How Will the 2026 EU Maritime MRV, EU ETS and FuelEU Maritime Proposal Change Compliance for Shipping Companies?
Abstract
The European Commission’s proposal of 17 July 2026, COM (2026) 620 final, amends Regulation (EU) 2015/757 on maritime monitoring, reporting and verification — EU MRV — and Regulation (EU) 2023/1805 on FuelEU Maritime. Although legally separated from the broader EU ETS revision proposal, COM (2026) 616, the proposal is designed to align maritime MRV, EU ETS and FuelEU Maritime compliance.
The central change is the creation of a single monitoring, reporting and verification framework covering both greenhouse gas emissions and energy used on board ships. Shipping companies would submit one monitoring plan and one MRV report, which would support both ETS and FuelEU obligations. The proposal also expands MRV coverage for certain ships between 400 and 5,000 gross tonnages, strengthens rules for offshore operations, integrates well-to-wake energy data, and consolidates verification and accreditation procedures.
For shipping companies, the reform offers administrative simplification but also raises the importance of data quality, fuel certification, energy-use tracking and contractual compliance management.
1. Why Is the Proposal Important?
The European Commission’s COM (2026) 620 final proposal aims to simplify and align the compliance framework for maritime transport under three related EU climate instruments:
• EU MRV Regulation — Regulation (EU) 2015/757
• EU ETS maritime rules — Directive 2003/87/EC
• FuelEU Maritime — Regulation (EU) 2023/1805
At present, shipping companies face partially overlapping obligations. EU MRV collects emissions data, EU ETS uses verified emissions data for allowance-surrender obligations, and FuelEU Maritime requires information on the greenhouse gas intensity of energy used on board. These systems are related, but their procedures and documentation are not fully integrated.
The proposal therefore seeks to create a single data and verification pathway. The purpose is not to create a new climate regime, but to make the existing regimes operate through a more coherent compliance with architecture.
The proposal is separated from the broader ETS proposal only for legal reasons. In policy terms, it should be read together with COM (2026) 616, the general EU ETS revision proposal.
2. What Is the Core Change?
The core change is the expansion of the EU MRV system so that it covers not only greenhouse gas emissions but also energy used on board ships.
This is a major shift. The MRV Regulation would become the common data platform for:
• EU MRV reporting;
• EU ETS maritime compliance;
• Fueleu Maritime monitoring and reporting;
• Verification of fuel and energy data;
• Calculation of fueleu compliance balances.
The term “emissions report” would be replaced by “MRV report”, reflecting the broader scope of the report. Similarly, under FuelEU Maritime, the term “FuelEU report” would be replaced by “MRV report.”
• In practical terms, companies would move toward:
• One monitoring plan;
• One MRV report;
• One verification framework;
• One set of core data for MRV, ETS and fueleu purposes.
This is the key simplification element of the proposal.
3. How Will the Monitoring Plan and MRV Report Change?
Under the proposal, each ship would have a single monitoring plan covering both emissions and energy use. The plan would need to include the information required for EU ETS and FuelEU Maritime compliance. The monitoring plan would cover, among other elements:
• Greenhouse gas emission sources;
• Fuel consumers installed on board;
• Types of fuel used;
• Energy used on board;
• Substitute sources of energy;
• Zero-emission technologies;
• On-shore power supply equipment;
• Wind-assisted propulsion systems;
• Applicable emission factors;
• Well-to-tank and tank-to-wake information;
• Procedures for monitoring fuel consumption and energy use;
• Derogations or adjustments under eu ets and fueleu maritime.
The MRV report would also become broader. It would include greenhouse gas emissions, energy used on board, fuel type, emission factors, OPS use, well-to-wake emissions information and data needed for FuelEU compliance. The reporting calendar would broadly follow this structure:
4. What Changes for FuelEU Maritime?
FuelEU Maritime would be closely integrated into the EU MRV framework. Instead of maintaining a separate reporting structure, FuelEU would rely on the MRV monitoring plan and MRV report. However, FuelEU would still require a specific Compliance Balance report. This report would be based on the verified MRV data and would include:
• the yearly average greenhouse gas intensity of energy used on board;
• the ship’s compliance balance;
• non-compliant port calls;
• time spent at berth in non-compliance with OPS requirements;
• yearly energy used on board, excluding OPS;
• yearly energy used from renewable fuels of non-biological origin.
This means that FuelEU reporting is simplified but not eliminated. The MRV report becomes the data foundation, while the Compliance Balance report remains the document that determines whether the ship meets FuelEU requirements. The proposal also preserves the key FuelEU flexibility mechanisms:
5. Which Ships Between 400 and 5,000 GT Are Affected?
The proposal is especially important for ships below 5,000 gross tonnages but not below 400 gross tonnages.
General Cargo Ships
From 1 January 2025, general cargo ships between 400 and 5,000 GT are within the EU MRV scope for commercial cargo voyages involving EU ports. The proposal confirms this approach and expands the MRV logic to include both:
• greenhouse gas emissions released; and
• energy used during relevant voyages and port stays.
This does not automatically mean that these ships are immediately subject to EU ETS allowance-surrender obligations. However, MRV inclusion creates the verified data infrastructure that may support future ETS integration.
Additional Ship Categories from 2029
The proposal also introduces MRV coverage for additional ship categories between 400 and 5,000 GT, including:
• Oil tankers;
• Chemical tankers;
• Gas carriers;
• Lng carriers;
• Ro-pax ships;
• Passenger ships.
The stated objective is to increase environmental effectiveness, preserve a level playing field and reduce the risk of circumvention.
6. What Are the New Rules for Offshore Operations?
The proposal introduces targeted rules for vessels performing or supporting offshore operations. These rules are designed to reduce avoidance risks and ensure that offshore-related emissions are properly monitored.The scope covers ships operating in connection with offshore worksites located in:
• The territorial sea of a Member State;
• The exclusive economic zone of a Member State;
• The continental shelf;
• The continental shelf sea of a Member State.
The rules apply to both:
• Ships below 5,000 GT but not below 400 GT; and
• Ships of 5,000 GT and above.
The proposal also introduces new definitions for offshore operations and offshore worksite. This is intended to prevent gaps in the MRV and ETS framework for ships engaged in or supporting offshore activities.
7. How Are Fuel Types and Emission Factors Treated?
The proposal strengthens the treatment of fuel data and emission factors. This is particularly relevant for FuelEU Maritime, because FuelEU focuses on the greenhouse gas intensity of energy used on board.The proposal uses the following distinction:
For fossil fuels, companies may not diverge from default well-to-tank emission factors. For biofuels, biogas, renewable fuels of non-biological origin and recycled carbon fuels, companies may use actual values if certified under a scheme recognised by the Commission.
This makes certification critical. Claims regarding low-carbon fuels must be supported by recognised evidence, not only by commercial purchase contracts.
8. What Is the Role of OPS and Alternative Energy Sources?
The proposal integrates on-shore power supply and substitute energy sources more directly into the MRV and FuelEU framework. Substitute sources of energy include:
• Renewable energy generated on board;
• Electricity supplied from OPS;
• Wind-assisted propulsion systems.
The monitoring plan would need to describe OPS equipment, connection capability, electrical power demand at berth and electricity delivered through OPS. It would also need to include information on zero-emission technologies and wind-assisted propulsion systems, where applicable.
This is important because FuelEU Maritime increasingly rewards lower-carbon energy use and penalises non-compliance with OPS-related obligations for relevant ship categories and ports.
9. How Does Verification Change?
The proposal establishes a more integrated verification and accreditation framework. Verifiers would assess not only emissions data but also the reliability, credibility, accuracy and completeness of energy-use data. Verification would cover:
• MRV reports;
• monitoring plans;
• FuelEU Compliance Balance reports;
• fuel and energy data;
• emission factors;
• OPS data;
• derogations and adjustments;
• consistency between reported MRV data and FuelEU compliance data.
Accreditation for FuelEU verification would be linked to accreditation under the MRV Regulation. The proposal also introduces automated systems, electronic templates and standardised data exchange formats. This is likely to improve consistency, but it also means that companies will need stronger internal data-control systems.
10. What Is the Expected Timeline?
The proposal provides for entry into force on the twentieth day after publication in the Official Journal of the European Union. The general application date is indicated as 1 January 2029 / the second year after entry into force, leaving final timing to the legislative process. Key dates include:
11. What Are the Practical Implications for Shipping Companies?
For shipping companies, the proposal has two sides.
On the one hand, it simplifies compliance by reducing duplication. Companies would benefit from a single MRV workflow instead of separate and overlapping processes. On the other hand, the proposal raises the importance of:
• energy-use data quality;
• fuel certification;
• well-to-wake emissions accounting;
• OPS documentation;
• alternative energy records;
• verifier-ready evidence;
• contract clauses allocating compliance responsibilities.
For operators of 400–5,000 GT vessels, especially general cargo ships, the proposal confirms that smaller ships are becoming part of the EU’s maritime climate-data architecture. Even where ETS allowance-surrender obligations do not yet apply, MRV inclusion should be treated as a strategic compliance signal.
Conclusion and Assessment
The 2026 proposal is best understood as a move toward a single maritime emissions and energy-data ecosystem. It does not simply adjust reporting terminology; it restructures the way maritime climate compliance data will be collected, verified and used.
The most important change is the integration of EU MRV, EU ETS and FuelEU Maritime through one monitoring plan and one MRV report. This should reduce administrative duplication, but it also increases the importance of accurate, auditable and fuel-specific data.
For FuelEU Maritime, the proposal confirms that compliance will depend heavily on verified energy-use data, well-to-wake emissions factors and certified low-carbon fuel claims. For EU ETS, the strengthened MRV system provides a more robust foundation for allowance-related obligations.
For smaller ships, particularly those between 400 and 5,000 GT, the direction is clear: the EU is expanding maritime climate oversight beyond the largest vessels. General cargo ships in this segment are already in the MRV system from 2025, while additional categories are expected from 2029.
Overall, the proposal should be seen as both a simplification measure and a tightening of data discipline. Shipping companies should respond by strengthening internal monitoring systems, reviewing fuel-procurement documentation, updating charterparty and management contracts, and preparing for more integrated ETS and FuelEU compliance.
References:
1-European Commission, Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2015/757 and (EU) 2023/1805 to simplify and streamline monitoring, reporting and verification and to align revisions of the EU Emissions Trading System, COM (2026) 620 final, Brussels, 17 July 2026.
2-European Commission, Proposal for a Directive of the European Parliament and of the Council amending Directive 2003/87/EC and Decision (EU) 2015/1814 as regards driving competitiveness and cost-effective decarbonisation, COM (2026) 616.
3-Regulation (EU) 2015/757 of the European Parliament and of the Council of 29 April 2015 on the monitoring, reporting and verification of greenhouse gas emissions from maritime transport, and amending Directive 2009/16/EC.
4-Regulation (EU) 2023/1805 of the European Parliament and of the Council of 13 September 2023 on the use of renewable and low-carbon fuels in maritime transport, and amending Directive 2009/16/EC.
5-Directive 2003/87/EC of the European Parliament and of the Council establishing a system for greenhouse gas emission allowance trading within the Union.
6- Directive (EU) 2018/2001 of the European Parliament and of the Council on the promotion of the use of energy from renewable sources.
7-European Maritime Safety Agency — EMSA, maritime emissions monitoring and reporting guidance materials.
8-International Maritime Organization, IMO Data Collection System for fuel oil consumption of ships.
9-International Maritime Organization, MARPOL Annex VI and related MEPC resolutions on EEDI, EEXI and CII