the MRV and ETS
owner, also if the ship is on a bareboat charter. The respon-
obligations. The ISM company may be mandated by several
sibility can be shifted to the technical manager – i.e. the ISM
owner companies, but it remains a single shipping company
company – only by an agreement between the registered
responsible for the combined fleet under the MRV and ETS.
owner and the ISM company explicitly stating the delegation.
Under this option, the existing Monitoring Plan can be con-
tinued, provided it is extended with the required additional
The company responsible for monitoring and reporting
elements required by the updated Monitoring Plan template
under the MRV regulation must be the same as the company
(see below).
responsible under the ETS directive for surrendering emis-
sion allowances. However, the practical aspects related to
Shipowners and ship managers should make an agree-
monitoring and reporting – such as developing a monitoring
ment on who assumes the responsibility for the EU MRV
plan, implementation, and developing emissions reports –
and EU ETS, and update any documentation as needed.
can still be performed by technical management companies.

DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime DNV Disclaimer of Liability Page 1/3
Administering Authority (AA)
Each company, whether it is the registered owner or ISM com-
pany, will be assigned to an AA of an EU/EEA member state.
Companies registered in an EU/EEA country will be assigned
to the AA of that country. Companies registered outside the
EU/EEA will be assigned to the AA of the country where their
ships had the most port calls the last four years. The EC will
provide a list of companies and their respective AA by
1 February 2024.
Each shipping company responsible for one or more ships
under ETS needs to apply for a Maritime Operator Holding
Account with its AA, within 40 days after the list is published
by the EC. The practicalities related to this will vary between
different AAs. The AA is then required to open the account
within an additional 40 working days.
The documentation requirements for opening an account
are common for all AAs and include:
• General info about the legal entity (e.g., name, address,
contact person)
• If the company is the registered owner: a list of ships for
which the company assumes control
• If the account holder is part of a group: a document clearly
identifying the structure of the group (certified true copy
required).
The AA may also ask for a document proving:
• Registration of the legal entity, its bank account details and
confirmation of VAT registration
• Name, date of birth and nationality of the legal entity’s
beneficial owner, including the type of ownership or control
they are exercising
• A copy of the instruments establishing the legal entity
• A copy of the annual report or of the latest audited finan-
cial statements, or if no audited financial statements are
available, a copy of the financial statements stamped by the
tax office or the financial director.
Companies, who know which AA they will be assigned
to, should apply for a Maritime Operator Holding
Account as soon as possible.
DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime
Change of company and partial emissions reports
In case of change of company (i.e., either the registered
owner or the ISM company), the MRV regulation requires that
a partial emissions report is verified and submitted in the
Thetis MRV no later than three months after the change. This
ensures that both the previous and the next companies can
submit a company level emissions report containing the emis-
sions for which each company was liable for surrendering
allowances for under the ETS in the reporting period.
The need for a partial emissions report strictly follows from
the responsible company, either the registered owner or the
ISM company. In case the owner has assumed the responsibil-
ity, a change in the ISM company will not trigger the need for
a partial emissions report. If the responsibility is delegated to
the ISM company and the ship changes owner, it will depend
on whether the new owner delegates the responsibility to the
same ISM company. If the new owner assumes the responsibil-
ity itself, or a new ISM company takes over the responsibility, a
partial emissions report is required.
Update of Monitoring Plan
An updated Monitoring Plan assessed to be in conformity
by a verifier must be submitted to the AA by 1 April 2024.
Regardless of which AA the company is assigned to, the
submission of Monitoring Plans and emissions reports is
performed through Thetis MRV.
The Monitoring Plan has been expanded to reflect the
additional obligations under the MRV and ETS. The new plan
template covers, among other smaller adjustments:
• Emission factors for CH4 and N2O, in addition to CO2
• Procedures related to determining the emission factors for
biofuels, RFNBOs (renewable fuels of non-biological origin)
and RCFs (recycled carbon fuels)
• Emission source class and slippage coefficient values for
LNG-fuelled ships
• Detailed information on the shipping company
• Information on application of carbon capture and storage
technologies
• Procedures covering data flow activities and risk assessment.
The figure on the following page summarizes the EU MRV/
ETS milestones as discussed in this news.
DNV Disclaimer of Liability Page 2/3
 MRV/ETS requirements timeline
MRV/ETS requirements timeline

1 Oct.
2023
New MRV secondary
legislation published 2024 2025 2026
12.03 01.04 30.04 31.03 30.09

Shipping company to apply for Operator

Holding Account with AA (40 days from 1 Feb)

Assessed
Revised MRV MP to be MRV MP
prepared* submitted
to AA**

Vessel MRV Vessel MRV

Emission Report Emission Report
submitted to AA submitted to AA

Emission
Company MRV
allowances
Emission Report
surrendered to
submitted to AA
AA

Annual MRV reporting period*** Annual MRV reporting period*** Annual….

*According to new MRV Monitoring Plan (MP) template

2025: General cargo (400–5000 GT) and offshore ships (400- GT)
**AA - Administering Authority assigned to shipping company by the European Commission
reporting MRV data
*** Vessels under current MRV scope will need to monitor emissions as per updated MP

1 DNV ©

DNV recommends that companies establish or update their Monitoring Plans and submit them for assessment as soon
as possible. Conveniently, the revised MRV Monitoring Plan online form from DNV is now available in Fleet Status on
Veracity to support the preparation, with information from the previous plan revision readily available. Validation rules
and info boxes will guide you to ensure all updated tables are filled in and the plan is ready to be submitted.

MRV Monitoring Plan >

Recommendations References
Ship owners and managers should make an agreement on • EU ETS – Emissions Trading System - DNV
who assumes the responsibilities for the EU MRV and EU ETS • Fleet Status (Veracity)
and to provide an updated Monitoring Plan to the verifiers. • Article of the European Commission
For DNV customers, the revised MRV Monitoring Plan online
form is available in Fleet Status on Veracity.

For customers:
AAs should be updated on the ships as soon as it is clear which DATE – Direct Access to Technical Experts via My Services on Veracity.
AA each company is assigned to. DNV recommends that com-
Otherwise:
panies, who know which AA they will be assigned to, apply for Use our office locator to find the nearest office.
a Maritime Operator Holding Account as soon possible.

DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime DNV Disclaimer of Liability Page 3/3